The URL can be used to link to this page

Home My WebLink About10-5382Our File No.: 275380 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 CROWN ASSET MANAGEMENT, LLC 3355 BRECK -41UDGE BLVD STE 132 DULUTH, GA 30096 Plaintiff, VS. JOSHUA A MORGAN 611 3RD ST FL 1 NEW CUMBERLAND, PA 17070 Defendant. np c, _ tclc COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: l C? - 538"x` L' i tin 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 s Q 2.00 W may, .Q.tk 2y to d, a'` Our File No.: 275380 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, F-squire Attorney I.D. #38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff CROWN ASSET MANAGEMENT, LLC 3355 BRECKINRIDGE BLVD STE 132 DULUTH, GA 30096 Plaintiff, VS. JOSHUA A MORGAN 611 3RD ST FL 1 NEW CUMBERLAND, PA 17070 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is CROWN ASSET MANAGEMENT, LLC, 3355 BRECKINRIDGE BLVD STE 132, DULUTH, GA 30096. 2. Defendant(s) is/are JOSHUA A MORGAN, an adult individual residing at 611 3RD ST FL 1 NEW CUMBERLAND, PA 17070. 3. Plaintiff, CROWN ASSET MANAGEMENT, LLC, is the Assignee and Successor in Interest of Account # ending in 3160; and said account was issued to Defendant(s) by FIRST NATIONAL BANK OF OMAHA, 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 $1,799.61. 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 $1,799.61 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & AS O IATES, P.C. Attorney fo P ' tiff A Law Firm Enjq= Debt Collection BY: David J. Apotha cer, Esquire Dated: 8/10/2010 Our File No.: 275380 Y VERMCATION sV S A r-i CW rLI q_- hereby sues that I am 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 tmdersig?oed understands that the statements !7!" are made subject to the penalties of 18 Pa.C.S..A. 4904 relating to unswom falsification to authorities. DATE: . CROWN ASSET MANAGEMENT, LLC JOSHUA A MORGAN 611 3RD ST FL 1 NEW CUMBERLAND, PA 17070 STATEMENT OF ACCOUNT Debtor's Name: JOSHUA A MORGAN Account Number: ending in 3160 Original Creditor: FIRST NATIONAL BANK OF OMAHA Balance Due: $1,799.61 Our File No.: 275380 EXHIBIT "A" .f 275380 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: CROWN ASSET MANAGEMENT, Expiration Date: LLC Type of Action: Civil Action Defendant/s: JOSHUA A MORGAN Serve Upon: JOSHUA A MORGAN Address for Service: 611 3RD ST FL 1 NEW CUMBERLAND, PA 17070 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 ?JFF ?.F''? '-•? c..C?]Gi ELFO-OFFICE C`7 H!: Jody S Smith Chief Deputy Richard W Stewart Solicitor ?'_3c"''t0 Pik 2:27 r? s hip ? ? .lt 'd?1 COUINT`.' 1 Crown Assset Management, LLC Case Number vs. Joshua A. Morgan 2010-5382 SHERIFF'S RETURN OF SERVICE 09/17/2010 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: Joshua A. Morgan, but was unable to locate him in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant Joshua A. Morgan. Current landlord of 611 3rd Street, Floor 1, New Cumberland, PA 17070 advised Deputies, Joshua A. Morgan has not resided at this location in over one year ago. SHERIFF COST: $48.30 September 17, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF (ci courfy&xte Shenfl 7eieoseft. Inc. _~; ~ ~, Our File No.: 275380 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire Attorney I.D.# 38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800)672-0215 Attorney for Plaintiff CROWN ASSET MANAGEMENT, LLC Plaintiff, vs. JOSHUA A MORGAN Defendant. ~'e~,~E3~~~;_~' ~wi~ 4,,~"~~~'W~"~~~ 1~y-s-~~°a`$~`~rE ti~~ COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 10-5382 CIVIL PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & AS IATES, P.C. Attorneys f r P 'ntiff A Law Firm En~a~ d i ebt C¢llectioY By: Dated: 10/26/2010 David J. Apotha~cer, Esquire ~mm~i~mn