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Home My WebLink About10-6758r, Our File No.: 283198 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. NICOLE LYNN DURAND 6 RAILROAD AVE CAMP HILL, PA 17011 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY = Ft E?-St= FICA Ia+ t :°; F L 0TARY : , T x 22 P M, 2:24 COUNTY 1irtiSYLVANIA NO.: !D - 61,58 Civil l+xcv- NOTTCR 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 QS a.oo Pa Arr/ e? IRtn3 Our File No.: 283198 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. NICOLE LYNN DURAND 6 RAILROAD AVE CAMP HILL, PA 17011 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 NICOLE LYNN DURAND, an adult individual residing at 6 RAILROAD AVE CAMP HILL, PA 17011. 3. Plaintiff, PORTFOLIO RECOVERY ASSOCIATES, LLC, is the Assignee and Successor in Interest of Account # ending in 611 A; and said account was issued to Defendant(s) by CITI FINANCIAL, INC./ASHLEY FURN HOMESTORE, 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 $1,645.83. 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 $1,645.83 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER,& MSOCIATES,4?'.C. A Law Firm En ag d in De Collection BY: David J. Apothaker, Esquire Dated: 10/13/2010 Our File No.: 283198 VERIFICATION David J. Anothaker, 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. ThVnec ds that the statements therein are made subject to the penalties of 18 Pa.C.S.A. 4904 relat' n to authorities. David J. ApoAttorneyDATE: 10/13/2010 'PORTFOLIO RECOVERY ASSOCIATES, LLC NICOLE LYNN DURAND 6 RAILROAD AVE CAMP HILL, PA 17011 STATEMENT OF ACCOUNT Debtor's Name: NICOLE LYNN DURAND Account Number: ending in 611 A Original Creditor: CITI FINANCIAL, INCJASHLEY FURN HOMESTORE Balance Due: $1,645.83 Our File No.: 283198 EXHIBIT "A" SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor nFF:?E ',c ???"t 5 E?tFr Portfolio Recovery Associates, LLC VS. Nicole Lynn Durand Case Number 2010-6758 SHERIFF'S RETURN OF SERVICE 11/03/2010 10:40 AM - Gerald Worthington, Deputy Sheriff, who being duly swom according to law, states that on November 3, 2010 at 1040 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Nicole Lynn Durand, by making known unto herself personally, at 6 Railroad Avenue, Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $41.50 November 05, 2010 GERALD WORTHINGT , DEPUTY SO ANSWERS, RON R ANDERSON, SHERIFF ;Y C? (c) CounfySuite Sheriff, Ieleosoft Inc Our file No.: 283198 - 1? APOTHAKER & ASSOCIATES, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff Attorney ID# 307949 PORTFOLIO RECOVERY ASSOCIATES, LLC Plaintiff, vs. NICOLE LYNN DURAND Defendant. DEC 2 0 2010 r FILED-OFFICE ;1E PROTHONOTARY DEC 27 PM 2: 56 BERLAND COUNTY ENNSYLVANIA COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO.: 10-6758-CIVILTERM Civil Action STIPULATION IN LIEU OF JUDGMENT } The matters and things in controversy having been discussed by and between the parties, and a settlement having been agreed upon: It is on November 30, 2010, STIPULATED by and between Plaintiff, PORTFOLIO RECOVERY ASSOCIATES, LLC, and :Defendant, NICOLE LYNN DURAND parties as follows: 1. Defendant agrees to pay the sum of $1,779.33, 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 $1,779.33 shall be paid by the by Defendant, NICOLF, LYNN DURAND, to the attorneys for Plaintiff in the following manner: a. $1,000.00 to be paid on or before December 1, 2010; b. $50.00 to be paid bi-weekly each month, beginning December 10, 2010 until paid in full. All checks are to made payable to PORTFOLIO RECOVERY ASSOCIATES, LLC, and sent to: Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 Our file No.: 283198 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 $1,779.33, 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 NICOLE LYNN DURAND by first-class, postage prepaid. We hereby consent to the form and entry of the within Stipulation. APOTHAKER & ASSOCIATES, P.C. Attorneys for A ' tiff A Law Firm Engaged it ebt Collection By: , Esquire /_? k-k 61 V L VV A ??'l A COL L D )VVl/A A c7 0 Our File No.: 283198 -off s APOT AKER & ASSOCIATES, P.C. - BY: Be njamin J. Cavallaro, Esquire r, 0m Attorne y I.D.# 307949 25' -t cn ° c} 520 Fel wship Road C306 =-n Mount L aurel, NJ 08054 ?_ ocl) (800) 67 2-0215 c: N M b Attorney for Plaintiff ss PORTF?LIO RECOVERY ASSOCIATES, LLC COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff, NICOLE LYNN DURAND NO. 10-6758-CIVILTERM Defendant PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: dismiss this action without prejudice. APOTHAKER & ASSOCIATES, P.C. Attorneys for Plaintiff A Law Firm Engaged in Debt Collection By: Be jamin J. avallaro, Esquire Dated: /29/2011 11 11j111111 11111111111