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Home My WebLink About08-4830Our File No.: 169613 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire Attorney I.D.#38423 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 (215) 634-8920 Attorneys for Plaintiff ATLANTIC CREDIT & FINANCE INC ASSIGNEE FROM HSBC c/o Apothaker & Associates, P.C. 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 Plaintiff, VS. MICHAEL KRAYBILL 242 BOSLER AVE APT 1 LEMOVNE, PA 17043-2028 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY er' NO.: CIO. LC-a 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 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire Attorney I.D.# 38423 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 (215) 634-8920 Attorneys for Plaintiff ATLANTIC CREDIT & FINANCE INC. ASSIGNEE FROM HSBC c/o Apothaker & Associates, P.C. 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 Plaintiff, VS. MICHAEL KRAYBILL 242 BOSLER AVE APT 1 LEMOVNE, PA 17043-2028 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is ATLANTIC CREDIT & FINANCE INC. ASSIGNEE FROM HSBC c/o Apothaker & Associates, P.C., 2417 Welsh Road, Suite 21 #520, Philadelphia, PA 19114. 2. Defendant(s) is/are MICHAEL KRAYBILL, an adult individual residing at 242 BOSLER AVE APT 1 LEMOVNE, PA 17043-2028. 3. Plaintiff, ATLANTIC CREDIT & FINANCE INC. ASSIGNEE FROM HSBC, is the Assignee and Successor in Interest of Account #5467020004211630; and said account was issued to Defendant(s) by HSBC, the Original creditor. 4. Defendant received, accepted and used the account to its benefit. 5. This account is in default and Defendant(s) has an unpaid balance of $5,929.72. A true and correct copy of the total due and owing is attached hereto, made a part hereof and marked as Exhibit "A". 6. All credits, if any, to which Defendant(s) is entitled, have been applied to the account and are included in Exhibit "A". 7. Although demand has been made, Defendant(s) 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 $5,929.72 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER & ZAI O I TES, P.C. Attorney tiff A Law Firm Enea Znebt Collection BY: David J. Ap4&6r, Esquire Dated: 8/4/2008 Our File No.: 169613 VERIFICATION ca"P.Snu 0. 6 nu hereby states that I am ? SC3 DJO } Ve 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. Cam= Pl ff DATE: ATLANTIC CREDIT & FINANCE INC. ASSIGNEE FROM HSBC MICHAEL KRAYBILL 242 BOSLER AVE APT 1 LEMOVNE, PA 17043-2028 STATEMENT OF ACCOUNT Debtor's Name: MICHAEL KRAYBILL Account Number: 5467020004211630 Original Creditor: HSBC Balance Due: $5,929.72 Our File No.: 169613 EXHIBIT "A" 6 ti 4 0 Frill ri' 1 ,li C= c CaJ N N -n ?F= 'C rn (00 SHERIFF'S RETURN - REGULAR CASE NO: 2008-04830 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ATLANTIAC CREDIT & FINANCE INC VS KRAYBILL MICHAEL MARK CONKLIN , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, r - lA )j S1 , of says, the within CRL COMPLAINT was served upon KRAYBILL MICHAEL the DEFENDANT at 2024:00 HOURS, on the 4th day of September, 2008 at 242 BOSLER AVENUE APT 1 LEMOYNE, PA 17043-2028 MICHAEL KRAYBILL by handing to a true and attested copy of CRIMINAL COMPLAINT together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 16.00 Affidavit .00 Surcharge 10.00 .00 44.00 Sworn and Subscibed to before me this day of , So Answers: R. Thomas Kline 09/05/2008 APOTHAKER & ASSOCIAT By: De uty Offherif A. D. .riWWi •.r+i11 A Our File No.: 169613 APOTHAKER & ASSOCIATES, P.C. BY. David J. Apothaker Attorney I.D.# 38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 ATLANTIC CREDIT & FINANCE INC. ASSIGNEE FROM HSBC Plaintiff, VS. MICHAEL KRAYBILL Defendant. Attorney for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-4830 Civil Action PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment against Defendant, MICHAEL KRAYBILL, in the default of an Answer, in the amount of $6,263.69 computed as follows: Amount claimed in complaint: $5,929.72 Amount Paid: - $(0.00) Interest from August 04, 2008 to 03/20/09 at the legal interest rate of 6.000 per annum $211.47 Attorney fees $0.00 TOTAL $6,141.19 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, MICHAEL KRAYBILL, last know address is 242 BOSLER AVE APT I LEMOVNE, PA 17043-2028. APOTHAKER &/ASSOCIATES, P.C. A Law Firm By: Dated: 3/20/2009 Our File No.: 169613 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 ATLANTIC CREDIT & FINANCE ) INC. ASSIGNEE FROM HSBC } Plaintiff, } vs. ) MICHAEL KRAYBILL ) Defendant. } COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-4830 Civil Action AFFIDAVIT OF NON-AHLITARY 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 242 BOSLER AVE APT 1 LEMOVNE, PA 17043-2028. We inquired with the web site of the Defense Boulevard, Suite 400, Arlington, VA 22209-2593, if the Mary M. Snavely-Dixon, Director of the indicated that the Defendant(s) is/are not in the i David J. Attorney 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 unworn falsification to authorities. Deparkamt ofDefaase MsrtpowerDstta Cater -201-20091159:07 MIANY 10 PwsuwA States Ptagort to tlu Sbels Ra?iCf Apt A%vt * A%+",,. May M Sww* Dwon, Directw Department ofDeCamse - Mawpowa Data Center 1604 Wil onTAvd, Same 400 Arlanton, VA 22209-2593 The Deform Mawavaer Data Comer (DU is an ogpnizi ion of *& Depa time ofDefime Wit umicbm *e Ddkme tar t and Eh*Wty Repaug Syst= (DEEPS) damabase valdch is the afcsal amttrte of data on a ty for nvTfty medical care and ether elob ty sy stems. The 15epart dDefmsa strong uffarts the tokme meat oflhe Sa ikemembers C Re efAet (50 nCS Appnt. ff 541 et serf] (SC OosmaiY 6e Sd&ms' and Swots' QvA R."Act of 1940). 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For Kistim <al amnakic, pleve contact the Wit ary Service SCRA poimts- comet Sea; WAl G: Tlrs came wm prod basad on a now and Socw Security uxuber (SM provided by the "wester, Providing an acraar o us or SST wit cause an eenoneous certiB mk to be providet reports mm m merav Upon sembos the "fiftaskaA dean bwks ofdw Dept of Damm Manlroww Data Centm bared on the *AaamOon dut yin provided, dw above is dK cmat s s ofdm individual as to A bdemm ws otdie Ma7itary. SHERIFF'S RETURN REGULAR 0.?CASE NO: 2008-04830 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ATLANTIAC CREDIT & FINANCE INC VS KRAYBILL MICHAEL ?; sEP 17 200e l I MARK CONKLIN , Sheriff or Deputy Sheriff of Cumberland County,Pennsyl'vania, who being duly sworn according to law, says, the within CRIMINAL COMPLAINT was served upon KRAYBILL MICHAEL the DEFENDANT at 2024:00 HOURS, on the 4th day of September, 2008 at 242 BOSLER AVENUE APT 2 LEMOYNE, PA 17043-2028 by handing to MICHAEL KRAYBILL a true and attested copy of CRIMINAL COMPLAINT together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 18.00 Affidavit .00 Surcharge 10.00 .00 44.00 Sworn and Subscibed to before me this day of , So Answers: R. Thomas Kline 09/05/2008 APOTHAKER & ASSOCIAT By: De uty heriff A. D. 169613 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY ATLANTIC CREDIT & FINANCE INC. ASSIGNEE ) COURT OF COMMON PLEAS FROM HSBC ) CUMBERLAND COUNTY VS. ) NO. 08-4830 MICHAEL KRAYBILL ) To: MICHAEL KRAYBILL 242 BOSLER AVE APT 1 LEMOVNE, PA 17043-2028 NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT Date of Notice: October 07, 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 DEFE14SES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAYBE EXTERED 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 ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 BAR Ig I DAVID J. AtPOTHAKER, ESQUIRE APOTHAKER & ASSOCIATES, PC A Law Firm Engaged in Debt Collection 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff Attorney ID #38423 00 "'__ F\1 4 r TO: MICHAEL KRAYBILL 242 BOSLER AVE APT I LEMOVNE, PA 17043-2028 ATLANTIC CREDIT & FINANCE INC. ASSIGNEE FROM HSBC Plaintiff, VS. MICHAEL KRAYBILL Defendant. NOTICE OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-4830 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 j 1 4 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, Esq. at this telephone number: 215-634-8920 WELTMAN, WEINBERG & REIS CO., L.P.A. BY: William T. Molczan I.D. No. 47437 436 Seventh Avenue, 1400 Koppers Bldg Pittsburgh, PA 15219 Phone: 412.434.7955 Fax: 412.434.7959 File # 9412121 r?ILWCa-€i F'tCL F THE PR TNONOTAF , 2012 FEB -3 Ali 11:35 Attorney for P tiff s) i AB?RLANO COUNTY PENNSYLVANIA ATLANTIC CREDIT & FINANCE INC. ASSIGNEE FROM HSBC Plaintiff vs. CUMBERLAND County Court of Common Pleas No.: 08-4830 MICHAEL KRAYBILL Defendant(s) PRAECIPE FOR APPEARANCE TO THE PROTHONOTARY: Kindly enter our appearance on behalf of the Plaintiff in the above captioned matter. WELTMAN, WEINBERG & REIS CO., L.P.A. By William T. Mol an Attorney for Plaintiff