The URL can be used to link to this page

Home My WebLink About08-5544Our File No.: 179899 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire, Esq. Attorney I.D.#38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff ALTANTIC CREDIT & FINANCE INC. ASSIGNEE FROM CAPITAL ONE c/o Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 Plaintiff, VS. ROBERT D NOUSIANEN 155 SALEM CHURCH RD 51 MECHANICSBURG, PA 17050 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: o2 - 66yy l'ivil Terlw+ 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 Our File No.: 179899 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire, Esq. Attorney I.D.#38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff ALTANTIC CREDIT & FINANCE INC. ASSIGNEE FROM CAPITAL ONE c/o Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 Plaintiff, VS. ROBERT D NOUSIANEN 155 SALEM CHURCH RD 51 MECHANICSBURG, PA 17050 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is ALTANTIC CREDIT & FINANCE INC. ASSIGNEE FROM CAPITAL ONE c/o Apothaker & Associates, P.C., 520 Fellowship Road C306, Mount Laurel, NJ 08054. 2. Defendant(s) is/are ROBERT D NOUSIANEN, an adult individual residing at 155 SALEM CHURCH RD 51 MECHANICSBURG, PA 17050. 3. Plaintiff, ALTANTIC CREDIT & FINANCE INC. ASSIGNEE FROM CAPITAL ONE, is the Assignee and Successor in Interest of Account #5903592619818848; and said account was issued to Defendant(s) by CAPITAL ONE BANK (USA), N.A., 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 $10,131.00. 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 $10,131.00 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOIT='R SOCIATES, P.C. Atto ey r Plaintiff A Law Firm E g j in Debt Collection BY: David J , Esquire Dated: 9/9/2008 Our File No.: 179899 VERIFICATION hereby states that I am ps -DJQf L P 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 unswom falsification to authorities. P1 ff DATE: ALTANTIC CREDIT & FINANCE INC. ASSIGNEE FROM CAPITAL ONE ROBERT D NOUSIANEN 155 SALEM CHURCH RD 51 MECHANICSBURG, PA 17050 STATEMENT OF ACCOUNT Debtor's Name: ROBERT D NOUSIANEN Account Number: 5903592619818848 Original Creditor: CAPITAL ONE BANK (USA), N.A. Balance Due: $10,131.00 Our File No.: 179899 EXHIBIT "A" 3 N 0 C C 7?J v' 0 F r::.'I "U f?7 Grl SHERIFF'S RETURN - REGULAR CASE NO: 2008-05544 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ALTANTIC CREDIT & FINANCE INC VS NOUSIANEN ROBERT D WILLIAM CLINE , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE NOUSIANEN ROBERT D was served upon the DEFENDANT , at 1842:00 HOURS, on the 24th day of September, 2008 at 155 SALEM CHURCH RD 51 MECHANICSBURG, PA 17050 by handing to KRISTISIA NOUSIANEN, DAUGHTER 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 Service Affidavit Surcharge ID IV????9V°^ 18.00 10.00 .00 10.00 .00 38.00 Sworn and Subscibed to before me this day So Answers: R. Thomas Kline 09/25/2008 APOTHAKER & ASSOCIATES By -G Deputy Sheriff of , A. D. Our File No.: 179899 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker Attorney I.D.# 38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 ALTANTIC CREDIT & FINANCE INC. ) ASSIGNEE FROM CAPITAL ONE ) Plaintiff, ) VS. ) ROBERT D NOUSIANEN ) Defendant. ) Attorney for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-5544 Civil Action PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment against Defendant, ROBERT D NOUSIANEN, in the default of an Answer, in the amount of $10,545.78 computed as follows: Amount claimed in complaint: $10,131.00 Amount Paid: - $(0.00) Interest from September 09, 2008 to 03/20/09 at the legal interest rate of 6.000 per annum $298.28 Attorney fees $0.00 TOTAL $10,429.28 I hereby certify that the appropriate Notices of Default, as attached have been mailed in accordance with Pa.R.Civ.P. 237.1 on the dates indicated on the Notices. I certify Defendant, ROBERT D NOUSIANEN, last know address is 155 SALEM CHURCH RD 51 MECHANICSBURG, PA 17050. APOTHAKER A Law Firm By: SOCIATES, P.C. - Plaintiff in Debt Collection Dated: 3/20/2009 } Our File No.: 179899 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker Attorney I.D.# 38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff ALTANTIC CREDIT & FINANCE INC. ASSIGNEE FROM CAPITAL ONE Plaintiff, vs. ROBERT D NOUSIANEN Defendant. Civil Action AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA . SS. COUNTY OF CUMBERLAND David J. Apothaker, being duly sworn according to law, deposes and says that I am the attorney for Plaintiff, and authorized to make this affidavit; that Defendant(s) resides at 155 SALEM CHURCH RD 51 MECHANICSBURG, PA 17050. We inquired with the web site of the Defense M wer Data Center, located at 1600 Wilson Boulevard, Suite 400, Arlington, VA 22209-2593, if the D t(s) is/are in any branch of the military. Mary M. Snavely-Dixon, Director of the Defens power Data Center has sent back our inquiry indicated that the Defendant(s) is/are not in the military David J. tpothaker Attorney Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-5544 The above signed understands that the statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Depwi ent ofDefenme Msopower Data Center MAR-20.200914.01,16 Massy Status Report Pwwrsma to the Servic era CWil RaWAct RORW D Bated on due information posy bavr$ fixvWmd, the MADC does not possess any ief'esunation indiceft that dwe M4WAW is currently on active duty. Upon sewchigg die i fins dion data banks of the Department ofDefmm Manpower Data Center, based on the infaanution that you provided, the above is the current status ofdwe individual as to all braoches of dwe Mikarg. )6t A. Mary M. Snavely-Diaoan, Director Department ofDefeme -Manpower Data Center 1600 n 8hd., Suite 400 A ptim. VA 22209-2"3 The Defense Manpower Data Center (DMDO is an orgufmitiim ofthe Department of De&we slant maintains the Defense Fsr6hni art and Di li y Reportag System (DEUS) dd"e wbith is the ofcW source of data on e*#Mq far Mary medical cast and Other ear "Items, The Department of Defrase stroo* suppmu the enforcement of &e Servicemembers CrA Rel efAct 150 USCS Apps. 501 et s q (SCRA) (formerly the Soldi*W and SsiilW CW R*WAct of 1 "O). MOC has issued hundreds of thouax* of 'does not possess toy i firmation 6dicaliq that the individual is cvffm ly on active duty' responses, and has aape ienced a and eaor rate. In the event the individual rebereoced above, or nay fim illy member, 6ienel„ or rgxeseotstive asserts in my mummer that tlwe iAw; nil is on active ,duty, or it odmvvise entided to the parotectians ofthe SCRA, you are strongly encouraged to obtain 6ardwer° vailicati oa oftlre persoow s active duty stakws by esters p ersoes Mi'itaty Service via tlte'def ns**mil DRL provided below, Ifyou have evidence the pason is on active-duty and you fiwd to obtain this additional Military Service v wificatim provisions of the SCRA may be invoked against you. If you obtain t3xdw Ewa abau *e person (e-g, an SSN, improved semacy o=t a middle nm wX you can s tv* your request again at this Web its and we wdl provide a new certificate for that orrery, This response reflects twat active duty status only. For historical infwmatiam, please concoct the I tart' Service SCRA points- of-conkwwet. See: huplAwm.def=elink,mK&dyi&TC09SI,T)R.hamt WARNW4 This certificate was provided based on a roans and Social Security number (S provWd by the tawqua r. Providmg an wonem awn or SSN will case an etromous certificate to be provided. lUPMI M.- SHERIFF'S RETURN REGULAR CASE NO: 2008-05544 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND 'l ; ALTANTIC CREDIT & FINANCE INC Qy tJ `` ?I VS j' NOUSIANEN ROBERT D WILLIAM CLINE , Sheriff or Deputy Sheriff of Cumberland Caunty,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon NOUSIANEN ROBERT D the DEFENDANT , at 1842:00 HOURS, on the 24th day of September, 2006 at 255 SALEM CHURCH RD 51 MECHANICSBURG, PA 17050 by handing to KRISTISIA NOUSIANEN, DAUGHTER 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: So Answers: Docketing 18.00 Service 10.00 .? Affidavit ,00 Surcharge 10.00 R. Thomas Kline .00 38.00 09/25/2008 APOTHAKER & ASSOCIATES Sworn and Subscibed to By: before me this day Deputy Sheriff of A.D. 179899, OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY ALTANTIC CREDIT & FINANCE INC. ASSIGNEE ) COURT OF COMMON PLEAS FROM CAPITAL ONE ) CUMBERLAND COUNTY vs. ) NO. 08-5544 ROBERT D NOUSIANEN ) To: ROBERT D NOUSIANEN 155 SALEM CHURCH RD 51 MECHANICSBURG, PA 17050 NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT Date of Notice: October 27, 2008 IMPORTANT NOTICE YOU ARE I11)EF'AULT 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 YOUJR 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 isl DAVID J. APOTHAKER, 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 40 k , D e OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS TO: ROBERT D NOUSIANEN 155 SALEM CHURCH RD 51 MECHANICSBURG, PA 17050 ALTANTIC CREDIT & FINANCE INC. ASSIGNEE FROM CAPITAL ONE Plaintiff, VS. ROBERT D NOUSIANEN Defendant. COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-5544 Civil Action 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. Anothaker, Esq. at this telephone number: 215-634-8920