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Home My WebLink About08-1801Our File No.: 150135 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esq. Attorney I.D.1#38423 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 (215)-634-8920 Attorneys for Plaintiff CAPITAL ONE BANK c/o Apothaker & Associates, P.C. 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 Plaintiff, VS. CHRISTOPH J PRYOR 1826 ANNA ST NEW CUMBERLAND, PA 17070-1205 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 09- 1801 NOTICE 0 1Vil lean 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. 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. 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 CAPITAL ONE BANK c/o Apothaker & Associates, P.C 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 Plaintiff, VS. CHRISTOPH J PRYOR 1826 ANNA ST NEW CUMBERLAND, PA 17070-1205 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 0 F- / Fa l C?-) e 1 CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff, CAPITAL ONE 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, PA 19114. 2. Defendant is CHRISTOPH J PRYOR, an adult individual residing at 1826 ANNA ST NEW CUMBERLAND, PA 17070-1205. 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 $2,030.63. v_ 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 $2,030.63 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOT ASSOCIATES, P.C. 7F'En?kaged y for Plaintiff A Law in Debt Collection BY: Dated: 2/29/2008 David J. Apothaker Our File No.: 150135 VERYFICAR N m hereby states t&at I am 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 IS pa.C.S.A. 4904 relating to unswom falsification to authorities. DATB: Now with FREE Accelerator • • for the brat 12 nvanthsr-a 060 value a 97* ?I H 13 first 3 months; $9.Mhrro. thereafter SON UP TODAYI ' 1-888-587-9669 Mention Offer Code: EMERALD Or visit www.peoplopc.com/go/emerald a `/Z., , GOLD VISA ACCOUNT /((, 4388-6420-8455-5633 Account S Previous Balance $1,078.91 Payments Credits and Adjustments $.00 Transactions $11,00 Finance Charges $21.93 New Balance $1,141.84 Minimum Amount Due $1,141.84 Payment Due Date April 02, 2005 Total Credit Line $800 Total Available Credit $.00 Credit Line for Cash $800 Available Credit for Cash $.00 At your service To cell Customer Relations or to report a lost or stolen card: 1-800-903-3637 For free online account service and special automer offer, log on to. waM1V.espit loneoom Send Payment to: Send inquiries to. Attn: Remittance Processing Capital One Bank Capital One Services P.O. Box 790216 P.O. B. 95015 St. Louis, MO 63179-0216 Richmond, VA 23285-5015 Important Account Information Please review the important information enclosed with your statement and keep a copy for your records. Payments, Credits and Adjustments FEB 04 - MAR 03, 2005 Page 1 of 1 Transactions 1 03 MAR CAPITAL ONE MONTHLY MEMBER FEE $6.00 2 03 MAR PAST DUE FEE 35.00 You wen assessed a p due fee of $35.00 on 03/03/2005 because your minimum payment was not received by the due chit of 0310312005. To avid this fee in the fiuure, we recommend that you allow at least 7 business days for your payment to reach Capital One. Flmanen Charges Plewesee rrtvnex deforimpwta iffiormahm Balmvv>? e Fe Period Cmrr pondmg ?? AP pA PURCHASES $1,089.66 .07189%P 26.244 $2L93 CASH $.oo .0718996P 26.2496 $.00 ANNUAL PERCENTAGE RATE applied this period 26.24% PLEASE RETURN PORTION BELOW WITH PAYMENT V jowl 0000000 0 4388642084555633 03 1141840100001141843 New Balance $1.141.84 Minimum Amount Due $1,141.84 Payment Due Date April 02, 2005 Total enclosed S ? Account Number. 4388-6420-8455-5633 Jtreet Apt # sty s x ZIP Home Plane Altemste Phone #9006366301285656# MAIL ID NUMBER Capital One Bank CHRISTOPH J PRYOR P.O. Box 790216 1826 ANNA ST St. Louis, MO 63179-0216 v NEW CUMBERLAND PA 17070-1205 Please wrde ww arrount number on your dmck or money order made ,able to Capital One Bank and mail in the a Ixed a Ivte. A-pri f-.Iiagaddva armors-sward-&,&1 -g R. orala<F-k peoplepc- online %1J A better way to Internet. PeoplePC Online offers the features you would expect from higher-priced Internet Service Providers at half price for the first 3 months! ® Virus Protection powered by Symentec- ® Pop-Up Blocker- 1? Spam Controls ® 4 Smarter Smart Dialer Technology ® EW More Email Addresses dNP `off Internet Call Waiting r 90 -J 00 -1 d CA) to b t'7 c? } rv cao to r? W t? t 1 O E -n a 'Y y ,w yv rn A SHERIFF'S RETURN - REGULAR CASE NO: 2008-01801 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CAPITAL ONE BANK VS PRYOR CHRISTOPH J NOAH CLINE , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon PRYOR CHRISTOPH J the DEFENDANT at 1826 ANNA ST NEW CUMBERLAND, PA 17070-1205 ANITA PRYOR, MOTHER by handing to a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 16.32 Affidavit .00 Surcharge 10.00 41631 Dr 4- 00 44.32 Sworn and Subscibed to before me this day of , at 1315:00 HOURS, on the 31st day of March , 2008 So Answers: +y? c 66? R. Thomas Kline 04/01/2008 APOTHAKER & ASSOCIATES By: Deputy Sheriff A. D. Our File No.: 150135 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker Attorney I.D.# 38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 CAPITAL ONE BANK Plaintiff, vs. CHRISTOPH J PRYOR Defendant. TO THE PROTHONOTARY: Attorney for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-1801 Civil Action PRAECIPE FOR DEFAULT JUDGMENT Kindly enter judgment against Defendant, CHRISTOPH J PRYOR, in the default of an Answer, in the amount of $2,119.79 computed as follows: Amount claimed in complaint: $2,030.63 Amount Paid: - $(0.00) Interest from February 29, 2008 to 06/18/09 at the legal interest rate of 6.000 per annum $89.16 Costs $0.00 Attorney fees $0.00 TOTAL $2,119.79 I hereby certify that the appropriate Notices of Default, as attached have been mailed in accordance with Pa.R.Civ.P. 237.1 on the dates indicated on the Notices. I certify Defendant, CHRISTOPH J PRYOR, last know address is 1826 ANNA ST NEW CUMBERLAND, PA 17070-1205. APOTHAKER & Attorneys A Law Firm Enaae By: kTES, P.C. bt Collection pothaker Dated: 6/18/2009 Our File No.: 150135 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 CAPITAL ONE BANK COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff, vs. NO.: 08-1801 CHRISTOPH J PRYOR Defendant. Civil Action AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS. David J. Apothaker, being duly sworn according to law, deposes and says that I Plaintiff, and authorized to make this affidavit; that Defendant(s) resides at 1826 CUMBERLAND, PA 17070-1205. We inquired with the web site of the Defense Manpower Data Center, Boulevard, Suite 400, Arlington, VA 22209-2593, if the Defe ,;ftVit(s) is/are in any Mary M. Snavely-Dixon, Director of the Defense indicated that the Defendant(s) is/are not in the military. j David J. Ap?thaker Attorney for Plaintiff Center has sent The above signed understands that the statements herein are made subject to the Section 4904 relating to unsworn falsification to authorities. m the attorney for ANNA ST NEW i at 1600 Wilson of the military. our inquiry ties of 18 Pa. C.S. Department of Defense Manpower Data Center Mary Status Report Pursuant to the Senicemembcrs CivA Relief Act <, Last First/Middle Begin Date Itie PI YOR Active Duty Status CURISTOPH 3 Based on the information you have furnished, the DMDC does not pos indicating that the individual is currently on active duty Upon searching the information databanks of the Department of Defense Manpower Data Center, biased you prcmdede the above is the current status of the m&uh al as to all branches of the'?atar y, y6t fit. Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 160101 Wilson Bh-ct_ Slate 444 Arlington. VA 222019-2593 The Defense Manpower Data Center (D' IDC) is an organization of the Department of Defense that Enrollment and Eligrihty Reporting System (DEERS) database which is the official source of data on care and other el gib it} systems. The Department of Defense strongly snrppvrts the enforcement of the Senicemembers Civil Relief Act [50' et seq] (SCRA) (formerly the Soldiers' and Sailors' Civil Relief Act of 1940)). D14DC has issued hundreds not possess any information indicating that the individual is currently on active dirty" responses, and has exp rate- In the event the indnidual referenced above- or any fam9y member: fi end or representative asserts in individual is on active duty, or is otherwise entitled to the protections of the SCRA_ you are strongly encour verification of the person's active dirty status by contacting that person"s ??. Service via the "defenselinl below. If you have evidence the person is on active-duty and you fart to obtain this additional Nlkary Servi provisions of the SCRA may be invoked against you- If you obtain firmer information about the person ( e_g., an SSI?, improved accuracy of DOB, a middle your request again at this'keb site and we sn? provide a nenv certificate for that query. This response reflects current active duty status only, For historical information, please contact the NbItary S of-contact.. See: blip:.' 'v.?n-"•.del'ensebik,mra,fa is-PC019SLDR,htmI W.--NI `G; This certificate was provided based on a name and Social Security number (SSA) provided Providing an erroneous name or SSN .N-M cause an erroneous certificate to be provided. .lc -15-2401910:47.53 it Service I hkgency ieSS 4m, information the information that the Defense for military medical ;CS Appx_ §§ 5011 thousands of "does :iced a small error y manner that the ed to obtain further E LRL provided verification- you can submit SCRA points- the requester. .P?s rt ID BZGFF T 4)DH 150135 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY CAPITAL ONE BANK } COURT OF COMMON CUMBERLAND COUN vs. ) CHRISTOPH J PRYOR ) NO. 08-1801 To: CHRISTOPH J PRYOR 1826 ANNA ST NEW CUMBERLAND, PA 17070-1205 NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAUL', Date of Notice: July 11, 2008 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORT AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, F YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE M BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FE . CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 DAD J. APOTHAKER, ESQUIRE APOTHAKER & ASSOCIATES, PC A Law Firm Engaged in Debt Collectio 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 (215) 634-8920 Attorney for Plaintiff Attorney ID #38423 SHERIFF'S RETURN - REGULAR r}, CASE NO: 2'008=01801 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CAPITAL ONE BANK A VS PRYOR CHRISTOPH J NOAH CLINE Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according t says, the within COMPLAINT & NOTICE was served upon PRYOR CHRISTOPH J the DEFENDANT , at 1315:00 HOURS, on the 31st day of March at 1826 ANNA ST NEW CUMBERLAND, PA 17070-1205 by handing to ANITA PRYOR, MOTHER a true and attested copy of COMPLAINT & NOTICE :Law, 2008 together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 16.32 .00 10.00 .00 So Answers: Sworn and Subscibed to before me this of 44.32 R. Thomas Kline 04/01/2008 APOTHAKER & ASSOCIATES By: day Deputy Sheriff A. D. F ' } _. av *I4.oc Pry AT -Y C1L? lay 789 ? aa?aoo t4o+,cA. Pa..lpcQ OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS TO: CHRISTOPH J PRYOR 1826 ANNA ST NEW CUMBERLAND, PA 17070-1205 CAPITAL ONE BANK Plaintiff, VS. CHRISTOPH J PRYOR Defendant. COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-1801 Civil Action NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that I 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 ARBITRA' 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 /s/ Gt,c,cS" 2. OK8 ?'Ia6lo?