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HomeMy WebLinkAbout10-6753Our File No.: 266447 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apotliaker, Esquire Attorney I.D. #38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff PORTFOLIO RECOVERY ASSOCIATES, LLC 140 CORPORATE BOULEVARD NORFOLK, VA 23502 Plaintiff, VS. MARGARET L HANDSHEW 32 E MAIN ST NEWVILLE, PA 17241 Defendant. ";LEO-OFFICE Or `44. PRO i HO OTAR 7'1 lfl nnT ') t, k, L? ! e ? ', 2: 0 3 COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 10 - &I Z ?Vit lend 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 O 0-1 J9q/ 2# as0 //o Our File No.: 266447 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 PORTFOLIO RECOVERY ASSOCIATES, LLC 140 CORPORATE BOULEVARD NORFOLK, VA 23502 Plaintiff, VS. MARGARET L HANDSHEW 32 E MAIN ST NEWVILLE, PA 17241 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is PORTFOLIO RECOVERY ASSOCIATES, LLC, 140 CORPORATE BOULEVARD, NORFOLK, VA 23502. 2. Defendant(s) is/are MARGARET L HANDSHEW, an adult individual residing at 32 E MAIN ST NEWVILLE, PA 17241. 3. Plaintiff, PORTFOLIO RECOVERY ASSOCIATES, LLC, is the Assignee and Successor in Interest of Account # ending in 7004; and said account was issued to Defendant(s) by COMPUCREDIT, 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 $1,398.01. A true and correct copy of the total due and owing is attached hereto, made a part hereof and marked as Exhibit "A". i a. 6. All credits, if any, to which Defendant(s) is entitled, have been applied to the account and are included in Exhibit 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 $1,398.01 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & CIATES C. Attorney for r'laintiff A Law Firm Ent Zed Debt ollectio? BY: David J. A taker, Esquire Dated: 10/13/2010 Our File No.: 266447 I M 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 t9-IQworn falsificatign to authorities. David J. loty#&, Esquire fof Plaintiff DATE: 10/13/2010 i ?. PORTFOLIO RECOVERY ASSOCIATES, LLC MARGARET L HANDSHEW 32 E MAIN ST NEWVILLE, PA 17241 STATEMENT OF ACCOUNT Debtor's Name: MARGARET L HANDSHEW Account Number: ending in 7004 Original Creditor: COMPUCREDIT Balance Due: $1,398.01 Our File No.: 266447 EXHIBIT "A" SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ` Jody S Smith Chief Deputy Richard W Stewart Solicitor 77 Portfolio Recovery Associates, LLC Case Nder vs. 2010=6753 Margaret L. Handshew SHERIFF'S RETURN OF SERVICE 11/08/2010 '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: Margaret L. Handshew, but was unable to locate her in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant Margaret L. Handshew. Request for service at 32 E. Main Street, Newville, PA 17241 is vacant. However, The Newville Postmaster has confirmed they are still delivering Margaret L. Handshew's mail to 32 E. Main Street, Newville, PA 17241. SHERIFF COST: $43.80 November 08, 2010 SO ANSWERS, RONNY R ANDERSON, SHERIFF fc, Ccur 5u ^Pi fi t .. ft ErC. FILED-OFFICE r,F THE PR0T'H0NOT,f1 R`(' A- Our File No.: 266447 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 PORTFOLIO RECOVERY ASSOCIATES, LLC Plaintiff, VS. MARGARET L HANDSHEW Defendant. 01, 11 JAN -4 AM 10: 1 COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 10-675 3-CIV ILTERM PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & ASSOCIATES, P.C. Attorneys for Plaintiff A Law Firm Engaged i bt Collection By: David J. Apothaker, Esquire Dated: 12/20/2010 11111111111111