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HomeMy WebLinkAbout10-7236Our File No.: 290380 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 ADVANTAGE ASSETS II, INC. 7322 SOUTHWEST FREEWAY, SUITE 1600 HOUSTON, TX 77074 Plaintiff, vs. COLLEEN M HERWEG 203 RENO AVE NEW CUMBERLAND, PA 17070 Defendant. ~~ Th'~i. D-T~NONOi'ARY 20-0 t~OY 17 PM 2~ 0 i CUMBERLAhlD C0t1MTY PENNSYLVAhlIA COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: ~ O -`1 o1.3~p 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 © ~°a'~`~ k ~g5gq0 a ~w~. ~~ r~s ~ ~a Our File No.: 290380 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 ADVANTAGE ASSETS II, INC. 7322 SOUTHWEST FREEWAY, SUITE 1600 HOUSTON, TX 77074 Plaintiff, vs. COLLEEN M HERWEG 203 RENO AVE NEW CUMBERLAND, PA 17070 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is ADVANTAGE ASSETS II, INC., 7322 SOUTHWEST FREEWAY, SUITE 1600, HOUSTON, TX 77074. 2. Defendant(s) is/are COLLEEN M HERWEG, an adult individual residing at 203 RENO AVE NEW CUMBERLAND, PA 17070. 3. Plaintiff, ADVANTAGE ASSETS II, INC., is the Assignee and Successor in Interest of Account # ending in 6060; and said account was issued to Defendant(s) by CITIBANK/THE HOME DEPOT, 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 $2,225.98. 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 aze 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 $2,225.98 and requests this Court awazd costs to the extent permitted by applicable law. & ASSOCIATES, P.C. A Law F' ngag in Debt Collection BY: David J. Apothaker, Esquire Dated: 11 /4/2010 Our File No.: 290380 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. made subject to the penalties of 18 Pa.C.S.A. 4904 falsification to authorities. ' lu ~ • t~nr~cer, t;squire Attorney for Plaintiff The undersigned understands that the statements therein are ., DATE: 11/4/2010 ADVANTAGE ASSETS II, INC. COLLEEN M HERWEG 203 RENO AVE NEW CUMBERLAND, PA 17070 STATEMENT OF ACCOUNT Debtor's Name: COLLEEN M HERWEG Account Number: ending in 6060 Original Creditor: CITIBANKJTHE HOME DEPOT Balance Due: $2,225.98 Our File No.: 290380 EXHIBIT "A" SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson r Y Sheriff t?tt, of ?It1t9?pr( , -D:x C= 1j Jody S Smith a ? ?h ' ? .1 !M M rn--n Chief Deputy c-) -0r; Richard W Stewart " Solicitor Ffu,E ?F' E SrERiFF ? 1 =-n C) 3 c? M Advantage Assets II, Inc. Case Number vs. 2010-7236 Colleen M. Herweg SHERIFF'S RETURN OF SERVICE 11/29/2010 05:02 PM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on November 29, 2010 at 1702 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Colleen M. Herweg, by making known unto herself personally, at 203 Reno Avenue, New Cumberland, Cumberland County, Pennsylvania 17070 its contents and at the same time handing to her personally the said true and correct copy of the same. NOAH CLINE, DEPUTY SHERIFF COST: $43.30 November 30, 2010 SO ANSWERS, RbNI'V ~ R ANDERSON, SHERIFF (C) CountySti to Sherd, Teleosoft. Inc. Our File No.: 290380 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 Il, INC. Plaintiff, vs. COLLEEN M HERWEG Defendant. MUD 'TF _ _ 1 r - Ln r x C-- CM CD a C7. x'C N COURT OF COMMON PLEAS CUMBERLAND COUNTY ` NO. 10-7236 PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & OCIATES, P.C. Attorne for laintiff A Law Firm En aged t Debt Collection By: David J. Apol cer, Esquire Dated: 3!7/2012 1