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Home My WebLink About08-2748 Out?File No.: 155441 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 PROFESSIONAL INVESTMENT AND FINANCES LLC c/o Apothaker & Associates, P.C. 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 Plaintiff, vs. JAMES A MOORE 138 W CHURCH AVE CARLISLE, PA 17013-3203 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: D$ - 0174 8 NOTICE C i Vi < <P-r M 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 cone. 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 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 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 PROFESSIONAL INVESTMENT AND FINANCES LLC c/o Apothaker & Associates, P.C. 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 Plaintiff, vs. JAMES A MOORE 138 W CHURCH AVE CARLISLE, PA 17013-3203 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 08- .7 7VP Ctuc1 7P,- CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff, PROFESSIONAL INVESTMENT AND FINANCES 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 JAMES A MOORE, an adult individual residing at 138 W CHURCH AVE CARLISLE, PA 17013-3203. 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 $3,626.96. ' 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 $3,626.96 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER Attorn A Law Firm Ed BY: Dated: 4/10/2008 David J: SOCIATES, P.C. Plaintiff in Debt Collection Our File No.: 155441 VERIFICATION David J. Apothaker, Esq hereby states that I am counsel for plaintiff in this action, and that I am authorized to take this Verification, and that the statements made in the foregoing Civil Action Complaint are true and correct to the best of my knowledge, information, and belief. The undersigned understands that the statements therein are made subject to the penalties of 18 Pa.C.S.A. 4904 relating to up$worn falsification to authorities. David J. Attorney for Plaintiff DATE: 4/10/2008 t .? PROFESSIONAL INVESTMENT AND FINANCES LLC c/o Apothaker & Associates, P.C. 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 JAMES A MOORE 138 W CHURCH AVE CARLISLE, PA 17013-3203 STATEMENT OF ACCOUNT Debtor's Name: JAMES A MOORE Account Number: 5179457320184340 Original Creditor: CHASE MANHATTAN BANK Balance Due: $3,626.96 Our File No.: 155441 EXHIBIT "A" "EIP- 00 00 f- 0? (n M cz) n 01 00 V 00 00 po :u? f j SHERIFF'S RETURN - REGULAR CASE NO: 2008-02748 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PROFESSIONAL!,INVESTMENT AND VS MOORE JAMES MICHAEL BARRICK , Sheriff or Deputy Sheriff of Cumberland C unty,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon Mnni?' .7aMPq n the DEFENDANT , at 0019:25 HOURS, on the 2nd day of May , 2008 at 138 W CHURCH AVENUE CARLISLE, PA 17013 JAMES MOORE DEFENDANT 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 5.00 Affidavit .00 Surcharge 10.00 yb t/a P? .00 33.00 Sworn and ubscibed to before me his of day So Answers: R. Thomas Kline 05/05/2008 APOTHAKER & A;]&:?Zll?f- ,/-4!f?6puty By: S ri f A. D. Our File No.: 155441 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker Attorney I.D.# 38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 PROFESSIONAL INVESTMENT AND FINANCES LLC Plaintiff, VS. JAMES A MOORE Defendant. Attorney for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-2748 Civil Action PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment against Defendant, JAMES A MOORE, in the default of an Answer, in the amount of $3,891.32 computed as follows: Amount claimed in complaint: $3,626.96 Amount Paid: - $(0.00) Interest from April 10, 2008 to 2/18/2009 at the legal interest rate of 6.000 per annum $152.86 Costs $111.50 Attorney fees $0.00 TOTAL $3,891.32 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 that Plaintiff's address as PROFESSIONAL INVESTMENT AND FINANCES LLC c/o Apothaker & Associates, P.C. 520 Fellowship Road C 306, Mount Laurel, NJ 08054 and that Defendant, JAMES A MOORE, last know address is 138 W CHURCH AVE CARLISLE, PA 17013-3203. APOTHAKER P.C. Attorn s f Plaintiff A Law Firm En ag in Debt Collection By: David J. Apothaker Dated: 2/18/2009 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS TO: JAMES A MOORE 138 W CHURCH AVE CARLISLE, PA 17013-3203 PROFESSIONAL INVESTMENT AND FINANCES LLC Plaintiff, vs. JAMES A MOORE Defendant. NOTICE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-2748 Civil Action 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, EN. at this telephone number: 215-634-8920 Our File No.: 155441 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 PROFESSIONAL INVESTMENT AND FINANCES LLC COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff, VS. JAMES A MOORE NO.: 08-2748 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 am the attorney for Plaintiff, and authorized to make this affidavit; that Defendant(s) resides at 138 W CHURCH AVE CARLISLE, PA 17013-3203. We inquired with the web site of the D, Boulevard, Suite 400, Arlington, VA 22209-259 Mary M. Snavely-Dixon, Director of th indicated that the Defendant(s) is/are not in the Attorney for Plaintiff r Data Center, located at 1600 Wilson s) is/are in any branch of the military. Data Center has sent back our inquiry 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 ID Military Status Report Pursuant to the Servicemembers Civil Relief Act Pagel of 2 FEB-18-2009 06:22:05 < Last Name First/Middle Begin Date Active Duty Status Service/Agency MOORE JAMES A 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. A0 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.htrnl WARNING: This certificate was provided based on a name and Social Security number (SSN) provided https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 2/18/2009 1'55441 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY PROFESSIONAL INVESTMENT AND FINANCES ) COURT OF COMMON PLEAS LLC ) CUMBERLAND COUNTY VS. ) NO. 08-2748 JAMES A MOORE } To: JAMES A MOORE 138 W CHURCH AVE CARLISLE, PA 17013-3203 NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT Date of Notice: June 4, 2008 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 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, IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. 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 Lawyer Referral and Information Service 800-990-9108 _/s/ David J. Apothaker DAVID J. APOTHAKER, ESQUIRE APOTHAKER & ASSOCIATES, PC 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 NO: 2008-02748 P bC COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PROFESSIONAL INVESTMENT AND VS MOORE JAMES A 'I MICHAEL BARRICK , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon MOORE JAMES A the DEFENDANT at 0019:25 HOURS, on the 2nd day of May , 2008 at 138 W CHURCH AVENUE CARLISLE, PA 17013 by handing to JAMES MOORE DEFENDANT 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 5.00 Affidavit .00 Surcharge 10.00 .00 33.00 Sworn and Subscibed to before me this day So Answers: R.. Thomas Kline 05/05/2008 APOTHAKER & ASSOCI r- By : ePuty S f Fe ri-f of A. D. « Cu C.'a t +t , ?} r