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Home My WebLink About10-0698 Our File No.: 237190 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire Attorney I.D.#38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff PALISADES COLLECTION, LLC c/o Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 Plaintiff, vs. BETSY J KURTZ 7 BAUGHMAN DR NEWVILLE, PA 17241-9711 Defendant. 1: ' 1 LED T?r?• lr?+i'... ?? rl i ? nti I :. J ' t? 2 IQ JA 28 Fri t: 42 COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: ?p - loq$ Civil Ip,J'h1 NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 $ga.oo PA Ate`/ ,X.* )!07(0107 Our File No.: 237190 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire, Esq. Attorney I.D.#38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff PALISADES COLLECTION, LLC ) c/o Apothaker & Associates, P.C. ) 520 Fellowship Road C306 ) Mount Laurel, NJ 08054 ) Plaintiff, ) vs. ) BETSY J KURTZ ) 7 BAUGHMAN DR ) NEWVILLE, PA 17241-9711 ) Defendant. ) COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is PALISADES COLLECTION, LLC c/o Apothaker & Associates, P.C., 520 Fellowship Road C306, Mount Laurel, NJ 08054. 2. Defendant(s) is/are BETSY J KURTZ, an adult individual residing at 7 BAUGHMAN DR NEWVILLE, PA 17241-9711. 3. Plaintiff, PALISADES COLLECTION, LLC, is the Assignee and Successor in Interest of Account #015900002002123569; and said account was issued to Defendant(s) by AT&T WIRELESS, the Original creditor. 4. Defendant received, accepted and used the account to its benefit. 5. This account is in default and Defendant(s) has an unpaid balance of $1,551.34. A true and correct copy of the total due and owing is attached hereto, made a part hereof and marked as Exhibit "A". 6. All credits, if any, to which Defendant(s) is entitled, have been applied to the account and are included in Exhibit "A". 7. Although demand has been made, Defendant(s) has failed to make payment of the amount due as above. WHEREFORE, Plaintiff demands judgment in favor of Plaintiff and against Defendant(s) for the sum of $1,551.34 and requests this Court award costs to the extent permitted by applicable law. APOTH=,R AS OCIATES, P.C. Atto y fo Plaintiff A Law Firm E kka2e in Debt Ctillectioi BY: David J. Apothaker, Esquire Dated: 1/21/2010 Our File No.: 237190 VERIFICATION David J. Apothaker Esquire hereby states that I am counsel for plaintiff in this action, and that I am authorized to take this Verification, and that the statements made in the foregoing Civil Action Complaint are true and correct to the best of my knowledge, information, and belief. The undersigned understands that the statements therein are made subject to the penalties of 18 Pa.C.S.A. 4904 relatin to worn falsification to authorities. David J. Apo aker, Esquire Attorney for -Plaintiff DATE: 1/21/2010 PALISADES COLLECTION, LLC BETSY J KURTZ 7 BAUGHMAN DR NEWVILLE, PA 17241-9711 STATEMENT OF ACCOUNT Debtor's Name: BETSY J KURTZ Account Number: 015900002002123569 Original Creditor: AT&T WIRELESS Balance Due: $1,551.34 Our File No.: 237190 EXHIBIT "A" SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Edward L Schorpp Solicitor ~$,,,a'cr ~~ ~~unll,,~~l~~~e~ ,, ~~~ ..~ - -.~I~ +,C "FIND-~r~lCttrn~t~t~i~ ~Jr T} {~ ~f~i~ ~ ~.t~1n'~..13.'~1r7T Palisades Collection, LLC vs. Betsy J. Kurtz 2000 FcB -$ P,"i 12~ 00 r 1::~ ~,v~ t 1;r, u.. Case Number 2010-698 SHERIFF'S RETURN OF SERVICE 02/02/2010 04:35 PM -Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on February 2, 2010 at 1635 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Betsy J. Kurtz, by making known unto herself personally, at 7 Baughman Drive, Newville, Cumberland County, Pennsylvania 17241 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $38.80 February 04, 2010 SO ANSWERS, R R ANDERSON, SHERIFF ty hs if Vic; vcu^y Suit!:: g;;t,;fF. "I^ieO..;it. Ic,;. ~ t Our file No.: 237190 - 2' APOTHAKER & ASSOCIATES, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff Attorney ID# 55140 ;~ ~ ~ «- ~-~~ ~ f.~,RY 2QIQ':i.~'t -5 PYi 3~ ~ i COURT OF COMMON PLEAS PALISADES COLLECTION, LLC ) CUMBERLAND COUNTY Plaintiff, ) DOCKET NO.: 10-698 CIVII. TER M vs. ) Civil Action BETSY J KURTZ ) STIPULATION 1N LIEU OF JUDGMENT Defendant. ) } The matters and things in controversy having been discussed by and between the parties, and a settlement having been agreed upon: It is on March O5, 2010, STIPULATED by and between Plaintiff, PALISADES COLLECTION, LLC, and Defendant, BETSY J KURTZ parties as follows: 1. Defendant agrees to pay the sum of $1,739.97, which sum Plaintiff agrees to accept in full settlement of its claim herein, inclusive of counsel fees and court costs. 2. The sum aforesaid of $1,739.97 shall be paid by the by Defendant, BETSY J KURTZ, to the attorneys for Plaintiff in the following manner: a. $75.00 to be paid on or before the 15th day of each month, beginning March 15, 2010 until paid in full. All checks are to made payable to PALISADES COLLECTION, LLC, and sent to: Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 C ~ ~~ w Our file No.: 237190 3. In the event Defendant fails to pay in accordance with the terms set forth in this Stipulation, then, and in that event, Plaintiff shall be entitled to obtain the entry of Judgment against Defendant ex pane, in the sum of $1,739.97, giving Defendant credit for any sums actually paid pursuant to the terms of this Stipulation. 4. In the event of default as aforesaid, Plaintiff shall be entitled to obtain the entry of Judgment upon ex pane application, with supporting certification, and with notice to Defendant only in the form of a copy of the application addressed to BETSY J KURTZ by first-class, postage prepaid. We hereby consent to the form and entry ~f the within Stipulation. APOTHAKER & ASSOCIATES, P.C. Attorneys for Pla' tiff A Law Firm Engage ebt Collection By: y F. Scian, Esquire B J KUR Our File No.: 237190 c C= -'' APOTHAKER & ASSOCIATES, P.C. R m m `- BY: David J. Apothaker, Esquire zM :rim Attorney I.D.# 38423 -<> 520 Fellowship Road C306 r-2: ---qc1 Mount Laurel, NJ 08054 v - 0 (800) 672-0215 N cis Attorney for Plaintiff r 1 ? PALISADES COLLECTION, LLC COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff, vs. BETSY J KURTZ NO. 10-698 CIVIL TERM Defendant. PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & ASSOCIATES, P.C. Attorney r Plaintiff A Law Firm EnwARetl in Debt Collection By: David J. Dated: 3/6/2012 , Esquire