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HomeMy WebLinkAbout10-7769Our File No.: 298253 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. ALISSA PRICE 30 SUMMERFIELD DR CARLISLE, PA 17015-6931 Defendant. ZQ~ Q QEC i t P!~ 2~ 4 7 GjJMBER~,A~p CC1U~~TY ~E~1l~SY~.~~~N~~ COURT OF COMMON PLEAS CUMBERLAND COUNTY ~'~ ~, I 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 ~~~ asas~y Our File No.: 298253 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. ALISSA PRICE 30 SUMMERFIELD DR CARLISLE, PA 17015-6931 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. ~~,~ ~~~i I G~~~ CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is BARCLAYS BANK DELAWARE, 125 S WEST STREET, WILMINGTON, DE 19801. 2. Defendant(s) is/are ALISSA PRICE, an adult individual residing at 30 SUMMERFIELD DR CARLISLE, PA 17015-6931. 3. At the special instance and request of Defendant, Plaintiff, BARCLAYS BANK DELAWARE, issued to Defendant(s), Account # ending in 0077. 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 $2,660.62. 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 $2,660.62 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & AS Attorney for A Law Firm Engaged BY: Dated: 12/8/2010 RTES, P.C. Collection David J. Apothal~, Fis(quire Our File No.: 298253 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, and belief. The undersigned understands that the statements therein are made subject to the penalties of 18 Pa.C.S.A. 4964 relating to unsworn falsification to authorities. David J. Aper, Esquire Attorney for Plaintiff DATE: 12/8/2010 BARCLAYS BANK DELAWARE ALISSA PRICE 30 SUMMERFIELD DR CARLISLE, PA 17015-6931 STATEMENT OF ACCOUNT Debtor's Name: ALISSA PRICE Account Number: ending in 0077 Balance Due: $2,660.62 Our File No.: 298253 EXHIBIT "A" Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY 1 "LED f , ra ,Ig114 1 i 1- V1, ... fR Tetr ,n?ry?1 fi 7i 1, `t . 't 4 Barclays Bank Delaware vs. Case Number Alissa Price 2010-7769 SHERIFF'S RETURN OF SERVICE 01/07/2011 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: Alissa Price, but was unable to locate her in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant Alissa Price. Request for service at 30 Summerfield Drive, Carlisle, Pennsylvania 17015 the defendant was not found. However, The Carlisle Postmaster is still delivering Alissa Price's mail to 30 Summerfield Drive, Carlisle, Pennsylvania 17015. SHERIFF COST: $33.40 SO ANSWERS, January 07, 2011 RONW R ANDERSON, SHERIFF Our File No.: 298253 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker Attorney I.D.# 38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff BARCLAYS BANK DELAWARE Plaintiff, vs. ALISSA PRICE Defendant. 66 yk' t. 1 J i, a t .)Y•L fJ i COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 10-7769 CIVIL PRAECIPE TO REINSTATE COMPLAINT - CIVIL ACTION TO THE PROTHONOTARY: Kindly reinstate the Complaint in the above captioned Civil Action for an additional thirty (30) days. APOTHAKER & ASSO S, P.C. Attorney for Pain A Law Firm Engaged ' De t Coll ion BY: David J. Anothak Esquire Dated: 3/4/2011 g/It