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Home My WebLink About10-676041 Our File No.: 262733 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apoth2ker, 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. JENNIFER L RIGHI 1129 HARRISBURG PIKE APT 2 CARLISLE, PA 17013 Defendant. FILED-OFFICE OF T?,!7 Pc), oTH0o OTARY if L, C"T 22 2: 24 Rlf-''DG0 1 T' is SYLVAN IP; COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: tD - (O7(Oa 0-iva-Ferm 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 5 4g01•o0 Po AT7%/ l Our File No.: 262733 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. JENNIFER L RIGHI 1129 HARRISBURG PIKE APT 2 CARLISLE, PA 17013 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 JENNIFER L RIGHI, an adult individual residing at 1129 HARRISBURG PIKE APT 2 CARLISLE, PA 17013. 3. Plaintiff, PORTFOLIO RECOVERY ASSOCIATES, LLC, is the Assignee and Successor in Interest of Account # ending in 5943; and said account was issued to Defendant(s) by WASHINGTON MUTUAL/PROVIDIAN NATIONAL BANK, 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 $1,889.43. 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 $1,889.43 and requests this Court award costs to the extent permitted by applicable law. ATE , P.C. SS CI APOTHAKER ro Attornr 7aintiff A Law Firm Ena d i Deb Collectioi BY: Dated: 10/13/2010 David J. Apothalr, Esquire Our File No.: 262733 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 unders"As that the statements therein are made subject to the penalties of 18 Pa.C.S.A. 4904 David J. ApothiVr, Esquire Attorney for Plaintiff to authorities. DATE: 10/13/2010 PORTFOLIO RECOVERY ASSOCIATES, LLC JENNIFER L RIGHI 1129 HARRISBURG PIKE APT 2 CARLISLE, PA 17013 STATEMENT OF ACCOUNT Debtor's Name: JENNIFER L RIGHI Account Number: ending in 5943 Original Creditor: WASHINGTON MUTUAL/PROVIDIAN NATIONAL BANK Balance Due: $1,889.43 Our File No.: 262733 EXHIBIT "A" SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor Portfolio Recovery Associates, LLC vs. Jennifer L. Righi Case Number 2010-6760 SHERIFF'S RETURN OF SERVICE 11/04/2010 06:56 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on November 4, 2010 at 1856 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Jennifer L. Righi, by making known unto herself personally, at 1129 Harrisburg Pike, Apartment 2, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to her personally the said true and correct copy of the same. RYAN BURGETT, D PUTY SHERIFF COST: $33.40 November 05, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF ?.n ?_ r? c) GountySuite ShentF. Teleosoft. Inc. Our File No.: 262733 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 1 :=I: ?O OTHO OTAR i' I AN All 11: 39 -JM { PE N ERLAND NSYLVAN A T COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff, vs. NO. 10-67 60-C I V ILTERM JENNIFER L RIGHI Defendant. PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & ASSOCIATES, P.C. Attorneys for ntiff A Law Firm Engaze in ebt Collection By: David J. Apo cer, Esquire Dated: 7/27/2011 111111111111111111111111111111111l