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Home My WebLink About11-0298A Our File No.: 289703 ' 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. MELISSA L HOLMES 521 TERRACE DR NEW CUMBERLAND, PA 17070 Defendant. rLi rEL"- 74 '..? ., p130 i 1JAN13 PM 2:!3 PENNSYLVA Ii4, COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: / /- WW A '/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 ? ??t i3? sa Our File No.: 289703 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. MELISSA L HOLMES 521 TERRACE DR NEW CUMBERLAND, PA 17070 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 MELISSA L HOLMES, an adult individual residing at 521 TERRACE DR NEW CUMBERLAND, PA 17070. 3. Plaintiff, PORTFOLIO RECOVERY ASSOCIATES, LLC, is the Assignee and Successor in Interest of Account # ending in 1733; and said account was issued to Defendant(s) by CAPITAL ONE BANK, N.A., 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 $1,914.28. 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 $1,914.28 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & AS CIATES, P. Attorney for rnIlebt 'tiff A Law Firm Engaged C e t BY: David I Anothakh Zsauire Dated: 12/23/2010 Our File No.: 289703 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 understands that the statements therein are made subject to the penalties of 18 Pa.C.S.A. 4904 relatip(g to David J. Apc Attorney falsification to authorities. Esquire DATE: 12/23/2010 PORTFOLIO RECOVERY ASSOCIATES, LLC MELISSA L HOLMES 521 TERRACE DR NEW CUMBERLAND, PA 17070 STATEMENT OF ACCOUNT Debtor's Name: MELISSA L HOLMES Account Number: ending in 1733 Original Creditor: CAPITAL ONE BANK, N.A. Balance Due: $1,914.28 Our File No.: 289703 EXHIBIT "A" 289703 Request for Service R. Thomas Kline Sheriff Cumberland County Office of the Sheriff One Courthouse Square Carlisle, PA 17013 Ph: 717.240.6390 Fx: 717-240-6397 Plaintiff/s: Court Number: PORTFOLIO RECOVERY Expiration Date: ASSOCIATES, LLC Type of Action: Civil Action Defendant/s: MELISSA L HOLMES Serve Upon: MELISSA L HOLMES Address for Service: 521 TERRACE DR NEW CUMBERLAND, PA 17070 Alternate Address for Service: Type of Service: ( ) Personal (X) Adult in Charge O Deputize O Certified Mail O Posting Special Service Instructions: ** If service is to be made by deputized service to another county please specify which county Filing Attorney Information: Name: Apothaker & Associates, P.C. Address: 520 Fellowship Road C306 Mount Laurel, NJ 08054 Telephone: 215-634-8920 Our File No.: 289703 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 Plaintiff, vs. MELISSA L HOLMES Defendant. -CiFFICL t..? PIOTHONOTAR"i 2011 FEB 28 AM 8: 20 CUMBERLAND COUNTY PENNSYLVANIA COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 2011-298 PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & ASSOCIATES, P.C. Attorneys for P ",tiff A Law Firm Engaged i De t Collection By: Dated: 2/16/2011 David J. Apoth? r, Esquire 111M I