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Home My WebLink About11-0306Our File No.: 283842 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. DAVID W HAYES 35 SUNFIRE AVE CAMP HILL, PA 17011 Defendant. RLED-OFFICE "'! I JH 13 PM 2: E 71 NIBERLA"D CHIN` COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: I I- xo 0 0I V 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 a 09# -75302 Our File No.: 283842 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. DAVID W HAYES 35 SUNFIRE AVE CAMP HILL, PA 17011 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 DAVID W HAYES, an adult individual residing at 35 SUNFIRE AVE CAMP HILL, PA 17011. 3. Plaintiff, PORTFOLIO RECOVERY ASSOCIATES, LLC, is the Assignee and Successor in Interest of Account # ending in 7617; and said account was issued to Defendant(s) by CITIFINANCIAL, INC./ZIMMERMAN PLUMBING & HEATING, 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 $1,199.80. 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 $1,199.80 and requests this Court award costs to the extent permitted by applicable law. APOTHAKE & SOCIATES, P.C. Atto ey r Plaintiff A Law Firm g ed in Debt Collection Dated: 12/23/2010 BY: David J. Apothaker, Esquire Our File No.: 283842 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 relatin to sworn falsification to authorities. David J. Apothalr, Esquire Attorney for Plaintiff DATE: 12/23/2010 PORTFOLIO RECOVERY ASSOCIATES, LLC DAVID W HAYES 35 SUNFIRE AVE CAMP HILL, PA 17011 STATEMENT OF ACCOUNT Debtor's Name: DAVID W HAYES Account Number: ending in 7617 Original Creditor: CITIFINANCIAL, INC./ZIMMERMAN PLUMBING & HEATING Balance Due: $1,199.80 Our File No.: 283842 EXHIBIT "A" s 283842 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: DAVID W HAYES Serve Upon: DAVID W HAYES Address for Service: 35 SUNFIRE AVE CAMP HILL, PA 17011 Alternate Address for Service: Type of Service: O Personal (X) Adult in Charge O Deputize O 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 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy L'Oov ni utrr rf FILED-OFFICE OF THE PROTHONOTARY 2aI I SAN 24 AM 041 Richard W Stewart Solicitor Portfolio Recovery Associates, LLC vs. David W. Hayes °.rc c n ,-. F- 'I, c. CU PENNSYLVANIA TY Case Number 2011-306 SHERIFF'S RETURN OF SERVICE 01/19/2011 01:28 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on January 19, 2011 at 1328 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: David W. Hayes, by making known unto himself personally, at 35 Sunfire Avenue, Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $41.50 January 20, 2011 RYAN BURGETT, DEPUTY SO ANSWERS, RON R ANDERSON, SHERIFF C CoulrvSUlte She'd(. iF ro<oft. loL Our File No.: 283842 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. DAVID W HAYES Defendant. !? try REL. !? q3"1 ? t 4 f ?1 . COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 11-306-CIVIL PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & ASSOC S, P.C. Attorneys for Pl ti A Law Firm Engaged in eb Collection By: David J Dated: 3/9/2011 ?11?16011?1111?