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Home My WebLink About08-6201Our File No.: 185295 APOTHAKER & ASSOCIATES, P.C. AY: David J. Apothaker, Esquire, Esq. Attorney I.D.#38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff FIA CARD SERVICES A/K/A BANK OF AMERICA c/o Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 Plaintiff, vs. KENNETH P URSIN 5020 MENDENHALL DR MECHANICSBURG, PA 17050-8355 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 08 - (oaD1 Civi 1 I?1'M 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 Pile No.: 185295 APOTHAKER & ASSOCIATES, P.C. ]?Y: David J. Apothaker, Esquire, Esq. Attorney I.D.#38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff FIA CARD SERVICES A/K/A BANK OF AMERICA c/o Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 Plaintiff, vs. KENNETH P URSIN 5020 MENDENHALL DR MECHANICSBURG, PA 17050-8355 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: o F. & ° -o / G yd' I -Wf--V CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is FIA CARD SERVICES A/K/A BANK OF AMERICA c/o Apothaker & Associates, P.C., 520 Fellowship Road C306, Mount Laurel, NJ 08054. 2. Defendant(s) is/are KENNETH P URSIN, an adult individual residing at 5020 MENDENHALL DR MECHANICSBURG, PA 17050-8355. 3. At the special instance and request of Defendant, Plaintiff, FIA CARD SERVICES A/K/A BANK OF AMERICA, issued to Defendant(s), Account #4888937999088943. 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 $18,234.59. 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 $18,234.59 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHI= A SOCIATES, P.C. Atto Tey fo Plaintiff A Law Firm E gage in De ollectio BY: Dated: 10/9/2008 David J. Apothaker, Esquire Our File No.: 185295 r w VERIFICATION David J ARothaker. Esquire, Esa. 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, The undersigned understands that the statements therein are made subject to the penalties of 18 Pa.C.S relating to unworn falsification to authorities. David J. A?othaker, Esquire Attorney for Plaintiff DATE: 10/9/2008 FIA CARD SERVICES A/K/A BANK OF AMERICA KENNETH P URSIN 5020 MENDENHALL DR MECHANICSBURG, PA 17050-8355 STATEMENT OF ACCOUNT Debtor's Name: KENNETH P URSIN Account Number: 4888937999088943 Balance Due: $18,234.59 Our File No.: 185295 EXHIBIT "A" a cca Ri 1 p O err, A o ..D /p r L - (?f1 +r 00 Z`j A. - s ° L. a T-n ? ? D K ^ SHERIFF'S RETURN - REGULAR CASE NO: 2008-06201 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FIA CARD SERVICES ET AL VS URSIN KENNETH P MICHAEL BARRICK Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE URSIN KENNETH P was served upon DEFENDANT the at 0009:46 HOURS, on the 28th day of October , 2008 at 5020 MENDENHALL DR MECHANICSBURG, PA 17050 ADRIAN URSIN by handing to WIFE OF DEFENDANT 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 101301, 18.00 12.00 .00 10.00 .00 40.00 Sworn and Subscibed to before me this day So Answers: R. Thomas Kline 10/29/2008 .?? APOTHAKER & ASSO A ES r' By: eput Sheriff of A. D. Our File No.: 185295 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker Attorney I.D.# 38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 FIA CARD SERVICES A/K/A BANK OF AMERICA Plaintiff, VS. KENNETH P URSIN Defendant. Attorney for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-6201 Civil Action PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment against Defendant, KENNETH P URSIN, in the default of an Answer, in the amount of $18,234.59 computed as follows: Amount claimed in complaint: $18,234.59 Amount Paid: - $(0.00) Interest from October 09, 2008 to 05/14/09 at the legal interest rate of 0.000 per annum $0.00 Costs $0.00 Attorney fees $0.00 TOTAL $18,234.59 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, KENNETH P URSIN, last know address is 5020 MENDENHALL DR MECHANICSBURG, PA 17050-8355. TES, P.C. A Law Firm Uneaded in Dubt Collection By: J. Apothaker Dated: 5/14/2009 . II . Our File No.: 185295 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 FIA CARD SERVICES A/K/A BANK OF AMERICA Plaintiff, VS. KENNETH P URSIN Defendant. Civil Action AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-6201 : 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 5020 MENDENHALL DR MECHANICSBURG, PA 17050-8355. We inquired with the web site of the Defense Boulevard, Suite 400, Arlington, VA 22209-2593, if thV Mary M. Snavely-Dixon, Director of the De indicated that the Defendant(s) is/are not in the mili David J. Any Attorney for r Data Center, located at 1600 Wilson s) is/are in any branch of the military. 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. TDeparM mt d-Defense Manpower Data Center 11+lbmy Status Rapod Parsom to the: St vict xis Civil Re WAct MAY-14-200910.0945 URSIN KENNETH P *se d on dire zfiznmbm yen have izoiahed, the DMDC does ant p assess any nf`aemadon i &x&g, that, the iu+c i&W is cu?ready an active duty. Upon searching the isb mudan darn barks of the Department of Defense anpower Dam Caster, based an the iakm atim that you provided, the abe we is the current status afa ion as to at branches of the; teary. OwtA L.,.j- 11 rw?A?W- Mara' M. Sir Duran, Direwcka Department c(Defanse - Mmpower Data Center 1500 Wlsoo Blvd.; Sake 400 Magoon, VA 22209-2593 Mw DaE'earse Maapo weer Data Centex OAMM is an.Orgooko w of thee Departmesrt o(Defame the maintains d w Define Eft and WAOx y Rqwriing System (DEERS) database which is the officiol source of daft an dig+'lnl`ty for aaitwy me&ol cam and Other dimity systems. The Deportment of Dew sti r supports the a nfixt ement of the S P, - ietmeaabers Civil Relief Act [30 USCS Appx. f § 501 et sexy (SCRA) 0=* the Ste' and Sailars' Cid Rtli (Act of 194. DMDC has issued weds d6wsands of-does not possess myi &zmatim ind`icating' dot the iruwidaal ig car a* an act im 4W rem and has experienced a smo& trim mate. Ia the event the irmivided rued above, or any fimly meumber,1iiend, or representative asserts in any maauer that the indlWdoal is on active duty, at is otherwise end to the protections of the SCRA, you are swan* encouraged to obtain farther ved&mdm ofthe person's naive duty' stars by contacting that p ms&s lorry Service via the "defmsellot nsi" URL provided below. Nyou have ev deoce the person is an active-daty and you f d to obtain this addWon l Mlwy Service vaffcdim% provisions af'the SCRA may be invoked age you. if you vbtainftdierr about the person (e.g., an SSN. nnpaavcd wxurwy of DOB. a middle name), you can wit Dour request agoin at this Web site and we wR provide a new t cafe hr that 9w'y. Ik,s reRxwe reds current active duty stag only. For bisi<r" iron, please cooted the: Witary Service SCRA poents- of-+cootu t. Sex: btt>xl www m mii&TC09SLDR-htmt WAR]f' N& Tlis cep' rcate was provided based on a nome and Saes Shy r zAw (SSN) prwA&d by the rem. Proviellrrg an erroneous now or SSN wgl came an enrone= vertlicaft to be provided. Ras *n DD FFRORt~i'aCXW 185295 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY FIA CARD SERVICES A/K/A BANK OF ) COURT OF COMMON PLEAS AMERICA ) CUMBERLAND COUNTY VS. ) NO. 08-6201 KENNETH P URSIN ) To: KENNETH P URSIN 5020 MENDENHALL DR MECHANICSBURG, PA 17050-8355 NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT Date of Notice: December 03, 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 ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 BAR DAVID J R & 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 \k\ .OTHAKER, ESQUIRE APO HAKE 50-?-g CASE NO: 2008-06201 P SHERIFF'S RETURN - REGULAR COMMONWEALTH'OF PENNSYLVANIA: COUNTY OF CUMBERLAND FIA CARD SERVICES ET AL VS URSIN KENNETH P f{+??i,'.+, 7 NOV 11 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 URSIN KENNETH P the DEFENDANT at 0009:46 HOURS,.on the 28th day of October , 2008 at 5020 MENDENHALL DR MECHANICSBURG, PA 17050 by handing to ADRIAN URSIN WIFE OF DEFENDANT 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 12.00 Affidavit .00 Surcharge 10.00 .00 40.00 Sworn and Subscbed to before me this day So Answers: R. Thomas Kline 10/29/2008 - `? APOTHAKER: & ASSO A ES By: - eput Sheriff of A. D. n i H 2009 [I Y '2 0 ilk i 4 9 *if+ coo Po ""I ewe 13414q ., 'JAG S, OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS TO: KENNETH P URSIN 5020 MENDENHALL DR MECHANICSBURG, PA 17050-8355 FIA CARD SERVICES A/K/A BANK OF AMERICA Plaintiff, VS. KENNETH P URSIN Defendant. NOTICE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-6201 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, Esq at this telephone number: 215-634-8920 .3/a%9