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Home My WebLink About10-1196Our file No.: 241533 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. KIMBERLY SHARP 500 MULBERRY DR MECHANICSBURG, PA 17050 Defendant. FILE3 JL_ 1 1. 2010 FEB 22 A; ;11: E 0 COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 10 -11410 ai'f' I lPxmot 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 4g0J.00 PO A7W (`tF 1710103 1 d,3'7 85.5 Ourkile No.: 241533 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. KIMBERLY SHARP 500 MULBERRY DR MECHANICSBURG, PA 17050 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 KIMBERLY SHARP, an adult individual residing at 500 MULBERRY DR MECHANICSBURG, PA 17050. 3. Plaintiff, PALISADES COLLECTION, LLC, is the Assignee and Successor in Interest of Account #6019183000651836; and said account was issued to Defendant(s) by GE MONEY BANK, 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 $2,833.40. 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 It $2,833.40 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & AS O IATES, P.C. Attorney f P 'ntiff A Law Firm Engag d ' Debt Collection BY: Dated: 2/16/2010 David J. Apda. er, Esquire Our File No.: 241533 VERIFICATION David J. Auothaker. 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. Apothaker, Esquire Attorney for Plaintiff DATE: 2/16/2010 PALISADES COLLECTION, LLC KIMBERLY SHARP 500 MULBERRY DR MECHANICSBURG, PA 17050 STATEMENT OF ACCOUNT Debtor's Name: KIMBERLY SHARP Account Number: Original Creditor: Balance Due: Our File No.: 241533 6019183000651836 GE MONEY BANK $2,833.40 EXHIBIT "A" SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Edward L Schorpp Solicitor ~~~~~,tr gt ~u~ut,r~~~ ~ n ~~ n~~~;6 ~- ~ =~E;=~F~~ ~.}~ TNT ~i'ARY ?010 ~S~tR -3 A1~ 1! ~ 23 ~CI v~ y~~}ti~~V -1; ~~t~.. Palisades Collection, LLC Case Number vs. Kimberly Sharp 2010-1196 SHERIFF'S RETURN OF SERVICE 02!25/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Kimberly Sharp, but was unable to locate him in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant Kimberly Sharp. Request for service at 500 Mulberrry Drive, Mechanicsburg, PA 17050 does not exist. SHERIFF COST: $42.00 February 25, 2010 SO AN ANDERSON, SHERIFF Vic; Ceun'y~taite Snen`f. Te~easott, Inc. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson F~+~t=i~E Sheriff ~.~~ ~t "„urf~~,f ~ ~ ~ ~,~'~'~±`~'~,a~ Jody S Smith ~° ~~' Chief Deputy 7Q~~ Mib~ ~ 2 ~~ 8• ~g Edward L Schorpp Solicitor ~i4 = .. ~~~~~ ~~~i~~~~;~~ ~1 ~r~~ PrSYLYA~IA Palisades Collection, LLC Case Number vs. Kimberly Sharp 2010-1196 SHERIFF'S RETURN OF SERVICE 02/25/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Kimberly Sharp, but was unable to locate her in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant Kimberly Sharp. Request for service at 500 Mulberrry Drive, Mechanicsburg, PA 17050 does not exist. 05/10/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Kimberly Sharp, but was unable to locate her in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant Kimberly Sharp. Current resident of 500 Mulberry Drive, Mechanicsburg, PA 17050 advised Deputies Kimberly Sharp does not resided at this location. The Mechanicsburg Postmaster to date has not been able to provide a current address for the defendant. SHERIFF COST: $42.00 SO ANSWERS, May 10, 2010 RON R ANDERSON, SHERIFF (c) CouirySuite SFerat. Teieoso't. Inc. I'axDB Resu~tDetails Ilr>tai1P~ 1Znc~„1~~ ~ ,. D +..~ ~......u vu iw.~ui W LVl 1 QL VG DistrictNo 19 Parcel ID 19-23-0569-081A MapSuffix HouseNo 500 Direction Street MULBERRY DRIVE Ownerl SHEAFFER, THOMAS S & CHERI L C/O LIVING TRUST TRS PropType R PropDesc LivArea 3366 CurLandVal 25000 CurImpVal 258300 CurTotVal 283300 CurPretVal Acreage 1.00 CIGrnStat TaxEx 1 SaleAmt 1 SaleMo O 1 Sale Da 22 SaleCe 20 SaleYr O 1 DeedBkPage 00238-00155 YearBlt 1900 HF File_Date 10/27/2004 HF Approval Status A ( of 1 http://taxdb.ccpa.net/details.asp?id=19-23-0569-081 A&dbselect= l 1 19-23-0569-081A in the 2004 Tax Assessment Database 4/14/2010 9:43 AM Our File No.: 241533 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker Attorney I.D.# 38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800)672-0215 Attorney for Plaintiff PALISADES COLLECTION, LLC Plaintiff, vs. KIMBERLY SHARP Defendant. F1L~C--- - ~:.~ 2Qi0 ~U~ _v ~l-~ ! I A'!!2 ~~1~~?A U~V9v ., /5 i`i' COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 10-1196 CIVIL TERM PRAECIPE TO REINSTATE COMPLAINT -CIVIL ACTION TO THE PROTHONOTARY: Kindly reinstate the Complaint in the above captioned Civil Action for an additional thirty {30) days. APOTHAKER & Attorney A Law Firm En~as BY: Debt TES, P.C. David J. Apo~haker, Esquire Dated: 7/28/2010 ~10•bo Pa AT'TJ c* IRay-to 2# ay c.~y SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson ~~~#: ~ _ Sheriff y~,lr 0~ Jody S Smith ~ ~~ Chief Deputy ~^ ~~ L u l ~ i , v v ~ u .~ _ ~ ~: Richard W Stewart ~~ ~°~ ~O(d ~}V(r t ~o ,AM ~•~ Solicitor rice ~F =r•,E s~;~~"`,~ ~.~. ' 1 'M i Palisades Collection, LLC Case Number vs. 2010-1196 Kimberly Sharp SHERIFF'S RETURN OF SERVICE 08/12/2010 03:06 PM -Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on August 12, 2010 at 1506 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Kimberly Sharp, by making known unto Susie Abbon, Mother of defendant at 1278 Brandt Road, Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time handing to her personally the said true and correct copy of the same. RYAN BURGETT, DEP SHERIFF COST: $37.00 August 13, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF (c) CountySuite Sheriff. Teleosoft, b~c. .... 1 Our File No.: 241533 APOTHAKER & ASSOCIATES, P.C. By: David J. Apothaker , Attorney I.D.# 38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800)672-0215 ' Attorney for Plaintiff PALISADES COLLECTION, LLC FILED-OFFICE ~?f THE PROTHONOTARY 20 i 0 OCT f 5 AM !0~ 13 CUMBERLAND COUNTY PENNSYLVANIA COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff vs. KIMBERLY SHARP NO.: 10-1196 CIVIL TERM Defendant Civil Action PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment against Defendant, KIMBERLY SHARP, in the default of an Answer, in the amount of $2,936.27 computed as follows: Amount claimed in complaint: $ 2,833.40 Less: Amount Paid: ( 0.00} Plus: Interest from February 16, 2010 to October 4, 2010 at the legal interest rate of 6.00% per annum 102.87 Attorney fees 0.00 TOTAL ~ $ 2,936.27 I certify that Defendant, KIMBERLY SHARP, last address is 1278 BRANDY ROAD MECHANICSBURG, PA 17055. David J. Apot cer, Esq. Attorney for Plai tiff ~~~. G,~ ~ / n Dated: October 4, 2010 C~.. hF Ct~ aG~Jo~Yo ~~- ~~q7~ ~cr~t c~ m~. ~ ~ w Our File No.: 241533 APOTHAKER & ASSOCIATES, P.C. By: David J. Apothaker Attorney I.D.# 38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800)672-0215 Attorney for Plaintiff PALISADES COLLECTION, LLC Plaintiff vs. KIMBERLY SHARP Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 10-1196 CIVIL TERM Civil Action CERTIFICATION PURSUANT TO RULE 237.1 Pursuant to PA Rule Civil Procedure 237.1, I certify that a copy of the NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT has been sent to the Defendant or the Attorney of Record. I verify that the statements made in this Certification are true and correct. I understand that false statements herein are made subject to the penaltie f 18 Pa.C.S.A. §4904, relating to unsworn falsification to authorities. David J. Ap er, Esq. Attorney for Plaintiff Dated: October 4, 2010 ~_- - Our File No.: 241533 APOTHAKER & ASSOCIATES, P.C. By: David J. Apothaker Attorney I.D.# 38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800)672-0215 Attorney for Plaintiff PALISADES COLLECTION, LLC Plaintiff vs. KIMBERLY SHARP Defendant Civil Action AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 10-1196 CIVIL TERM SS. David J. Apothaker, being duly sworn according to law, deposes and says that I am the attorney for Plaintiff, and authorized to make this affidavit; that Defendant(s) resides at 1278 BRANDY ROAD MECHANICSBURG, PA 17055. We inquired with the web site of the Defense Wilson Boulevard, Suite 400, Arlington, VA 2220 branch of the military. Mary M. Snavely-Dixon, Director of the Defer our inquiry indicated that the Defendant(s) is/are not in David J. Apothaker, Esq. Attorney for Plaintiff r Data Center, located at 1600 the Defendant(s) is/are in any Center has sent back I verify that the statements made in this Certification are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904, relating to unsworn falsification to authorities. ~.. ~~ of Ddrnar lriaozrovva Data Genter flee-w-2SiIa o7 t93? Armaet m the Srnice Irlemben C.rvil ReidAct Kam b4sf!!ltiiile P1Kia Dsea Atxiva ~]' 5tsAs ANlva ~' Ead f~ta , sFIARP ', KI.~iBERI.Y Baled oa Aae iukxmtaiaa pat 1>ati2 {u[sished. the DA~C does oat possess aap aafcxvu>saa indicating the oci~+idoai stahn- lpea s the atEarmastion data banl's ofthe ~ of Defane yiaapovrer 1~ C'sattt, based on tht i>focmaitibn I~t : yea pre+.idcd the ebm"e is the a s~aa ~ dre iadnidwi as to ai tsra~es of the G~niFaro>Kd Services (Army, T+Savw, :Wfat»r C«ps; Air Force, 2~4AA, 23a6ic 13raldt, said Coast ~. rte, n. ,~.~s,-~. '-3+tacy 3~i Smat'ety-Accoo, D~cctcx naperttaard ut't~rfe+nse ~ .Lla~piru~ Data Ctsia IfiUO ~'Asoa $h~ck. Suits d4L1 AtGs{Iwo, 4'A :?249-2193 1"he Defatsr Masporva Dams Center {DEC) a as orgaaizaaoa cEtLe Depattiment aCDekose that toeitttsin tAe Lkfaese Eaaimera sod ~' Repastiog Syst® (DEERS} database w•LicLss the aAic7a1 sotare of data m rlig+beSty ~r missy taedieaf cue and atlkx Y s?'stems. ib,r non strae~y mpporu the esi'uCemcot err the service \;rm6ers Chit RrLrf Act (5o t,'SC App. §~ 301 er see{, as arne~ded} {SCRA) ltnrmnir tmawn as the Soislrer:' and 5as~oti Civt1 Relief Ars of 29~SO}. ntiIDC Las issnta ir~ds otthosnemds of 'does oat possess any iodr~ that the it-dhi3ld >g cztrrdly oo acdvx duty' resposeses, and has esgesieacsd a small error rate. Ia t}x want the oc!<si~al refertncr!d abosr, « airy ~j mmober, fsiend, err rrprz•se~ r mserb a Q+Y maotser that the atdviduad is eau active duty. a u olher~aise ratified to the ~ of the SCRA, yat are strotrgk encaraged m olrt>b [urtirr ~ificaec+a of tht ptrson s stann by t' Arat prrsaa s 5er~'ice t4a the "daferttalrsftmi' L`ItI. Igo 'wow ~S ,sq~ nisPCO~j ~~ lC you hsv'e evidrace the pasaa is on ecti+R duty and ym+#`si W uLtaias tl~s add8oaal Service verification, pooai+x Ptot'isans ofthz SCRA maq be aatkeQ ag~t yas~ Ser 50'[750 A{~t- 7~~21{r)- if you obtain addidooal ~ above the person (e 8 , an 55N, inprov+cd accuracy of DAI:I, a taidclle twae}, yvo can submit }9otr rer}scst agnst et dis 4`eb ste and m•r nil ~ovidc a tscv caCficatc tsx Aut 4MY. ILis respvase re9ects active dstyy statRS lag date the individual was kut os# aceirx duty. ~~ teas +s°it~R the pree~q 3t5? days. bar hbtnncal iforxaatio4 pfrase rates the Sanicr SCRA poi#s-of-eo~x. .t/a++t ir~o~aaaia+r sn ".ierire Div' SrRtus" Actisx Sty stereos ~ reposed 6 this ctt'~[stc is ddned io accamd~ce Rih 10 T3SC y 24I{d}(l) for a~iod dinner ~ 30 catnectAre days. Ia Are case of a >~ber of the tiatiaaal Guard, ocbdes serica tinder a caI to active srsviee eodsaiized by for Pr rsidmr er the Sanatory of Dedensc far a period of mare ttsan 30 conxecvtis~a drys tasda 32 tTSC $ SO:tf) fa prrpcrses ~ rsspoadAO~ m a tsveinrad r~rgcacy dcc6mred by dx 1?residrar and SrQporucd by Federal ands. AI Actnr Gmerd Rrsrnx (AGR} meaohca's mast be + aen mataotitrd mabilezaaao Position in !tie tar'! tLey stdport.. 11is ixisdes Navy TARS. ]dat~c Catps ARs asd Coast Goad I2PAs_ Activx Dtty staEte also apples m a Ga[amed Service member ui>,o ~ an aetisx dray caatsistsioaed a$scer of dre G.S, rabic T3estwh 5ervics a dre P~rmaotd Qceanic aad Atrrrosptteric Admiastrari«s {;vTQAA Camrriss(taed C4ps1 &x a geviad of awre @razt 3fl cansctvtn~c Cis Lrtnfs~ tJur SC$.A is Brtrat5ri ix Sow Carscr Covt:age mdrr ilrc SCRA is broader n sage rases sad iaclndrs same categories of pasam oa activx duty for ptaposes ddre -SC~CA u~ maid rxx be muted as on Attn~t D+t`i ux3er this ctrttliratr- ~ixp titmges otdirs are amcrded to ratmd rte pcxiud of active dot}, which wrrtdd rztmd SCRA gatecric~es- Prrsms srrloeg to ~ ere ffiis veF>site ee:d6caeon sha>id check m meta sate the a~ oo >tifiieh SC1tA prottetiem art based lave rwt 6esa aaseaded m rtttersd Are asdssis~e drtes of serviCt. FurthKtnare, soma protettiaas mdse SCRA may estmd bs pccsom vv~ hav9e received orders m sepat fca activx dray as m be iadoct<d, bin who havx not aetoalty begraa ectivvc day err actually ~ iiduction. The Last Ihar an Acttv~r Iluty enir'y is ;mportaet because a uttatbc of protections a!' SCRA eslrnd br?!aod the last data of aetNr dun'. Than also trrodd rdy nr< this eertificue are ur6ed to seek quati6ed sego! coatssd to mute dint al tights guaraatted m Senict meaobrrs ender the 5C'R A are {uote~ct~ed R'AR'rilZdCr: TLis cmii6eate av-as provided based as a trassc attd S5'd Provided br ehe regmcssta. t?ravidag an esoaeoas name ar 55<~I v+rY ratru as ertoaeous eatificau to be pmvtded. Report BT'..k~'VFL'l~'~ .~ . 241533 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS ~ ' CUMBERLAND COUNTY PALISADES COLLECTION, LLC )COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. ) KIMBERLY SHARP ) NO. 10-1196 CIVIL TERM To: KIMBERLY SHARP 1278 BRANDY ROAD MECHANICSBURG, PA 17055 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. 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 ASSOCIATION 34 S. BEDFORD ST. CARLISLE, PA 17013 717-249-3166 BAR DAVID J. AP THAKER, ESQUIRE APOTHAKER & ASSOCIATES, PC A Law Firm Engaged in Debt Collection 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800} 672-0215 Attorney for Plaintiff Attorney ID #38423 Date: September 07, 2010 ~. OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS TO: KIMBERLY SHARP 1278 BRANDY ROAD MECHANICSBURG, PA 17055 PALISADES COLLECTION, LLC Plaintiff vs. KIMBERLY SHARP Defendant NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. XX JUDGMENT BY DEFAULT COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 10-1196 CIVIL TERM Civil Action JUDGMENT IN REPLEVIN JUDGMENT BY CONFESSION JUDGMENT FOR POSSESSION JUDGMENT ON AWARD OF ARBITRATORS JUDGMENT ON VERDICT JUDGMENT ON COURT FINDINGS JUDGMENT ON WRIT OF REVIVAL IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: ATTORNEY David J. Apothaker, Esa. at this telephone number: 800-672-0215 ~o/ls/r