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HomeMy WebLinkAbout09-2395a Our File No.: 204268 . 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 FIA CARD SERVICES, N.A. c/o Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 Plaintiff, vs. FRED W ZEPLIN 15 CUMBERLAND RD LEMOYNE, PA 17043-1616 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: (A - ot2A5 alv; l le'r V'4 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.: 204268 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 FIA CARD SERVICES, N.A. c/o Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 Plaintiff, VS. FRED W ZEPLIN 15 CUMBERLAND RD LEMOYNE, PA 17043-1616 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: O 4- 2 3 95 e,,.,( T.- CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is FIA CARD SERVICES, N.A. c/o Apothaker & Associates, P.C., 520 Fellowship Road C306, Mount Laurel, NJ 08054. 2. Defendant(s) is/are FRED W ZEPLIN, an adult individual residing at 15 CUMBERLAND RD LEMOYNE, PA 17043-1616. 3. At the special instance and request of Defendant, Plaintiff, FIA CARD SERVICES, N.A., issued to Defendant(s), Account #4888931996183989. 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 $16,881.84. 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 A WHERFF©RE; Plaintiff demands judgment in favor of Plaintiff and against Defendant(s) for the sum of $16,881.84 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER & ASS C TES, P.C. Attorney ffinII iit, 'A Law Firm Enwaae Co llee{oi BY: David J. Apothalter, -Esquire Dated: 4/8/2009 Our File No.: 204268 VERIFICATION David J Apothaker Esquire 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 %4efl The undersigned understands that the statements therein are made subject to the penalties of 18 Pa.C.S.A. 4ng to un sworn falsification to authorities. David J. Apothaker, Esquire Attorney for Plaintiff DATE: 4/8/2009 FIA CARD SERVICES, N.A. FRED W ZEPLIN 15 CUMBERLAND RD LEMOYNE, PA 17043-1616 STATEMENT OF ACCOUNT Debtor's Name: FRED W ZEPLIN Account Number: 4888931996183989 Balance Due: $16,881.84 Our File No.: 204268 EXHIBIT "A" 0 )TApy 2009 A?F i 15 AN /I: CUis.. - r "Iry x'18.50 90 An-/ aC* la-9956 ?aa381a Sheriffs Office of Cumberland County R Thomas Kline 6*xA° OT cu mbrEdward L Schorpp Sheri" Solicitor Ronny R Anderson Jody S Smith Chief Deputy 0FPCE -'F THE SHMFr Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 04/20/2009 06:18 PM - Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on April 20, 2009 at 1818 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Fred Zeplin, by making known unto Fred Zeplin personally, at 15 Cumberland Road, Lemoyne, Cumberland County, Pennsylvania, 17043, its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $42.40 April 21, 2009 ?? SO ANSWERS, 1A?,,'r?.,,. f R THOMAS KLINE, SHERIFF Deputy Sheriff Docket No. 2009-2395 FIA Card Services v Fred Zeplin rv n7 Michael S. Travis ID No. 77399 3904 Trindle Road Camp Hill, PA 17011 717-731-9502 mst@ mtravislaw Attorney for Defendant FIA CARD SERVICES, NA c/o Apothaker and Assoc., P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 Plaintiff vs. FRED ZEPLIN 15 Cumberland Road Lemoyne, PA 17043-1616 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA No. 09-2395 Civil Term ANSWER TO CIVIL ACTION COMPLAINT FIRST COUNT NOW COMES the Defendant, Fred Zeplin, by and through the office of the below signed attorney and answers the Complaint as follows: 1. `Denied. Strict proof of ownership of the account and any assignments are demanded at the time of trial. 2. Admitted. 3. Admitted in part, denied in part. Strict proof of the Plaintiff's ownership of this account is demanded at the time of trial. It is admitted that an account bearing the numbers ending in 3989 was provided to the Defendant. 4. Admitted in part, denied in part. It is admitted that an account was issued to the Defendant. It is denied that the amount claimed as due and owing was received or accepted as a benefit to the account. Strict proof of the charges is demanded at the time of trial. 5. Denied. Strict proof of any balance due and whether or not the account is in default are demanded at the time of trial. It is denied that Exhibit A is a statement of this account. Defendant is unfamiliar with this Exhibit. 6. Denied. Strict proof of any payments and/or credits due is demanded at the time of trial. 7. Denied. Defendant, through counsel, has contacted Plaintiff's counsel regarding payment arrangements. As of the date of answer, terms have not been reached. WHEREFORE, Defendant prays this Honorable Court to dismiss the Complaint.! avis 3904 Trindle Road Camp Hill, PA 17011 717-731-9502 mst@mtravislaw.com Attorney for Defendant FIA CARD SERVICES, NA c/o Apothaker and Assoc., P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 Plaintiff vs. FRED ZEPLIN 15 Cumberland Road Lemoyne, PA 17043-1616 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA No. 09-2395 Civil Term VERIFICATION The statements made in this Answer are true and correct to the best of my knowledge, information and belief. I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. Sect. 4904 relating to unsworn falsification to authorities. Fred "n Date: May 6? 2009 FIA CARD SERVICES, NA c/o Apothaker and Assoc., P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 Plaintiff VS. FRED ZEPLIN 15 Cumberland Road Lemoyne, PA 17043-1616 Defendant IN THE COURT OF COMMON CUMBERLAND COUNTY PENNSYLVANIA No. 09-2395 Civil Term CERTIFICATE OF SERVICE PLEAS I certify that a true and correct copy of the foregoing document was served on the below persons by first class U.S. Mail, postage prepaid: FIA Card Services c/o Apothaker and Assoc 520 Fellowship Road C306 Mount Laurel, NJ 08054 Michael S. Travis 3904 Trindle Road Camp Hill, PA 17011 0 ///Z7 Attorney for Defendant FILED-0 4-{Vk OF THE OTAPY 2009 MAY I I AN 9: 4 3 TV vq rl Our File No.: 204268 FIA CARD SERVICES, N.A. } Plaintiff ) VS. ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.: 09-2395 FRED W ZEPLIN ) Civil Action o) Defendant C= -+ ma) rM m m = M c-,) =-n m ? .) o v PRAECIPE FOR APPOINTMENT OF ARBITRATORS r-= r -Am <= TO THE HONORABLE, THE JUDGES OF SAID COURT: =C :Zm :e •' Benjamin J. Cavallaro, Esquire, counsel for the Plaintiff in the above action, respectfully > repmenWthaT 1. The above-captioned action is at issue 2. The claim of Plaintiff in the action is $16881.84. The following attorneys are interested in the case as counsel or are otherwise disqualified to sit as arbitrators: For Defendant For Plaintiff FRED W ZEPLIN Benjamin J. Cavallaro, Esquire 3904 TRINDLE RD. 520 Fellowship Road C306 CAMP HILL, PA 17011 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. November 22, 2010 AND NOW, Respect Iuire ORDER OF COURT ?`D at 0"0* AS% VI, es 20, in consideration of the foregoing petition, and Esq., and Esq., Esq., are appointed arbitrators in the above captioned action as prayed for. By the Court, Our File No.: 204268 FIA CARD SERVICES, N.A. Plaintiff VS. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.: 09-2395 FRED W ZEPLIN ) Civil Action a Defendant ) =i cm co M r i- ?,. c-a -ra rn PRAECIPE FOR APPOINTMENT OF ARBITRATORS C) r -n C) -I "cam TO THE HONORABLE, THE JUDGES OF SAID COURT: =C:) N CDM Benjamin J. Cavallaro, Esquire, counsel for the Plaintiff in the above action, respectfully reprwenwthag° 1. The above-captioned action is at issue 2. The claim of Plaintiff in the action is $16881.84. The following attorneys are interested in the case as counsel or are otherwise disqualified to sit as arbitrators: For Defendant For Plaintiff FRED W ZEPLIN Benjamin J. Cavallaro, Esquire 3904 TRINDLE RD. 520 Fellowship Road C306 CAMP HILL, PA 17011 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. November 22, 2010 Respect ORDER OF COURT a1%? a sa4.o°58 Q quire AND NOW, 0_u , 2016 , in consideration of the foregoing petition, 4 -?X.A_Z aA' Esq., and D( Esq., cr © and as pr fob o 1KZ C C? -- o • O (n ,?nct i ==_? _J Cn LJ_J :.s co Lu o CD C-) Esq., are appointed arbitrators in the above captioned action By the Court, ' - ???? FIA CARD SERVICES, N.A. FRED W. ZEPLIN In the Court of Common Pleas of Cumberland Ylaintttt County, Pennsylvania No. 09 -2395 Defendant Civil Action - Law. Oath We solemnly swear (or affirm) that we will su port, obey and defend the Constitution of the United States a t e onstitutio of his Commonwejth a will discharge the duties of our office with fidelity. 1 (44 Signature gnature Signat e E Delano M. Lantz, Esquire Name (Chairman) Delano M. Lantz & Associates Law Firm 4 North Hanover Street Address Carlisle City, ?3 ?S3 Edward P. Seeber, Esquire Name James, Smith, Dietterick & Connelly, PC Law Firm 555 Gettysburg Pike, Suite C-400 Address 17013 Mechanicsburg 17055-5207 Zip City, Zip a yqsq Award Sonya A. Isa v sto, squire Name Marcello & Kivisto, LLC Law Firm 1200 Walnut Bottom Rd., Suite 331 Address Carlisle 17015 City, Zip /Sgss We, the undersigned arbitrators, having been duly appointed and sworn (or affirmed), make the following award: (Note: If damages for delay are awarded, they shall be separately stated.) , dissents. (Insert name if applicable.) Date of Hearing: U Z4y,,, a ej OW Date of Award: 7Z?1 ?4 yq $4, k/ ( (Chairman) Notice of Entry of Award ' Now, the O&Lk4ay of L--? 20-LL _, at M., the above award was entered upon the docket and notii a thereof-given by mail to the parties or their attorneys. Arbitrators' compensation to be paid upon appeal. By: P Prothonotary Deputy FILED-OFFICE OF THE PROTHONOTAR`t 2011 JAN 28 PM 1= 50 CU PENNSYLVA A UUNTY CT 1ew m ?. )W? /1), r4+Al( a . //oz 8/it Our file No.: 204268 Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff FIA CARD SERVICES, N.A. Plaintiff, vs. FRED W ZEPLIN Defendant. FILED-OFFICE j HE Fr20?,4Otj,C t 1? ? t FEB - 7 PM 3: r. S PUMBEBLANO COUNTY PENNSYLVANIA COURT OF COMMONS PLEAS CUMBERLAND COUNTY DOCKET NO.: 09-2395 Civil Action STIPULATION IN LIEU OF JUDGMENT The matters and things in controversy having been discussed by and between the parties, and a settlement having been agreed upon: It is on January 24, 2011, STIPULATED by and between FIA CARD SERVICES, N.A. ("Plaintiff') and FRED W ZEPLIN ("Defendant"), as follows: 1. Plaintiff filed suit in the above captioned matter seeking damages in the amount of $16,881.84. 2. Defendant agrees to pay to Plaintiff the sum of $5,500.00, which sum Plaintiff agrees to accept in full settlement of its claim herein. 3. As of this date, payments totaling $0.00 have been applied to the aforementioned sum. 4. Defendant shall remit payment(s) in the following manner: a. $785.71 to be paid on or before January 28, 2011; b. $785.71 to be paid on or before the 22nd day of each month, beginning February 22, 2011 through June 22, 2011; c. $785.74 to be paid on or before July 22, 2011. 5. All checks shall be made payable to "FIA CARD SERVICES, N.A.", and sent to the office of Plaintiff's attorney, Apothaker & Associates, P.C., located at the following address: Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 1 6. In the event Defendant fails to pay in accordance with the terms set forth in this Stipulation Plaintiff must notify Defendant's attorney(s), in writing, of Defendant's default. The name and address of Defendant's attorney(s) that notice will be sent to is: MICHAEL S. TRAVIS ESQ 3904 TRINDLE RD. CAMP HILL, PA 17011 7. If the default is not cured within fifteen (15) days after written notice to Defendant's attorney(s), then Plaintiff shall be entitled to obtain the entry of Judgment against Defendant upon ex parte application, with supporting certification, and with notice to Defendant's attorney in the form of a copy of the application addressed to Defendant's attorney, by first-class, postage prepaid, in the suit amount specified in paragraph one (1) of this stipulation less any sums paid pursuant to this Stipulation. We hereby consent to the form and Whe Stipulation. By: e , Esquire 949Apothaker & Associates, P.C. Attorneys for Plaintiff -? B IC AE TRAVIS ESQ' MIC AEL S. TRAVIS ES By: F D :WZEPLIN Defendant 2 -n X M Our File No.: 204268 -arn APOTHAKER & ASSOCIATES, P.C. By: Benjamin J. Cavallaro r" x Attorney I.D.# 307949 520 Fellowship Road C306 ): r? Mount Laurel, NJ 08054 1 j' (800) 672-0215 "w Attorney for Plaintiff FIA CARD SERVICES, N.A. vs. Plaintiff FRED W ZEPLIN Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 09-2395 Civil Action PRAECIPE TO ENTER JUDGMENT PURSUANT TO STIPULATION TO THE PROTHONOTARY: Please enter a judgment in favor of plaintiff, FIA CARD SERVICES, N.A., and against Defendant, FRED W ZEPLIN, for failure to comply with the terms and conditions of the Stipulation in Lieu of Judgment (Stipulation), filed with this Court on February 7, 2011, a copy of which is attached hereto as Exhibit "A". Assess damages in the amount of. Balance: $ 16,881.84 Less: Payments: ( 785.71) Plus: Interest from February 7, 2011 .00 TOTAL $ 16,096.13 Be tamin? avallaroEsq. Aty for Plaintiff Dated: June 28, 2011 +14.00 PD ATT%l C*31116 &alol3yl Our File No.: 204268 APOTHAKER & ASSOCIATES, P.C. By: Benjamin J. Cavallaro Attorney I.D.# 307949 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff FIA CARD SERVICES, N.A. VS. Plaintiff FRED W ZEPLIN Defendant Benjamin J. Cavallaro, Esquire, certifies as follows: Civil Action 1. I am an attorney with the Law Firm of Apothaker & Associates, P.C., attorneys for the Plaintiff in the above captioned matter, and as such, have full and complete knowledge of the facts herein. 2. The matter was settled by and between the parties by Stipulation in Lieu of Judgment (Stipulation), on February 7, 2011, a copy of the Stipulation is attached hereto and marked as Exhibit "A". 3. Defendant breached this agreement by failing to make payments in accordance with the terms of said Stipulation. 4. Therefore, pursuant to the Stipulation, Plaintiff is proceeding towards the entry of Judgment in the amount of $16,881.84, giving the Defendant credit for payments made totaling COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 09-2395 $785.71, for a total of $16,096.13. I verify that the statements made in this Certification are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904, relating to unsworn falsification to authorities. Benjam' Ca llaro, Esq. Attorne aintiff Dated: June 28, 2011 Our File No.: 204268 APOTHAKER & ASSOCIATES, P.C. By: Benjamin J. Cavallaro Attorney I.D.# 307949 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff FIA CARD SERVICES, N.A. COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff VS. FRED W ZEPLIN NO.: 09-2395 Civil Action Defendant AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND : SS. Benjamin J. Cavallaro, 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 15 CUMBERLAND RD LEMOYNE, PA 17043-1616. We inquired with the web site of the Defense Manpower Data Center, located at 1600 Wilson Boulevard, Suite 400, Arlington, VA 22209-2593, if the Defendant(s) is/are in any branch of the military. Mary M. Snavely-Dixon, Director of the Defense Manpower Data Center has sent back our inquiry indicated that the Defendant(s) is/are not in the military. B n'ami . Cavallaro, Esq. Attorney for Plaintiff I verify that the statements made in this Certification are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904, relating to unsworn falsification to authorities. 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Coserage Under the SCRs is Broader in Sonar Carnes CovemW under the SCRA is broader m some cues and ides some categories of persons on active dnty for purposes of the SCF.1 , bo .A,sad not be rep(mtcd as on Acme Dut) under ties ccrt6ate Man times orders. err amended to extend the period of artier derv:, aikh would nctend SCRRA protections. Persons &"kmg to rel.: ou tlas website crrti5cafim should check to make sue the ciders on which SCRA protections are based havt not been amended to extend the wKk"r dames of service. Fur*xnPcre, pmwcum of the SCRA my extend to persons who hair rec m cd orders to report for actn'e dur or to be redacted bit who her not achmly begw actin duty or actualy reported for nducton. The Last Date ate Actn'e Dear. csmti• is ituportara becausc a mmrbet of protections o(SCRA. "end hey ood the dat-? of nrtisv o. Those who w d rely on ibis cstdrpffi- atr urged to ser}s sxrtmsel euvwe that aff nos puranteed to Seer meorfaers under the SCRA are protected '4i -UR\ING This certnca a was prosided based on a name and SSN- prrnuled by the requester Prm ding an erroneous name ter 5SN k%a cause an eacx> as certificate to be protideal Report 1D 386FOUDL1 . "` Our file No.: 204268 ' Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff FIA CARD SERVICES, N.A. ) Plaintiff, ) vs. ) FRED W ZEPLIN } Defendant. } COURT OF COMMONS PLEAS CUMBERLAND COUNTY DOCKET NO.: €19-2395 Civil Action STIPULATION IN LIEU OF JUDGMENT The matters and things in controversy having been discussed by and between the parties, and a settlement having been agreed upon: It is on January 24, 2011, STIPULATED by and between FIA CARD SERVICES, N.A. ("Plaintiff") and FRED W ZEPLIN {"Defendant"), as follows: 1. Plaintiff filed suit in the above captioned matter seeking damages in the amount of $16,881.84. 2. Defendant agrees to pay to Plaintiff the sum of $5,500.00, which sum Plaintiff agrees to accept in full settlement of its claim herein. 3. As of this date, payments totaling $0.00 have been applied to the aforementioned sum. 4. Defendant shall remit payTnnent(s) in the following manner: a. $785.71 to be paid on or before January 28, 2011; b. $785.71 to be paid on or befoore the 22"' day of each month, beginning February 22, 2011 through :Tune 22. 2011; c. $785.74 to be paid on or before July 22, 2011. 5. All checks shall be made payable to "FlA CARD SERVICES, N.A.", and sent to the office of Plaintiffs attorney, Apothaker & Associates, P.C., located at the following address: Apothaker & Associates, P.C. 520 Fellowship Road {'306 Mount Laurel. NJ 08054 6. In the event Defendant fails to pay in accordance with the terms set forth in this Stipulation Plaintiff must notify Defendant's attorney(s), in writing, of Defendant's default. The name and address of Defendant's attorney(s) that notice will be sent to is: MICIIAEL S. TRAVIS ESQ 3904 TRINDLE RD. CAMP HILL, PA 17011 7. If the default is not cured within fifteen (15) days after written notice to Defendant's attorney(s), then Plaintiff shall be entitled to obtain the entry of Judgment against Defendant upon ex parte application, with supporting certification, and with notice to Defendant's attorney in the form of a copy of the application addressed to Defendant's attorney, by first-class, postage prepaid, in the suit amount specified in paragraph one (1) of this stipulation less any sums paid pursuant to this Stipulation. We hereby consent to the form and entry of the with)pn Stipulation. By: avallaro, Esquire ID# 307949 Ahaker & Associates, P.C. Attorneys for Plaintiff //Ph -` M C AEL S. TRAVIS ES -1 1 RI'D \? 'T t'I.Ih Defendant OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS TO: FRED W ZEPLIN 15 CUMBERLAND RD LEMOYNE, PA 17043-1616 FIA CARD SERVICES, N.A. Plaintiff vs. FRED W ZEPLIN Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 09-2395 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. JUDGMENT FOR FAILURE TO COMPLY WITH THE TERMS AND CONDITIONS OF THE STIPULATION IN LIEU OF JUDGMENT JUDGMENT BY DEFAULT ? JUDGMENT IN REPLEVIN JUDGMENT BY CONFESSION ? JUDGMENT FOR POSSESSION ? JUDGMENT ON AWARD OF ARBITRATORS IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: ATTORNEY Benjamin J. Cavallaro Esc. at this telephone number: 215-634-8920 oNOni?2 1111111111111111111111111111111111111111 1111111111111111111111111111111111111111111 J 2171983 GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 FIA CARD SERVICES, N.A. FRED W ZEPLIN COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. DOCKET NO. : 09-2395 ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter my appearance on behalf of the plaintiff in the above-captioned matter. P012 GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINB RG, ESQUIRE JOEL M. F SQUIRE 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. Dated: FREDERIC LWJBERG, ESQUIRE