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HomeMy WebLinkAbout10-7768Our File No.: 29823.4 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 BARCLAYS BANK DELAWARE 125 S WEST STREET WILMINGTON, DE 19801 Plaintiff, vs. LAURA K BOLIN A/K/A LAURA RELLINGER 1 RICHLAND LN APT 101 CAMP HILL, PA 17011 Defendant. i if..~C?-E~F~'IC r~ ~~?~ Pf?~T~OP~u i~r,,,° I 0 DEC i 7 PM 2: t~ C~MBER(.A~~D C~El~ i ~' FEN~DSYLVA~tI COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: I~" ~7~~ ~l UI 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 ~L~ ~ 9°~'~ A~1 P~~~r ~ r~ /~s~y ~ ~~ Asa s~~ Our File No.: 29823,4 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 BARCLAYS BANK DELAWARE 125 S WEST STREET WILMINGTON, DE 19801 Plaintiff, vs. LAURA K BOLIN A/K/A LAURA RELLINGER 1 RICHLAND LN APT 101 CAMP HILL, PA 17011 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. ~ I ~ ~~~ ~ C ~-~~ CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is BARCLAYS BANK DELAWARE, 125 S WEST STREET, WILMINGTON, DE 19801. 2. Defendant(s) is/are LAURA K BOLIN A/K/A LAURA RELLINGER, an adult individual residing at 1 RICHLAND LN APT 101 CAMP HILL, PA 17011. 3. At the special instance and request of Defendant, Plaintiff, BARCLAYS BANK DELAWARE, issued to Defendant(s), Account # ending in 9099. 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 $2,114.97. 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. Althpugh 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 $2,114.97 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER ASS CIATES, P.C. Attorn y for laintiff A Law Firm E aae in Debt C~tio~ BY: David J. Apothaker, Esquire Dated: 12/8/2010 Our File No.: 298234 i VERIFICATION David J. Apothaker, Esquire, Esq, 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, therein are made subject to the penalties of 18 Pa.C.S The undersigned understands that the statements relating to unsworn falsification to authorities. David J. Apoth~er, Esquire Attorney for Plaintiff DATE: 12/8/2010 BARCLAYS BANK DELAWARE LAURA K BOL1N A/K/A LAURA RELLINGER 1 RICHLAND LN APT 101 CAMP HILL, PA 17011 STATEMENT OF ACCOUNT Debtor's Name: LAURA K BOLIN A/K/A LAURA RELLINGER Account Number: ending in 9099 Balance Due: $2,114.97 Our File No.: 298234 EXHIBIT "A" SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff FILLS GI F i, tr [H Prl Hti,;`,E??. Jody S Smith Chief Deputy Richard W Stewart Solicitor Barclays Bank Delaware vs. Laura K. Bolin 21110 DEC 28 PH 3: '4 0MBERLAND CGUP -,11',- PENNS` LVA€ IA Case Number 2010-7768 SHERIFF'S RETURN OF SERVICE 12/21/2010 06:50 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on December 21, 2010 at 1850 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Laura K. Bolin a/k/a Laura Rellinger, by making known unto herself personally, at 1A Richland Lane, Apartment 101, 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 December 22, 2010 r RYAN BURGETT, UTY SO ANSWERS, RON R ANDERSON, SHERIFF !c) Coup vS_Ide S:r=xiN. 1 el('osofit_ 1 " • t Yoffe & Yoffe, P.C. Jeffrey N. Yoffe, Esq. 214 Senate Avenue, Suite 404 Camp Hill, PA 17011 jyoffe@verizon.net Ph: (717)975-1838 Fax: (717)975-1912 BARCLAYS BANK DELAWARE Plaintiff VS. LAURA K. BOLIN A/K/A LAURA RELLINGER Defendant 'Cfr' PFNNsy' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 10-7768 CIVIL CIVIL ACTION ANSWER OF LAURA K. BOLIN TO COMPLAINT 1. Admitted. 2. Admitted. 3. Admitted. 4. Admitted. 5. It is Denied that $2,114.97 is owed on the account. The amount which Defendant owes to Plaintiff is significantly less than $2,114.97. Proof of what Defendant allegedly owes to Plaintiff is demanded. Plaintiff improperly gave Defendant credit for several payments too late. The late crediting of payments resulted in Defendant improperly being charged excessive interest rates and penalties. 6. Denied. Plaintiffs Exhibit "A" is an inaccurate representation of the status of the account. Defendant's response to paragraph 5 is incorporated herein by reference. 7. Admitted. WHEREFORE, Defendant requests that Plaintiffs complaint be dismissed. YOFFE & YOFFE, P.C. By ' effrey . Yoffie, Esq. Attorney for Laura K. Bolin 214 Senate Avenue, Suite 404 Camp Hill, PA 17011 (717) 975-1838 Attorney ID No. 52933 jyo ffe&verizon. net t BARCLAYS BANK DELAWARE IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 10-7768 CIVIL LAURA K. BOLIN A/K/A LAURA RELLINGER Defendant CIVIL ACTION VERIFICATION I hereby state that I am an adult individual who is authorized to make this verification and that the facts set forth in the foregoing answer are true to the best of my knowledge, information, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. _ Dated: /-/IF-// 0 ?' La ra K. Bolin 1 BARCLAYS BANK DELAWARE IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 10-7768 CIVIL LAURA K. BOLIN A/K/A LAURA RELLINGER Defendant CIVIL ACTION CERTIFICATE OF SERVICE The undersigned certifies that on the date indicated below he served a copy of the foregoing answer on David J. Apothaker, Esq. Service was accomplished by mailing the same to the below individual at the address indicated. Apopthaker & Associates, P.C. Attn: David J. Apothaker, Esq. 520 Fellowship Road C306 Mount Laurel, NJ 08054 YOFFE & YOFFE, P.C. Date: I // By Akq- A' ?JeffreyN. Yoffe, Esq. Attorney for Laura K. Bolin 214 Senate Avenue, Suite 404 Camp Hill, PA 17011 (717) 975-1838 Attorney ID No. 52933 Lyoff (@verizon.net Our File No.: 298234 BARCLAYS BANK DELAWARE Plaintiff vs. LAURA K BOLIN A/K/A LAURA Civil Action RELLINGER ) Defendant ) `= M r = , CJ7'? ? _ PRAECIPE FOR APPOINTMENT OF ARBITRATORS -: _ -fie w_ TO THE HONORABLE, THE JUDGES OF SAID COURT: -w Benjamin J. Cavallaro, Esquire, counsel for the Plaintiff in the above action, respectfully repreiJnt atT 1. The above-captioned action is at issue 2. The claim of Plaintiff in the action is $2114.97. The following attorneys are interested in the case as counsel or are otherwise disqualified to sit as arbitrators: For Defendant For Plaintiff Benjamin J. Cavallaro, Esquire 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. May 22, 2012 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.: 10-7768 CIVIL Respectfully Submitted, Benjamin . vallaro, Esquire ORDER OF COURT 5b a a Ck,J? 666'71 a-lwuq AND NOW, ZP , 20 in consideration of the foregoing petition, Esq., and Esq., and 7- ? Esq., are appointed arbitrators in the above captioned action as praye for. ,/SPn jam, m .S . eAUc, Memo I- C©Fa es ` .i . led ) Z/GG tae/ By the Court, ? ' 1100or 77