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Home My WebLink About07-3898APOTHAKER & 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 PINNACLE CREDIT SERVICES LLC c/o Apothaker & Associates, P.C. 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 Plaintiff, VS. MICHAEL C HUGENDUBLER 4 BRIER RD CAMP HILL, PA 17011 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 67 - 30040' a,-,, ? LNOTICE 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 notificacion. Hace falta asentar una comparencia escrita o con un abogado v entregar a la corte 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 notificacion. Ademas, la corte puede decidir a favor del edemandante y requiere que usted compla con todas las provisioner 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 PARA 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 PINNACLE CREDIT SERVICES LLC c/o Apothaker & Associates, P.C. 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 Plaintiff, vs. MICHAEL C HUGENDUBLER 4 BRIER RD CAMP HILL, PA 17011 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: O -/. 3 19 S' C-? d- -rA- - CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff, PINNACLE CREDIT SERVICES LLC, is a company with its principal place of business located at c/o Apothaker & Associates, P.C., 2417 Welsh Road, Suite 21 #520, Philadelphia, PA 19114 2. Defendant is MICHAEL C HUGENDUBLER, an adult individual residing at 4 BRIER RD CAMP HILL, PA 17011. 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 Plaintiffs 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 $2,229.88. 8. Although demand has been made, Defendant has failed to make payment of the amount due as above. 9. The original creditor is CHASE MANHATTAN BANK. WHEREFORE, Plaintiff demands judgment in favor of Plaintiff and against Defendant(s) for the sum of $2,229.88 plus costs, and reasonable attorney's fees. APOTHAKER & ASSOCIATES, P.C. Attorne for Plaintiff A Law Firm Eo6a4ed in Debt Collection BY: Dated: 6/19/2007 Our File No.: 101257 VERIFICATION David J. Apothaker, Esq. 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. David J. A?Oake Attorney for Plainti DATE: 6/19/2007 PINNACLE CREDIT SERVICES LLC c/o Apothaker & Associates, P.C. 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 MICHAEL C HUGENDUBLER 4 BRIER RD CAMP HILL, PA 17011 STATEMENT OF ACCOUNT Debtor's Name: MICHAEL C HUGENDUBLER Account Number: 5183377560082547 Original Creditor: CHASE MANHATTAN BANK Balance Due: $2,229.88 Our File No.: 101257 EXHIBIT "A" o 'v T,tr, L: i...l a v W 0 f "y# 113 (ot-3 CASE NO: 2007-03898 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PINNACLE CREDIT SERVICES LLC VS HUGENDUBLER MICHAEL C MEGAN MARLOW , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon HUGENDUBLER MICHAEL C the DEFENDANT , at 1806:00 HOURS, on the 11th day of July , 2007 at 4 BRIER ROAD CAMP HILL, PA 17011 MICHAEL HUGENDUBLER by handing to a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 14.40 Affidavit .00 Surcharge 10.00 00 b' 1 b j61 ?,?• V42.40 Sworn and Subscibed to before me this day of , So Answers: R. Thomas Kline 07/12/2007 APOTHAKER & ASSOC By. D puty Sheriff A.D. THOMAS J. LIOTT, JR., IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW KARTINA L. SIMISNEAN, 2007-3896 CIVIL TERM Defendant IN CUSTODY KARTINA LYNN SIMISNEAN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW / THOMAS JAMES LIOTT, JR.,: 2007-3998 CIVIL TERM t/ Defendant IN CUSTODY ORDER OF COURT AND NOW, this 15th day of October, 2007, upon consideration of the issue of custody with respect to the parties' child and following an initial period of hearing which has not yet been completed, the record shall remain open and counsel are requested to contact the Court's secretary for purposes of scheduling an additional day of hearing in this matter. It is noted that at the time of adjournment on today's date the father had testified and father's counsel was cross-examining mother. It is further noted that at the time of adjournment Mother's Exhibits 1 and 4 had been introduced and admitted and no other exhibits had been introduced or admitted. It is noted that counsel for the father has requested that a copy of the transcript of today's proceeding be provided to him and that the notes of testimony be transcribed and filed. The Court will enter a temporary order based upon the testimony received in the near future and pending further order of Court. Pending entry of the temporary order, the existing order of Court shall remain in full force and effect. '4L By the Court, 1 J.1 Wesley Ober;, Jr., ,J. James A. Miller, Esquire 356 North 21st Street Ciam Hill PA 17011 For the Father Jeffrey N. Yoffe, Esquire 214 Senate Avenue, Ste 404 Camp Hill, PA 17011 For the Mother pcb f I"..' r?- ?; n ?' a . ? ?? ?- w ?? Q r Our File No.: 101257 APOTHAKER & ASSOCIATES, P.C. 2417 Welsh Road, Suite 21 #520 t Philadelphia, PA 19114 (215) 634-8920 Attorneys for Plaintiff David J. Apothaker, Esquire Attorney ID #38423 PINNACLE CREDIT SERVICES LLC ) Plaintiff, ) VS. ) MICHAEL C HUGENDUBLER ) Defendant. ) COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 07-3898 Civil Action PRAECIPE TO ENTER DEFAULT JUDGMENT TO THE PROTHONOTARY: Please enter a default judgment in favor of plaintiff, PINNACLE CREDIT SERVICES LLC and against Defendant, MICHAEL C HUGENDUBLER, for failure to answer or otherwise respond to the Complaint - Civil Action. The Complaint was served upon the defendants on July 11, 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 September 11, 2007, and also attached hereto. Assess damages in the amount of. f (a) Balance: $2,229.88 (b) Interest from June 19, 2007 $46.55 (c) Costs $120.90 TOTAL $2,397.33 APOTHAKER & ASSOCIATES, P.C. Attorney f r Plaintiff A Law Firm End a in Debt Collection By: David J. Dated: 10/24/2007 I APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker Attorney I.Ds#38423 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 (215) 634-8920 Attorney for Plaintiff PINNACLE CREDIT SERVICES LLC COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff, vs. MICHAEL C HUGENDUBLER Defendant. AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND NO.: 07-3898 Civil Action : SS. 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 4 BRIER RD CAMP HILL, PA 17011. 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 Defe6se ]Manpower Data Center has sent back our inquiry indicated that the Defendant(s) is/are not i? the Military. 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. Request for Military Status Department of Defense Manpower Data Center 40 Military Status Report Pursuant to the Servicemembers Civil Relief Act Page 1 of 2 OCT-24-2007 11:48:30 Last Name First/Middle Begin Date _ Active Duty Status T_ -- Tservice/Agency HUGENDUBLER MICHAEL Based on the information you have furnished, 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. 4101 )?, it 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. §§ 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.mil/faq/pis/PC09SLDR.html WARNING: This certificate was provided based on a name and Social Security number (SSN) provided https://www.dmde.osd.mil/scra/owa/scra.prc_Select 10/24/2007 Our File No.: 10 1257 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 PINNACLE CREDIT SERVICES LLC COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff, vs. MICHAEL C HUGENDUBLER 4 BRIER RD CAMP HILL, PA 17011 Defendant. NO. 07-3898 NOTICE OF INTENTION TO TAKE DEFAULT TO: MICHAEL C HUGENDUBLER DATE OF NOTICE: September 11, 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 find out where you can get legal help: CUMBERLAND COUNTY BAR ASSOCIATION Lawyer Referral and Information Service 800-990-9108 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 #38423 SHERIFF'S RETURN REGULAR CASE NOS 2007-03898 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PINNACLE CREDIT SERVICES LLC VS HUGENDUBLER MICHAEL C MEGAN MARLOW Sheriff or Deputy Sheriff of Cumberland County,Fennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon H7JGE3DUBLER MICHAEL C the DEFENDANT , at 1806:00 HOURS, on the lath day of July , 2007 at 4 BRIER ROAD CAMP HILL, PA 17011. by handing' to MICHAEL HUGENDUBLER a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: So Answers. Docketing 18.00 14.40 Service Affidavit .00 Surcharge 10.00 R Thomas Kline 00 42.40 07/12/2007 APOTHAKER & ASSOC Sworn and Subscibed to By ? -? before me this day ?puty Sheriff of , A.D. cn 0 00 D -r? OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS TO: ` MICHAEL C HUGENDUBLER 4 BRIER RD CAMP HILL, PA 17011 PINNACLE CREDIT SERVICES LLC Plaintiff, vs. MICHAEL C HUGENDUBLER 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. COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 07-3898 Civil Action 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 Es. at this telephone number: 215-634-8920 /1/0-7)01 /-S/ C'Lt? P. &X-j 'K6