HomeMy WebLinkAbout10-6383SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson ~~ ~~~~-~ ~ ~~~ TAR`S'
Sheriff
Jod S Smith ~4a~,tr ~~ ~~~~rr1~7~
y 7pl0 OCT 14 AM !0~ 0
Chief Deputy ~
~' ~ ~ `~` ~UMBERLAhD COUNT'
Richard W Stewart ~ P~.t~,N
Solicitor c~FFtce c1F SHE s~E~tFF S Yl.~~ N (,?~
Advantage Assets II, Inc.
vs.
Sarah E. Nevarro
Case Number
2010-6383
SHERIFF'S RETURN OF SERVICE
10/11/2010 09:11 PM -Shawn Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on October
11, 2010 at 2111 hours, he served a true copy of the within Complaint and Notice, upon the within named
defendant, to wit: Sarah E. Nevarro, by making known unto Norm Nevarro, Husband of defendant at 645
W. First Street, Boiling Springs, Cumberland County, Pennsylvania 17007 its contents and at the same
time handing to him personally the said true and correct copy of the same.
A SHALL, DEPUTY
SHERIFF COST: $33.40
October 12, 2010
SO ANSWERS,
~~s.
RON R ANDERSON, SHERIFF
(cl CountySuilo Shenft. Teleosoft. Inc.
~ ~ -.
Our file No.: 282723 .
APOTHAKER & ASSOCIATES, P.C.
520 Fellowship Road C306
Mount Laurel, NJ 08054
(800)672-0215
Attorneys for Plaintiff
Attorney ID# 307949
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EA s ~`'
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CUMBER~AP~fl CaU~~t"z'
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COURT OF COMMON PLEAS
ADVANTAGE ASSETS II, INC. ) CUMBERLAND COUNTY
Plaintiff, ) DOCKE'T' NO.: 10-6383
vs. )
} Civil Action
SARAH E NAVARRO ~ )
STIPULATION IN 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 October 14, 2010, STIPULATED by and between Plaintiff,
ADVANTAGE ASSETS II, INC., and Defendant, SARAH E NAVARRO parties as
follows:
1. Defendant agrees to pay the sum of $1,898.60, 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 $1,898.60 shall be paid by the by Defendant,
SARAH E NAVARRO, to the attorneys for Plaintiff in the following manner:
a. $284.79 to be paid on or before October 15, 2010;
b. $284.79 to be paid on or before October 29, 2010
c. $200.00 to be paid bi-weekly each month, beginning November 12,
2010 until paid in full.
All checks are to made payable to ADVANTAGE ASSETS II, INC., and
sent to:
Apothaker & Associates, P.C.
520 Fellowship Road C306
Mount Laurel, NJ 08054
' Our file No.: 282723
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 parte, in the sum of $1,898.60, 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 parte application, with supporting certification, and with
notice to Defendant only in the form of a copy of the application addressed to SARAH E
NAVARRO by first-class, postage prepaid.
We hereby consent to the form and entry of the within Stipulation.
APOTHAKER & ASSOCIATES, P.C.
Attorneys for P tiff
A Law Fin~a~ed ' ebt Collection
By:
Esquire
SARAH E NAVARRO
a~~ ~a~,
Our File No.: 282723
APOTHAKER & ASSOCIATES, P.C.
By: Benjamin J. Cavallaro, Esquire
Attorney I.D.# 307949
520 Fellowship Road C306
Mount Laurel, NJ 08054
(800)672-0215
Attorneys for Plaintiff
ADVANTAGE ASSETS II, INC
Plaintiff
vs.
SARAH E NAVARRO
Defendant
7~~~ ~
lUII
COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY
}
NO.: 10-6383
} Civil Action
}
ACCEPTANCE OF SERVICE
I accept service of the Complaint in the above referenced matter.
__,
Date:
S E NAVARRO, Defendant
Address:
645 W 1ST ST
BOILING SPRINGS, PA 17007-9554
Our File No.: 282723
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
ADVANTAGE ASSETS II, INC
Plaintiff,
vs.
SARAH E NAVARRO
- i - ia-L?.1-s3?(
vc t€ ER
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO. 10-6383 CIVIL TERM
Defendant.
PRAECIPE TO DISMISS WITHOUT PREJUDICE
TO THE PROTHONOTARY:
Kindly dismiss this action without prejudice.
APOTHAKER & ASSOCIATES, P.C.
Attorneys faintiff
A Law Firm Enaaee i Debt Collection
By: l'?L
David J. Apothaker, Esquire
Dated: 2/23/2011
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