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HomeMy WebLinkAbout07-2264A1~OTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esq. Attorney I.D.#38423 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 (215) 634-8920 Attorneys for Plaintiff DISCOVER BANK c/o Apothaker & Associates, P.C. 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 Plaintiff, vs. JARED M BLOUCH 1201 LOUISA LN MECHANICSBURG, PA 17050 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY Y 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 with 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 my 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 ONE. 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. CUMBERLAND COUNTY BAR ASSOCIATION Lawyer Referral and Information Service 800-990-9108 AVISO Le han demandado a usted en la Corte. Si usted quiere defenderse do estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notification. Hate falta asentar una comparencia escrita o con un abogado v entregar a la cone en forma escrita sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la Corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notification. Ademas, la torte puede decidir a favor del edemandante y requiere que usted compla con todas las provisiones de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes pare usted. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO. VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARR AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. CUMBERLAND COUNTY BAR ASSOCIATION Lawyer Referral and Information Service 800-990-9108 ApOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esq. Attorney I.D.#38423 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 (215) 634-8920 Attorneys for Plaintiff DISCOVER BANK c/o Apothaker & Associates, P.C. 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 Plaintiff, vs. JARED M BLOUCH 1201 LOUISA LN MECHANICSBURG, PA 17050 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff, DISCOVER BANK, is a company with its principal place of business located at c/o Apothaker & Associates, P.C., 2417 Welsh Road, Suite 21 #520, Philadelphia, I'A 19114. 2. Defendant is JARED M BLOUCH, an adult individual residing at 1201 LOUISA LN MECHANICSBURG, PA 17050. 3. At the special instance and request of Defendant, Plaintiff sold and delivered to Defendant goods and/or services at the times, of the kinds, in the quantities, and for the prices set forth in Plaintiff s records. A true and correct copy of which is attached hereto, incorporated herein by reference and designated Exhibit "A". 4. Defendant received and accepted the goods and/or services described in Exhibit "A". 5. The prices set forth in Exhibit "A" are the fair, reasonable and market prices for said goods and/or services, and the prices which Defendant agreed to pay. 6. All credits, if any, to which Defendant is entitled, are set forth in Exhibit "A". 7. In addition, Plaintiff avers that Defendant has failed and continues to fail to make any payments, leaving a balance due and owing of $9,721.26 from September 11, 2003. 8. Although demand has been made, Defendant 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 $9,721.26 plus costs, and reasonable attorney's fees. APOTHAKER & ASSOCIATES, P.C. Attorney for Plaintiff A Law Firm Engd in Debt Collection BY: J. Dated: 4/10/2007 Our File No.: 91448 VERIFICATION David J. A othaker Es .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 unsworn falsification to authorities. DATE: 4/10/2007 DISCOVER BANK c/o Apothaker & Associates, P.C. 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 JARED M BLOUCH 1201 LOUISA LN MECHANICSBURG, PA 17050 STATEMENT OF ACCOUNT Debtor's Name: JARED M BLOUCH Account Number: 6011002250711728 Date of Debt: September 11, 2003 Balance Due: $9,721.26 Our File No.: 91448 EXHIBIT "A" `~L'7} t;t1 .~ ~ °7 rir ~ _J ~.~, d ~ ~ ~c ~ ~ c4 ~z ?~ e•s ~i _a ss -r~ ~ ~ ~'~x3~ ~ ~? CASE NO: 2007-0264 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF ENNSYLVANIA: COUNTY OF CUMBER AND DISCOVER BANK V BLOUCH JARED M RONALD HOOVER Sheriff or Deputy Sheriff of Cumberland Coun y,Pennsylvania, who being duly sworn according to law, says, the withi COMPLAINT & NOTICE was served upon RT.f1TT(''Ta ,TARRTI M the DEFENDANT ~ at 1843:00 HOURS, on the 2nd day of May 2007 at 1201 LOUISA MECHANICSBURG, JARED M BLOUSH A 17050 by handing to a true and attested copy of COMPLAINT & NOTICE together with and at the samq~ time directing His attention to the contents thereof. Sheriff's Cost Docketing 18.00 Service 24.96 Postage .39 Surcharge 10.00 .00 ~/~ y/o ~ ~ . 3 5 Sworn and Subs ibed to before me this day of , So Answers R. Thomas Kline 05/03/2007 APOTHAKER & ASSOCIATES By: Deputy S riff A.D. Our File No.: 91448 APOTHAKER & ASSOCIATES, P.C. 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 4215) 634-8920 Attorneys for Plaintiff David J. Apothaker, Esquire Attorney ID #38423 DISCOVER BANK Plaintiff, vs. JARED M BLOUCH Defendant. COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 2007-02264 Civil Action PRAECIPE TO ENTER DEFAULT JUDGMENT TO THE PROTHONOTARY: Please enter a default judgment in favor of plaintiff, DISCOVER BANK and against Defendant, JARED M BLOUCH, for failure to answer or otherwise respond to the Complaint -Civil Action. The Complaint was served upon the defendants on May 2, 2007 by the CUMBERLAND Sheriff s Department. Copies of the proofs of service are attached hereto as Exhibit "A". I certify, a copy of the Notice of Intention To Take Default was mailed on June 6, 2007, and also attached hereto. Assess damages in the amount of: (a) Balance: $9,721.26 (b) Interest from Apri110, 2007 $150.22 TOTAL $9,871.48 APOTHAKER & ASSOCIATES, P.C. Attorneys o Plaintiff A Law Firm Ent a in Debt Cohectio~ By: Apothaker Dated: 7/13/2007 ~a ~ ~ c.,°, O ~I4- ~ ~! ~ `~ ~ ' F -~ ~--'_ r n i~t ~ # cn. - w ~ ~ ~ O r a C ~ z ~ ~ } ~ £~ ~ ~ ~ 4j D ~- t.D J m C ~ D ~ ~``~ --- --~ OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS TO: JARED M BLOUCH •1201 LOUISA LN MECHANICSBURG, PA 17050 COURT OF COMMON PLEAS OF DISCOVER BANK ) CUMBERLAND COUNTY Plaintiff, ) vs. ) NO.: 2007-02264 JARED M BLOUCH ) Civil Action Defendant. ) NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. XX JUDGMENT BY DEFAULT JUDGMENT IN REPLEVIN JUDGMENT BY CONFESSION JUDGMENT FOR POSSESSION JUDGMENT ON AWARD OF ARBITRATORS JUDGMENT ON VERDICT JUDGMENT ON COURT FINDINGS JUDGMENT ON WRIT OF REVIVAL IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: ATTORNEY David J. Apothaker, Esc at this telephone number: 215-634-8920 o~.uQy 31, aoo7 /s/ (.ut.i*b ~. ,Coxq arcs U APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker Attorney I.D.#38423 2417 Welsh Road, Suite 21 #520 ~hiladalphia, PA 19114 (215) 634-8920 Attorney for Plaintiff DISCOVER BANK ) COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff, ) vs. ) NO.: 2007-02264 JARED M BLOUCH ) Civil Action Defendant. ) AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA SS. COUNTY OF CUMBERLAND David J. Apothaker, being duly sworn according to law, deposes and says that I am the attorney for Plaintiff, and authorized to make this affidavit; that Defendant(s) resides at 1201 LOUISA LN MECHANICSBURG, PA 17050. We inquired with the web site of the Defense Manpower Data Center, located at 1600 Wilson Boulevard, Suite 400, Arlington, VA 22209-2593, if the Defendant(s) is/are in any branch. of the military. Mary M. Snavely-Dixon, Director of the Manpower Data Center has sent back our inquiry indicated that the Defendant(s) is/are not David J. Apothaker Attorney for Plaintiff The above signed understands that the statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. ~ ~ ~ ~ ~i _ ~-'t~~ `~ ~- " (, _ W '"~ r ;':~ ~i'_? - tU ~a ' t~ -- ; ..~ ~ ^G Request for Military Status Department of Defense Manpower Data Center Military Status Report Pursuant to the Servicemembers Civil Relief Act Page 1 of 2 JUL-13-2007 08:39:32 Last Name First/Middle Begin Date Active Duty Status ServicelAgency BLOUCH JARED Based on the information you have famished, the DMDC does not possess any information indicating that the individual is currently on active duty. Upon searching the information data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the current status of the individual as to all branches of the Military. ~ ~-~ Mary M. Snavely-Dixon, Director Department of Defense -Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The Department of Defense strongly supports the enforcement of the Servicemembers Civil Relief Act [50 USCS Appx. #167;#167; 501 et seq] (SCRA) (formerly the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's active duty status by contacting that person's Military Service via the "defenselink.mil" URL provided below. If you have evidence the person is on active-duty and you fail to obtain this additional Military Service verification, provisions of the SCRA may be invoked against you. If you obtain further information about the person (e.g., an SSN, improved accuracy of DOB, a middle name), you can submit your request again at this Web site and we will provide a new certificate for that query. This response reflects current active duty status only. For historical information, please contact the Military Service SCRA points-of-contact. See: http•//www defenselink miUfaq/pis/PC09SLDR.htm1 WARNING: This certificate was provided based on a name and Social Security number (SSN) provided https://www.dmdc.osd.miUscra/owa/scra.prc_Select 7/13/2007 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker Attorney I.D.#38423 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 (215) 634-8920 Attorney for Plaintiff DISCOVER BANK COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff, vs. JARED M BLOUCH 1201 LOUISA LN MECHANICSBURG, PA 17050 Defendant. N0.2007-02264 NOTICE OF INTENTION TO TAKE DEFAULT TO: JARED M BLOUCH DATE OF NOTICE: June 06, 2007 IMPORTANT NOTICE You are in default because you have failed to enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice as set forth above, a judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to fmd out where you can get legal help: CUMBERLAND COUNTY BAR ASSOCIATION Lawyer Referral and Information Service 800-990-9108 ISI DAVID J. APOTHAKER, ESQUIRE A Law Firm Engaged in Debt Collection 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 (215) 634-8920 Attorney for Plaintiff Attorney ID #3 8423 Our File No.: 91448 e~~ , : ' ~ ~ r W i _ ~ {,~ ~"~ ~" N .,..,. ,..~ SHER1FFlS RE~'TJRN -- RECUL,7~R CASE N~}: 20137-:022b4 P CCIMMQI+IWEAL;TH ©F PENNSYLVANIA s CC3UNTY (3F C'~IMHERLANTi DISCQVER HAIv` VS SLOUCH JARED M '' RONALD HC~UVER , .Sheriff ar Deputy Sheriff of Cumbezland County, Pennsylvania, rho being duly sworn accord:.rzg to law, sa}~'s, the within CdMF'.LAINT & NQTICE was served upon, r'3%~UUCH JARED M t fae DEFENbANT at 1843:00 Ht3URS, on the 2nd day caf May 2007 , at ?2O1 LOU~SA hANE MECHANICSBURG, PA 170.50 by handing tc~ JARED M BLdUSH a trueand attested capy of C{?MPLATNT & NOTICE together with and at the same time directing>His attention. to the contents thereof. Sheriff's costs: So Answerer Doc~teting 18 .0~? ~ ~, Service 2 4 . 9 6 -~:~~:-~..~-. ,~~~,,,,. Surcharge IC.OD R. Thomas Kline 0 C~ 53.35 05/a3j2oo7 APOTHA.KER & ASSQC2A'ES Sworn and Subscihed to gy; .--~ before me this ~~l' Deputy S riff of ~ A.D.