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HomeMy WebLinkAbout14-6959 t Supreme Court-of Pennsylvania Cour' 'of Gammon Pleas Oe ' heet For Prothonotan-Use©nty: Tj f Io CC}lill Docket No: 'tlr j _f —t03'T 1VI IT614 0 71ne in,fo?marion collected on this form is used solely for court adini.nisn-ation purposes, ?Itis form does not supplement or replace the filing and ser-vice of pleadings or other papers as required by Imv op-rules of'court, S Commencement of Action: E ®Complaint El Writ of Summons ❑Petition ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking C Lead Plaintiffs Name: Lead Defendant's Name: T BARCLAYS BANK DELAWARE ROBERT A SOLOMON Dollar Amount Requested: ® within arbitration limits 0 Are money damages requested? ® Yes ❑ No (check ane) El outside arbitration limits tN Is this a Class Action Suit? ❑ Yes ® No Is this an MDJAppeal? ❑ Yes ® No A Name of Plaintiff/Appellant's Attorney: Apothaker Scian P.C. ❑ Check here if you have no attorney(are a Self-Represented [Pro Se] Litigant) Nature of the Case: Place an"X"to the left of the ONE case category that most accurately describes your PRIMARY CASE.If you are making more than one type of claim,check the one that you consider most important. TORT(do not include Mass Tort) CONTRACT(do not include.Judgments) CIVIL APPEALS ❑ Intentional ❑ Buyer Plaintiff Administrative Agencies ❑ Malicious Prosecution N Debt Collection:Credit Card ❑ Board of Assessment ❑ Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections ❑Nuisance ❑ Dept.of Transportation ❑Premises Liability ❑ Statutory Appeal:Other ❑ Product Liability(does not ❑ Employment Dispute: S include mass tort) Discrimination E ❑ Slander/Libel/Defamation ❑ Other: El Employment Dispute: Other ❑ Zoning Board C ,I, ❑ Other: ]< ❑ Other: O MASS TORT ❑ Asbestos N ❑ Tobacco ❑ Toxic Tart-DES REAL PROPERTY MISCELLANEOUS ❑ Toxic Tort-Implant ❑ Ejectment ❑ Common Law/Statutory Arbitration ❑ Toxic Waste ❑ Eminent Domain/Condenrnation ❑ Declaratory Judgment $ ❑ Other: ❑ Ground Rent ❑ Mandamus ❑ Landlord/Tenant Dispute ❑ Nan-Domestic Relations ❑ Mortgage Foreclosure: Residential Restraining Order ❑ Mortgage Foreclosure: Commercial ❑ Quo Warranto PROFESSIONAL ❑ Partition ❑ Replevin LIABLITY ❑ Quiet Title ❑ Other: ❑ Dental ❑ Other: ❑ Legal ❑ Medical ❑ Other Professional: Updated 1/1/2011 1 FILED-OFFICE Cr'" 11'E PROT 111ONOTAn`,' Our File No.: 385312 2914 NOV 26 APS 1 I- u9 Apothaker Scian P.C. By: David J. Apothaker, Esquire CUMBERLAND COUNTY I.D. #38423 FEPENNSYLVANIAYLPENNSYLVANIAYL 520 Fellowship Road Suite C306, PO Box' 5496 Mt. Laurel,NJ 08054-5496 (800)672-0215 Attorneys for Plaintiff BARCLAYS BANK DELAWARE ) COURT OF COMMON PLEAS 125 S WEST STREET ) CUMBERLAND COUNTY WILMINGTON, DE 19801NO.) ,+ Plaintiff, ) vs. ) ROBERT A SOLOMON ) 184 CONODOGUINET MOBILE EST ) NEWVILLE, PA 17241-9492 ) Defendant. ) 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. ltd CARLISLE .PA 17013 11- .'7-5 Pp 717-249-3166 0,11 M X3010 �� 3x3990 Our File No.: 385312 Apothaker Scian P.C. By: David J. Apothaker, Esquire Attorney I.D. #38423 520 Fellowship Road Suite C306, PO Box 5496 Mt. Laurel, NJ 08054-5496 (800)672-0215 Attomeys.for Plaintiff BARCLAYS BANK DELAWARE ) COURT OF COMMON PLEAS 125 S WEST STREET ) CUMBERLAND COUNTY WILMINGTON, DE 19801 ) NO.: Plaintiff, ) VS. ) ROBERT A SOLOMON ) 184 CONODOGUINET MOBILE EST ) NEWV1LLE, PA 17241-9492 ) Defendant. ) CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is BARCLAYS BANK DELAWARE, 125 S WEST STREET, WILMINGTON, DE 19801. 2. Defendant(s) is/are ROBERT A SOLOMON ("Defendant"), an adult individual residing at 184 CONODOGUINET MOBILE EST, NEWVILLE, PA 17241-9492. 3. At the special instance and request of Defendant, Plaintiff issued a credit account ("Account")to Defendant. 4. The Account number ends in 4627. 5. Defendant received, accepted and used the account by making purchases, balance transfers, and/or cash advances. 6. The account is in default due to Defendant's failure to make timely payments. 7. Although demand has been made, Defendant has failed to make payment of the amount due. 8. The amount due as of this date is $2,999.56. WHEREFORE, Plaintiff demands judgment in favor of Plaintiff and against Defendant(s) for the sum of$2,999.56 and requests this Court award costs to the extent permitted by applicable law. Apothaqedn n P.C. Attornaintiff A Law Firm EngDebt Collec ' BY: David J. Apotha er, Esquire Our File No.: 385312 n e • ^� 385312 VERIFICATION I, �� ereby state that I am for Plaintiff. I hereby verify that, upon information and belief,the statements made in the foregoing Civil Action Complaint are true and accurate. The undersigned understands that the statements therein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Affiant Name New Castle County, DE Defendant's Narne: ROBERT A SOLOMON Account Number: ending in 4627 Subsc ib anA sworn to before me this .2��~ day of Kz" Notary Public, County of New Castle, State of Delaware My commission expires: i 1 m/07— Nq,y �� •CJ 2•. EXP2A 215 , Jai_ v.w i 0v•�\ ��i ••�L�TARY P.�•�aQ��� Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY ,s < r; 4 HE PROTii() OFFICE QFTF'" £P'°rRiFF LOIiDEC 15 NI 3:2; CUMBERLAND COUNTY PENNSYLVANIA Barclays Bank Delaware vs. Case Number Robert A Solomon 2014-6959 SHERIFF'S RETURN OF SERVICE 12/09/2014 Jody S. Smith, Chief Deputy served the requested Complaint & Notice by "personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Robert A Solomon at the Cumberland County Sheriffs Office, One Courthouse Square, Carlisle, PA 17013. SHERIFF COST: $55.12 SO ANSWERS, December 09, 2014 RONNY R ANDERSON, SHERIFF (c) CountySuito Shoritr, Tc-eosoft. Inc.