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Home My WebLink About10-5320 Our File No.: 282877 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 FORTIS CAPITAL LLC 2831 ST ROSE PARKWAY STE 217 HENDERSON, NV 89052-4806 VS. Plaintiff, 2010f, Ii ;Z010 AOG 13 ??`^ 1=53 COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. i o - 536 C? v?? RICARDO E HARRIS 1804 LETCHWORTH DR CAMP HILL, PA 17011-5933 Defendant. 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 34 S. BEDFORD ST. CARLISLE PA 17013 717-249-3166 ?#: 19 L141t ' 94 24 6 75-7 Our File No.: 282877 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 FORTIS CAPITAL LLC 2831 ST ROSE PARKWAY STE 217 HENDERSON, NV 89052-4806 Plaintiff, VS. RICARDO E HARRIS 1804 LETCHWORTH DR CAMP HILL, PA 17011-5933 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. n-55X0 G\A-? CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is FORTIS CAPITAL LLC, 2831 ST ROSE PARKWAY STE 217, HENDERSON, NV 89052-4806. 2. Defendant(s) is/are RICARDO E HARRIS, an adult individual residing at 1804 LETCHWORTH DR CAMP HILL, PA 17011-5933. 3. Plaintiff, FORTIS CAPITAL LLC, is the Assignee and Successor in Interest of Account # ending in 6142; and said account was issued to Defendant(s) by WASHINGTON MUTUAL 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 $2,988.81. 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 $2,988.81 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & AS TES, P.C. Attorney fo PI rff A Law Firm Engage in t Co ctioi BY: V- David J. Apothaker, Esquire Dated: 8/10/2010 Our File No.: 282877 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 relating to urAworn falsification to authorities. David J Attorney for , Esquire DATE: 8/10/2010 FORTIS CAPITAL LLC RICARDO E HARRIS 1804 LETCHWORTH DR CAMP HILL, PA 17011-5933 STATEMENT OF ACCOUNT Debtor's Name: RICARDO E HARRIS Account Number: ending in 6142 Original Creditor: WASHINGTON MUTUAL BANK Balance Due: $2,988.81 Our File No.: 282877 EXHIBIT "A" 282877 Request for Service R. Thomas Kline Sheriff Cumberland County Office of the Sheriff One Courthouse Square Carlisle, PA 17013 Ph: 717.240.6390 Fx: 717-240-6397 Plaintiffs: Court Number: FORTIS CAPITAL LLC Expiration Date: F ype of Action: ivil Action Defendant/s: RICARDO E HARRIS Serve Upon: RICARDO E HARRIS Address for Service: 1804 LETCHWORTH DR CAMP HILL, PA 17011-5933 Alternate Address for Service: Type of Service: ( ) Personal (X) Adult in Charge (} Deputize () Certified Mail () Posting Special Service Instructions: * * If service is to be made by deputized service to another county please specify which county Filing Attorney Information: Name: Apothaker & Associates, P.C. Address: 520 Fellowship Road C306 Mount Laurel, NJ 08054 Telephone: 215-634-8920 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson ~~(}-{)} Sheriff r ~~~ ~ !fin ` ;.~~~1~~~ Jody S Smith ~gu~~,s+ of 4~ot~ber~~fi4 Chief Deputy ~~ ~- ~ i ~ :~ `~ (} ~~~ 3 ~ ~~ Richard W Stewart ~~ Solicitor cFFtce+ -, ~ s~+FRtFF '(,~I1~Q~,rr.t~:`~tJ ~~ ~cv~nv~ Fortis Capital LLC vs. Case Number Ricardo E. Harris 2010-5320 SHERIFF'S RETURN OF SERVICE 08/20/2010 07:22 PM -Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on August 20, 2010 at 1922 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Ricardo E. Harris, by making known unto himself personally, at 1804 Letchworth Drive, Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to him personally the said true and correct copy of the same. NOAH CLINE, DEPUTY SHERIFF COST: $41.50 August 26, 2010 SO ANSWERS, ... t~~^^.r~" RON R ANDERSON, SHERIFF ;oj CountySuite Sheoff. Teleosoft. Inc. . Our File No.: 282877 ' 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 FORTIS CAPITAL LLC VS. Plaintiff RICARDO E HARRIS Defendant Civil Action PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment against Defendant, RICARDO E HARRIS, in the default of an Answer, in the amount of $2,988.81 computed as follows: Amount claimed in complaint: Less: Amount Paid: Plus: Interest from August 10, 2010 to November 5, 2010 at the legal interest rate of 0.00% per annum Attorney fees TOTAL I certify that Defendant, RICARDO E HARRIS, la: LETCHWORTH DR CAMP HILL, PA 17011-5933. Dated: November 5, 2010 -4111 Gd 1?r?1 ) 04 y. a N4,4/ . ?, caw T 'H !-- ' ?lP\IE r 4 rya! r--_, - COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 10-5320 CIVIL $ 2,988.81 ( 0.00) 0.00 0.00 $ 2,988.81 is 1804 David J. Apoth Esq. Attorney for Plaintiff OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS TO: RICARDO E HARRIS 1804 LETCHWORTH DR CAMP HILL, PA 17011-5933 FORTIS CAPITAL LLC vs. Plaintiff RICARDO E HARRIS Defendant NOTICE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 10-5320 CIVIL Civil Action 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 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, Esq. at this telephone number: 800-672-0215 Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 10-5320 CIVIL 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 Our File No.: 282877 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 FORTIS CAPITAL LLC VS. Plaintiff RICARDO E HARRIS 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 penalties of 18 Pa.C.S.A. §4904, relating to unsworn falsification to authorities. David J. A er, Esq. Attorney for Plaintiff Dated: November 5, 2010 Our File No.: 282877 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 FORTIS CAPITAL LLC vs. Plaintiff RICARDO E HARRIS Defendant Civil Action AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 10-5320 CIVIL : 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 1804 LETCHWORTH DR CAMP HILL, PA 17011-5933. 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 De our inquiry indicated that the Defendant(s) is/are not David J. Attorney lower Data Center, located at 1600 , if the Defendant(s) is/are in any Center has sent back ker, Esq. 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. Dq-b-d afl))d- -Mwp*wer Data Center Nov-0-V10 0$A536 Mrd-y Sb" Rq- Prrsusat to the Service Members Casa Reie£Act A ed" bot S 1§sti" HAPMS RICARDO nosed oa dse ieh cwm%on yon bwe finished, the MIX don oot E iadicariag the irfi+'idasl Oahu Pas ens nay iaiarnrion teas naming the iifaaottsiop dw boors of the Dgmu wm of Ddewe Manpower Data Center, twined or dke i*cMation *A Ypn p?;ded the aba,ne is ibe aar!®t stuns oldie iadhidusi as ? al braewthes dtbe 1?ae7armed Services CAtsl'. 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In dw av w die isdinidaai rv%mced abovY, a any fawlf weber, ikwod, or reptesaa<slice allots R nosy tmaasrs that due fadAdad is on Sc6ft dtty, cc is Nhemiise avoided b the psotecdOw ofthc SCRA, 7wn ale Won* mrodroged to obtain hone vex&M- of doe priori s stn w by cmftco al tae pav* s Service va die "d&=d@ Mr LML hsvww. ,? nr•twet 1rQ .: Ilytas have evidoea the prawn is on acdve duty and you hi to obtain din addriamat Service v,r>ricsma, pm'Ikue prot?aas u>t'the SCRA>niap be ievvked avant yraa See 30 };SC' App.. §32}(c). if I'm obtain addi6otsal afarmatian ttbact the pasoa (e.l, as SSN, iapra?xd a?castacy dDpH, n sfidele aarsue), yon cats sabmrt your request ago at d is Web site and we x$ prwide a ww rntiBcatr fir thd 9cry- "a F lastorr -bv* ? ststbs itrci x* date die =lwK oai was tau 00 achve dAy. is was wither the preceding 367 aufOrmadioo, please contact she Service SCRA pairs-of-ccw c M- inp4n tadox ens ^ cow Do*- Smuer" Acthr duty %wk s - reycried in ibis cuW= to is defoed in acemloner with 10 U SC § 101(d)(1) for a period of tone dsao 30 --Wive days- Is die carne of a member of site l m imd Gumit iarS servite move a Cal to active yowler aiarized by the President os the Searetars ofDd wse kar a paiad atmme ihast 30 cosaecuhv days wader 32 GSC § 5020 for papaws of re4xwSag to a 4 earrgeacy decoyed by dse W-drat and su"xmd by FedmA UK% Al Acive Guard Reserv, (AGR) :amebas mmt be assigned amt an emhoriF mob&umoe position m the uoi dry WpMt. Tbis ioA des Navy TARS, :vv4,= Caps AP % mad Coast Guard RPAs. Active Duty stator ako apes to a t eformed Service member who n m active vier, rpaimi?sixK.d attar of die U.S- PuW He4t Service of the Natiomat C?scarsic and Aanospberw Awdmieistratim (,%'t3AA C-unissimed GNPs) for a period cFuxte drm 30 ccrosecudre devs Co.'mw tinder toe SCii'.4 is Broader in Soame Csscs Cmaa6e order Ale SCRA a broader is same rases sod ioclsdes some categorks of persons on active duty forpwposes 0(dw SCRA,who wnafd not be rq-ted a an Active Duty alder this eert6catt, Ninny times orders we amended to eseosd the period of active duty, which w=M exhm d SCRA proWai ns- Persons seeking to r* on din websie cndkadon shoed deck to mane sore die orders on which SCRA prat niow at based have not been amarlsd to dead diaindwve doges of saraice. Futhaasore, some protecfim of doe SCRA may eumd to persons wino h v meic+ee! Orders to repast for aaim Asy or to be inducted, but who have sat scw* begsiri active dap or _W* vgwded&r The Last Date on Adh* Duty eaky is important beemse a number a(prutecbow of SCRA mead b*-md &e bw ehites of awe dory Tbose who wadd r* on this ecr irate at aged to seeds qnigkd legit coumd w enwre. &w d rigks gaarseteed to Service members wAer the SCRA are prow-led R ARIv'L4 : 3}u caiTpeate was provided based cc a saw mod SST provided by ffie mqo,* r- proves as ra+otrea nmc of SW wd came as enumms cese6itme to be provided Report ID-S% T1+tI1s W9 282877 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY FORTIS CAPITAL LL'C ) vs. ) RICARDO E HARRIS ) To: RICARDO E HARRIS 1804 LETCHWORTH DR CAMP HILL, PA 17011-5933 COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 10-5320 CIVIL 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 TH KER, 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: October 08, 2010