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HomeMy WebLinkAbout10-5616Our File No.: 270511 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apbthaker; Esquire Attorney I.D. #38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff BARCLAYS BANK DELAWARE 125 S WEST STREET WILMINGTON, DE 19801 Plaintiff, VS. KIRSTIN SWEIGARD 1031 W TRINDLE RD MECHANICSBURG, PA 17055-4515 Defendant. O P ? 1:25 ?mpjly?YIVANiA COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 10 - Nol47 0,-W i (Ter AK 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 05 ?qa.A a?l? 0' ay7y&R Our File No.: 270511 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 BARCLAYS BANK DELAWARE 125 S WEST STREET WILMINGTON, DE 19801 Plaintiff, VS. KIRSTIN SWEIGARD 1031 W TRINDLE RD MECHANICSBURG, PA 17055-4515 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is BARCLAYS BANK DELAWARE, 125 S WEST STREET, WILMINGTON, DE 19801 2. Defendant(s) is/are KIRSTIN SWEIGARD, an adult individual residing at 1031 W TRINDLE RD MECHANICSBURG, PA 17055-4515. 3. At the special instance and request of Defendant, Plaintiff, BARCLAYS BANK DELAWARE, issued to Defendant(s), Account # ending in 3545. 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 $5,924.96. 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 $5,924.96 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & ASSOCIATES, P.C. Attorney f amtiff A Law Firm Enaa ed ' Debt Collection BY: David J. A?L&k cer, Esquire Dated: 8/13/2010 Our File No.: 270511 VERIFICATION David J Apothaker Esquire, Esq. 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.q?S.A. 4904 relating to unsworn falsification to authorities. David J. Apuffiaker, Esquire Attorney for Plaintiff DATE: 8/13/2010 BARCLAYS BANK DELAWARE KIRSTIN SWEIGARD 1031 W TRINDLE RD MECHANICSBURG, PA 17055-4515 STATEMENT OF ACCOUNT Debtor's Name: KIRSTIN SWEIGARD Account Number: ending in 3545 Balance Due: $5,924.96 Our File No.: 270511 EXHIBIT "A" ~ ~ Our File No.: 270511 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 BARCLAYS BANK DELAWARE Plaintiff, vs. KIRSTIN SWEIGARD Defendant. 2~ i 5~:~' ? I :~ f~: 3 ~9 COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 10-5616 CIVIL TERM PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & A O IATES, P.C. Attorneys or P intiff A Law Firm Enaa ed i Debt Collection BY= ~/ David J. Apothaker, Esquire Dated: 9/10/2010 IInIII~IIINIII~I~IV~~~I~l SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor a?t??c+' of 4?uriGrtl,14 FILED-OM ME rARY ,c Tt r $ FM 1: 02 OXNTY pE,NNSYL'M A Barclays Bank Delaware vs. Kirstin M. Sweigard SHERIFF'S RETURN OF SERVICE Case Number 2010-5616 09/02/2010 03:04 PM - Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on September 2, 2010 at 1504 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Kristin M. Sweigard, by making known unto Dave Sweigard, Husband of defendant at 1031 W. Trindle Road, Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $37.00 September 03, 2010 GERALD WORTHINGTON EPUTY SO ANSWERS, RON R ANDERSON, SHERIFF !C CouofySuite She'..ff. Telecac?t Inc,