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Home My WebLink About08-7177 Our File No.: 188900 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 ATLANTIC CREDIT & FINANCE, INC c/o Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 Plaintiff, VS. DAVID J MOORE 244 MEALS DR CARLISLE, PA 17015-3183 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY ?- -- No.: 08 -- ''1111 j (1t U L C(?11J'rl NOTICE You have been sued in court. If you wish t within twenty (20) days after this complaint and nc filing in writing with the court your defenses or objet the case may proceed without you and a judgment claimed in the complaint or for any other claim or n important to you. YOU SHOULD TAKE THIS PAPER TO CANNOT AFFORD ONE, GO TO OR TELEPHO7 GET LEGAL HELP. IF YOU CANNOT AFFORD TO HIRE INFORMATION ABOUT AGENCIES THAT MAY OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 defend against the claims set forth in the following pages, you must take action ce are served, by entering a written appearance personally or by attorney and ions to the claims set forth against you. You are warned that if you fail to do so iay be entered against you by the court without further notice for any money ief requested by the plaintiff. You may lose money or property or other rights )UR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH FFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE s ~ Our File No.: 188900 APO'LHAKER & 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 ATLANTIC CREDIT & FINANCE, INC. c/o Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 Plaintiff, vs. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: Of- DAVID urd??"' J MOORE 244 MEALS DR CARLISLE, PA 17015-3183 Defendant. 1. Plaintiff is ATLANTIC Fellowship Road C306, Mount Laurel, NJ ACTION COMPLAINT FIRST COUNT & FINANCE, INC. c/o Apothaker & Associates, P.C., 520 2. Defendant(s) is/are DAVID I J MOORE, an adult individual residing at 244 MEALS DR CARLISLE, PA 17015-3183. 3. Plaintiff, ATLANTIC CREDIT & FINANCE, INC., is the Assignee and Successor in Interest of Account #4791070000147999; and said account was issued to Defendant(s) by ASPIRE, the Original creditor. 4. Defendant received, accepted d used the account to its benefit. 5. This account is in default and efendant(s) has an unpaid balance of $6,330.37. A true and correct copy of the total due and owing is attached 6. All credits, if any, to which made a part hereof and marked as Exhibit "A". s) is entitled, have been applied to the account and are included in Exhibit "A". 7. Although demand has been 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 4 $6,330.37 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHIAKER & AS OCIATES, P.C. Attorney f laintiff A Law Firm Engag Nn Debt Collediioi BY: Esquire Dated: 11/25/2008 Our File No.: 188900 11, la to take this Verification, and 1 Complaint are true and correct to undersigned understands that the Pa.C.S.A. 4904 relating to unswo VERIFICATION hereby states that I am p_ for Plaintiff in this action, and that I am authorized t the statements made in the foregoing Civil Action he best of my knowledge, information, and belief. The atements therein are made subject to the penalties of 18 falsification to authorities. Ina i 0l1?7i? P1 DATE: ATLANTIC CREDIT & FINANCE, INC. DAVID J MOORE 244 MEALS DR CARLISLE, PA 17015-3183 STATEMENT OF ACCOUNT Debtor's Name: DAVID J Account Number 479107000014 Original Creditor: ASPIRE Balance Due: $6,330.37 Our File No.: 188900 EXHIBIT "A" 4a D 0 -V5 Cf T ?° . sT-i D N Q O Q rrl CJ i q SHERIFF'S RETURN - REGULAR CASE NO: 2008-07177 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ATLANTIC CREDIT & FINANCE INC VS MOORE DAVID J JASON VIORAL Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE MOORE DAVID J was served upon the DEFENDANT , at 0021:22 HOURS, on the 18th day of December-, 2008 at 244 MEALS DRIVE CARLISLE, PA 17015-3183 DAVID 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 Service Affidavit Surcharge /;Z/)q/or ?), 18.00 4.50 .00 10.00 .00 32.50 Sworn and Subscibed to before me this day of , So Answers: -R. homas Kline 12/19/2008 APOTHAKER & ASSOCIATES By. e ty Sheriff A.D. Our File No.: 188900 APOTHAKER & ASSOCIATES, P.C. Attorney for Plaintiff BY: David J. Apothaker Attorney I.D.# 38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 ATLANTIC CREDIT & FINANCE, INC. ) COURT OF COMMON PLEAS OF Plaintiff, ) CUMBERLAND COUNTY vs. DAVID J MOORE NO.: 08-7177 Civil Action PRAECIPE FOR DEFAULT JUDGMENT Defendant. TO THE PROTHONOTARY: Kindly enter judgment against Defendant, DAVID J MOORE, in the default of an Answer, in the amount of $6,685.23 computed as follows: Amount claimed in complaint: $ 6,330.37 Less: Amount Paid: ( 0.00) Plus: Interest from November 25, 2008 to August 12, 2009 at the legal 243.86 interest rate of 6.00% per annum Attorney fees 0.00 TOTAL $ 6,685.23 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, DAVID J MOORE, last known APOTHAKER & A is 244 MEALS DR CARLISLE, PA 17015-3183. .TES, P.C. A Law Firm Eng ged Debt By: David J. thakei Dated: August 12, 2009 Our File No.: 188900 10 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. VS. DAVID J MOORE Plaintiff, 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 244 MEALS DR CARLISLE, PA 17015-3183. 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 De indicated that the Defendant(s) is/are not in the mili COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-7177 David JA6,pothaker Attorney for Plaintiff 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 unworn falsification to authorities. APOTHAKER&ASSOCIATES9 P.C. ATTORNEYS AT LAW Department of Defense Manpower Data Center Alit-ls'.-2009 082.38 40 Military Status Report Pursuant to the Senicemembers Cif RefiefAct ?.Last Fir'st/?1iTiddie Begin Date Acth-e Duty Status Sersice/Age-acy MOORE DAVID J Based on the i6onuation,, ou have fisrrushed, the DNiDC does not possess auy information indicating that the individual is curr }y on actit°e duly. Upon searching the information data banks of the Department c(Defense Manpower Data Cerster, based on Ilse information that You Provided, the above is the curfew status of dX Vital as to al branches of &e Mbry4but ?j fi `f* *- ?VfaryNI. Snavely-Dixon, Director Department of Defense - Manpower Data Center 1600 Wilson Elvd__ Suite 400 Arlington VA 22209-2593 The Defense Manpower Data Center (Dz\IDC) is an orb of the Fmro lment and Ehgl* Reporting System (DEERS) database which is the official sours data oumailtains the Defense care and other *W systems. ebVb&tY for mt ar}' medical The Department of Defense strongly supports the enforcement of' the Saviceme bens Civa Re idAct [50 USCS Appx. §§ 501 et seq] (SCRA) (formerly the Scams' and Sailors 'Civil RefiefAct of 1 0)_ D.MDC has issued hundreds of &m sands of "does not possess any Jeformation nuicating that the individual is currersdy on active duty" responses rate. In the evesmt the individual referemcezl abon-e; or any , and has experienced a small error r?l is an active y family member, ? or representative asserts in any spanner that the may, or 1s wise entibed to the protections 'the SCRA; you are wom r encotuaged to obtain f rffier venfscation of the persoes active clay status by contacting that persoifs hi1itary Service via the 'below. If you have evidence the sefink..mg" I1R.I,, proved person is on active-duty and you fast to obtain this additional M try Service veri(icaben provisions of the SCRA may be invoked asgairsst you. If You Your request f€trther iaf about the person ( eg.; an SS ; i proved accuracy of DOB, a middle frame), you can submit again at this W eb site and we Ail provide a new cert&ate far that query, This response reflects current active duty status Only, For historical information, Please contact the Mkary Service SERA points- Seen httt)_-Hwv%1v_defermseli?c tz>t1 fin : PC09SLD htspl W AIt?vdNG: This certficate g as provided based on a name and Social Security number (SS Providing an erroneous name or SSN %v? cause an erroneous certifeate to be provided. N} provided by the requester. Re rtM-.BET,JAE,F 1889N OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY ATLANTIC CREDIT & FINANCE, INC. ) COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. ) DAVID J MOORE ) NO. 08-7177 To: DAVID J MOORE 244 MEALS DR CARLISLE, PA 17015-3183 NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT Date of Notice: January 19, 2009 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 DA D J. APOTHAKER, ESQUIRE APOTHAKER & ASSOCIATES, PC A Law Finn Engaged in Debt Collection 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff Attorney ID #38423 • PE i;?N - REGULAR SHERIFF' c?3 CASE NO: 2008-07177 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ATLANTIC CREDIT & FINANCE INC VS _ MOORE DAVID J JASON VIORAL Sheriff or. Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon MOORE DAVID J the DEFENDANT at 00121:22 HOURS, on the 18th day of December_, 2008 at 244 MEALS DRIVE CARLISLE,. PA 1-7015-3183 by handing to DAVID 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: So Answers: Docketing 18.00 Service .50 Affidavit .00 Surcharge 10.00 R. homas K_lne .00 32.50 12/19/2008 A.POTHAKER & ASSOCIATES Sworn and Subscibed to By: before me this day ty sheriff of 11. 1). )e_ r Tre ZOtl9 ??? 2d AM ?' ? ? A? 4%4.00 p o aa9 40 r ' OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS TO: DAVID J MOORE 244 MEALS DR CARLISLE, PA 17015-3183 ATLANTIC CREDIT & FINANCE, ) COURT OF COMMON PLEAS OF INC. ) CUMBERLAND COUNTY Plaintiff, ) vs. ) NO.: 08-7177 DAVID J MOORE ) Civil Action Defendant. 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. Apothaker, Esq. at this telephone number: 215-634-8920 S/a%9 2191491 The Law Offices of Frederic I Weinberg & Associates, P.C. BY: Frederic I. Weinberg, Esquire Identification No.: 41360 Joel M. Flink, Esquire Identification No.: 41200 375 E. Elm Street, Suite 210 Conshohocken, PA 19428 484/351-0500 to l� ATLANTIC CREDIT & FINANCE INC COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. DAVID MOORE DOCKET NO. : 2008-07177 ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter my appearance on behalf of the plaintiff in the above -captioned matter. The Law Offices o Frederic I. Weinberg & Associates, P BY: P012 Frederi I einberg, Esquire Joel M. Flink, Esquire Attorney for Plaintiff CERTIFICATION OF SERVICE I, FREDERIC I. WEINBERG, ESQUIRE, hereby certify that I, on the date below, served a copy of the Substitution of Attorney and Entry of Appearance Pursuant to Pa.R.C.P. 1028(c)(1), via First Class Mail, postage pre -paid, to all other parties or their counsel of record. FREDERIC I. WEINBERG, ESQUIRE Dated: (14