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Home My WebLink About11-0299Our File No.: 289628 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. DARRELL M HUGHES 276 REDWOOD LN CARLISLE, PA 17015 Defendant. 1C } ^ '•i E,iE J?' 13 P? 2? s r u BERL, COURT OF COMMON PLEAS CUMBERLAND COUNTY i NO.: I I- ??41 C/ /'V 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 fif4. ° /Z1???53?aa3 Our File No.: 289628 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. DARRELL M HUGHES 276 REDWOOD LN CARLISLE, PA 17015 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 DARRELL M HUGHES, an adult individual residing at 276 REDWOOD LN CARLISLE, PA 17015. 3. Plaintiff, PORTFOLIO RECOVERY ASSOCIATES, LLC, is the Assignee and Successor in Interest of Account # ending in 4200; 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 $2,839.69. 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 $2,839.69 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & Attorney A Law Firm Enaai ,SO IATES, P.C. Pl tiff in debt Collection BY: David J. Apothaker, Esquire Dated: 12/23/2010 Our File No.: 289628 VERIFICATION David J. Mthaker, 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 relating to unworn falsification to authorities. DATE: 12/23/2010 Attorney for Plaintiff PORTFOLIO RECOVERY ASSOCIATES, LLC DARRELL M HUGHES 276 REDWOOD LN CARLISLE, PA 17015 STATEMENT OF ACCOUNT Debtor's Name: DARRELL M HUGHES Account Number: ending in 4200 Original Creditor: CAPITAL ONE BANK, N.A. Balance Due: $2,839.69 Our File No.: 289628 EXHIBIT "A" 289628 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: DARRELL M HUGHES Serve Upon: DARRELL M HUGHES Address for Service: 276 REDWOOD LN CARLISLE, PA 17015 Alternate Address for Service: Type of Service: ( ) Personal (X) Adult in Charge () Deputize () Certified Mail () 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 4 A.POT*HAKER& AsSOCIATES, P.C. ATTORNEYS AT LAW December 23, 2010 PROTHONOTARY 1 COURTHOUSE SQUARE CARLISLE, PA 17013 RE: PORTFOLIO RECOVERY ASSOCIATES, LLC VS. DARRELL HUGHES DOCKET NO.: OUR FILE NO: 289628 DEAR CLERK: Enclosed please find an original and two copies of a Civil Action Complaint in the above referenced action. A check in the amount of $92.00 for filing is enclosed. Please file and return a filed copy to this office in the self-addressed stamped envelope enclosed for your convenience. Kindly forward the complaint to the sheriffs office to have the Defendants served at: 276 REDWOOD LN, CARLISLE, PA 17015. Enclosed is a check in the amount of $100.00 for Sheriffs costs. Please send the return of service back to my office in the enclosed self addressed stamped envelope after service is accomplished. Thank you for your cooperation in this matter. If you should have any questions please do not hesitate to contact me. APOTHAKER & ASSOCIATES, P.C. /KM 520 Fellowship Road, C306, Mount Laurel, NJ 08054 856 780.1000 856 780.1020f 215 634.8920 215 634.8421f' 800 672.0215 800 757.4928f' SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith FE8 , Chief Deputy P? ; 1 r Richard W Stewart ?7r r alr? ?.i1t `, Solicitor a ? ??; ?•Y? brim R??v ?" ? ,1 ` Portfolio Recovery Associates, LLC Case Number vs. Darrell M. Hughes 2011-299 SHERIFF'S RETURN OF SERVICE 02/11/2011 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that on February 11, 2011 at 0935 hours, he was unable to serve a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Darrell M. Hughes. After several attempts the Complaint and Notice has expired. SHERIFF COST: $49.60 SO ANSWERS, February 11, 2011 RON - RANDERSON, SHERIFF Our File No.: 289628 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 PORTFOLIO RECOVERY ASSOCIATES, LLC Plaintiff, vs. DARRELL M HUGHES Defendant FILED-OFFICE 'F THE PROTHONOTAR 2011 MAY 2l AM I 1 * 25 CUMBERLSAYND COUNTY COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 11-299-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 & SO IATES, P.C. Attorney r Pl 'ntiff A Law Firm Engag i Debt Coll ion BY: David J. Apothaker, Esquire Dated: 5/12/2011 i"') 6.k L- 2-7-76A (Z*'? S1 T Is SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson FILED-OFFICE Sheriff OF THE PROTHONOTARY 4?it??. qi t?tir?br????t4 Jody S Smith 2011 JUN 29 AM 9* 21 Chief Deputy Richard W Stewart CUMBERLAND COUNTY Solicitor`` ?t PENNSYLVANIA Portfolio Recovery Associates, LLC Case Number vs. Darrell M. Hughes 2011-299 SHERIFF'S RETURN OF SERVICE 06/23/2011 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that on June 23, 2011, he was unable to serve a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Darrell M. Hughes. After six attempts the occupant of 276 Redwood Lane, Carlisle, Cumberland County, Pennsylvania 17013 will not answer the door. Neighbors advised Deputies, Darrell M. Hughes does not speak to anyone since his wife passed away. SHERIFF COST: $34.00 SO ANSWERS, June 27, 2011 R-ONIVY R ANDERSON, SHERIFF (cj GourtySirte She? +,+. Te!ec u't. 1, ,-, SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff r rt 1' 141 X1,1" of L tuur?rr;r7?d "? ? ?Jody S Smith Chief Deputy - 2011 AUG _5 PM 2; 9 Richard W Stewart Solicitor - ° CUMBERLAND COUN PENNSYLVANIA Portfolio Recovery Associates, LLC Case Number vs. Darrell M. Hughes 2011-299 SHERIFF'S RETURN OF SERVICE 07/26/2011 03:21 PM - Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on July 26, 2011 at 1521 hours, she served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Darrell M. Hughes, pursuant to order of court by posting the premises located at 276 Redwood Lane, Carlisle, Cumberland County, Pennsylvania 17013 with a true and correct copy according to law. r ANDA COBALIH, DEPU August 02, 2011 SO ANSWERS, K'S?" N - Z?2 RON R ANDERSON, SHERIFF