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Home My WebLink About09-5964Out-File No.: 218762 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 RJM ACQUISITIONS LLC c/o Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 Plaintiff, VS. LAURA BABCOCK 305 OAKVILLE RD SHIPPENSBURG, PA 17257 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: OR - 99 (c4 0V'% l-Fer-r, 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 OutbFild No.: 218762 APOTHAKER & ASSOCIATES, P.C. BY: David J. Ap'othaker, Esquire, Esq. Attorney I.D.#38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff RJM ACQUISITIONS LLC c/o Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 Plaintiff, VS. LAURA BABCOCK 305 OAKVILLE RD SHIPPENSBURG, PA 17257 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 69- SS 6yeN4I CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is RJM ACQUISITIONS LLC c/o Apothaker & Associates, P.C., 520 Fellowship Road C306, Mount Laurel, NJ 08054. 2. Defendant(s) is/are LAURA BABCOCK, an adult individual residing at 305 OAKVILLE RD SHIPPENSBURG, PA 17257. 3. Plaintiff, RJM ACQUISITIONS LLC, is the Assignee and Successor in Interest of Account #081000925628595; and said account was issued to Defendant(s) by WACHOVIA BANK, 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 $1,366.83. 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. 411. WHEREFORE, Plaintiff demands judgment in favor of Plaintiff and against Defendant(s) for the sum of $1,366.83 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & ASSO TES, P.C. Attorney for P ff A Law Firm EnizaizedAn D bt Collection BY: David J. Ap4hkrer, Esquire Dated: 8/24/2009 Our File No.: 218762 VERIFICATION David J. Apothaker, Esquire 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 belief. The undersigned understands that the statements therein are made subject to the penalties of 18 Pa.C.S.A. 4904 relating toisvybrn falsification to authorities. David J. DATE: 8/24/2009 -o 0 LAURA BABCOCK 305 OAKVILLE RD SHIPPENSBURG, PA 17257 Debtor's Name: Account Number: Original Creditor: Balance Due: Our File No.: 218762 RJM ACQUISITIONS LLC STATEMENT OF ACCOUNT LAURA BABCOCK 081000925628595 WACHOVIA BANK $1,366.83 EXHIBIT "A" 0 F!L!-1 OF THE z' ?rqY 2999 5 '' Ali 8: 49 419.60 po ATr-/ Co M31A a3oca? Sheriffs Office of Cumberland County R Thomas Kline Sheriff ??r?cr a ?pbFr? FFCE -,FT= ERIFF PILED--0r1CE OF THE P^rTHCHOTAW Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor 2009 SEP ! f Ali 8: 4 3 cut ?._? -?JUNm PE,! N'SYLVAAlta RJM Acquisitions LLC vs. Laura Babcock Case SHERIFF'S RETURN OF SERVICE 09/04/2009 06:35 PM - Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that n September 4, 2009 at 1835 hours, he served a true copy of the within Complaint and Notice, upon',t e within named defendant, to wit: Laura Babcock, by making known unto herself personally, at 305 Oakville Road Shippensburg, Cumberland County, Pennsylvania 17257 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $46.00 September 08, 2009 SO ANSWERS R THOMAS KLINE, SHERIFF W 2?LAJAJ?),4g? Deputy Sheriff Our File No.: 218762 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 RJM ACQUISITIONS LLC VS. LAURA BABCOCK Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 09-5964 Civil Action Defendant PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment against Defendant, LAURA BABCOCK, in the default of an Answer, in the amount of $1,380.94 computed as follows: Amount claimed in complaint: $ 1,366.83 Less: Amount Paid: ( 0.00) Plus: Interest from August 24, 2009 to October 30, 2009 at the legal interest rate of 6.00% per annum 14.11 Attorney fees 0.00 TOTAL A $ 1,380.94 I certify that Defendant, LAURA BABCOCK, la?t kfiown address is 305 OAKVILLE RD SHIPPENSBURG, PA 17257. / / David J. ApMhaker, Esq. Attorney for Plaintiff Dated: October 30, 2009 M 0. Our File No.: 218762. 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 RJM ACQUISITIONS LLC ) Plaintiff } vs. ) LAURA BABCOCK ) Defendant ) COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 09-5964 Civil Action CERTIFICATION PURSUANT TO RULE 237.1 Pursuant to PA Rule Civil Procedure 237.1, I certify that a copy of the NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT has been sent to the Defendant or the Attorney of Record. 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. Dated: October 30, 2009 Our File No.: 218762 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 RJM ACQUISITIONS LLC VS. Plaintiff LAURA BABCOCK 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 305 OAKVILLE RD SHIPPENSBURG, PA 17257. 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 Defen M npower Data Center has sent back our inquiry indicated that the Defendant(s) is/are not in he ilitary. David J. othaTcer, Esq. Attorney for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 09-5964 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. DepattmentofDefenst Data Center -Mapmer Od-34-24494S:h3.18 Miitmy Stator Report Parssa d to the Seeaue Mks Cr 1 ReWAct C LAO F Skr?6ee Seaa hre Atdra Dotty Sds Attire Dr4 had Dace Nwbo UOMc-T BAD+-'pCK LA R_a Ha:ed ai the of mnlerm •: ou hate fisisbed, t?- D%MC dw" riot possess any ird =®iecararg [hrnditie?al status_ UP=searching the` x&nwhon data banks ofthe Depalned oo(Deffim Manpower Data Center based am the ximnsabon the you prosidtd, the above is the correa status of de i*&*ktai as to a4 broacbes o the L`rtiformed Ser% (Aztuy, Naeug, Marine Corps, Air Farce, NOAA, Public Heatiti; and Coast Guard). %AL om. A kA+A,?M_ N Mar, M. Saac*-I an, Director Deparltmeal ufDt e - Mwpo%w Data Cdr 1644 R'r7scaa litsd., 'Smite 440 Arfingtoik VA 2x209-2-493 Tb: Del Mot power DM Center (DtDC) i5 , of dDe a do waktaim *e Definse Enrollment and EIVI*y Repeating System OXERS) database which is the c+41 cW scarce of data an cKSW for military medical care and a dw efigbIlity seethes. Me DoD strongly supports dw enfarcrmew of the Sunwe Members Cr Rakf Art (50 USC App: J§ 501 etse% as amended) (SCR A) O one* known as the Soldiers' and SmWs' Cud Rckf Act a 1934). D-NIDC has k d reds of theatusub of 'dkres so possess any ` that the "vidoof is ewe* on awe duty' reWonsm and has experienced a smal error rote. In the ^wSthe ancisidfai re amwedabase, or any family member, fikw4 or tepnesent ve assests in my meaner tsar the W&idmal is on active nosy, at is othetvise mtidled to the prdections of the SCRA, you are strongly tordnuraged to obtain firthat vetWicaw of ibe passes shams by tonaeting Oat person's Sav" tie the ' xor LIM f'w ':. eddc FC!»r tlR lscnt If vas have ^idenm the pm sum is drill active duty and youfak to obtain this 5eseice P s 1hra inns t# the SCRA mr- be invoiced against yam, See 50 USC App. §521(t). 1f 1am dabtma ahnaat the pe<sdm fir,;., .rob SS\, irsgxc+ved y d:fD[.1F3, to ? tta)g s your request again at ties Web site and we uiE pracide a new cerfiLatc for that qw_v Thrti nV use refitcts active Asty statue:' ' date tut individual was last on active duty, ifit was sialk the preceding 367 days. For litstorical piew cartoct the Seryke SCRA points-cf-cootact More i%fiva anion on "Mictiw D* $Ames" Acticr duty stows as reported is d is catilicalc " dfcS"im accardawce with 10 €7SC § 141 {d)(1) for a period of more than 34 consecutive days- In the case at a member of the N ancnut Guard. includes service uedet a call to active, ser?ke armed seer the President or the Secretary cfDefiense for a petw d of raune dm 30 consecutive, clays t er 32 CSC § 50Xj forptrpom of respooding to a ' awrFewy dledxc d by the President and sa>Enmaed try Federal £mds. AM Ac*Y Guard Resenve (AGR) members oust be assigned agamst an mAhotizrd mobakwim posilim in due they support, This iockrdcS ti navy TARS, Niatimc Corps ARs sad Coast Guazd RPM, Ac*e Dm sus aho appki to a Uniformed Smite me er who b an W6" duty ? cmrsmissioned o&cr of the US, Pam 1lcakh Service. or Ow W4io" 4cear4c and Atswspbetic !* dtai irtra6on tN. OAA Cain signed Corps) for apesiDd ofmore shag 30 rousecutive da?s C~ We Ltmder Ae .SCRA a Br+aa&r M .S me Coe Courage under the SCRA is broader is some cases and includes some categories of persons on active dloty f w purposes oaf the SCRA u o %uM not bertpatiedl as cu Attie Duty under this cerdfytate. M am- times orders are amendrd to cu end dw period ofacwT duty, xfiech would emend SCRA protrchoas. Persons sedcing to tehv an this website certification should check to make stye the orders an wbich SCRA protentiow we based Base not been orwaded to cdead the inclusive dotes . of serNice Fmiwri nor e, scat prowtiooa ofthe SCRA may ahead to persons wife have received orders to report for acti m daty or to be i ductrA but who hmre not actually begm actn-e duty ar.actt>ally reported ferr induction. IN.- Last Date can Ac4dx Duty emery is saWortaut because a nutter ofprotectio ns of SCRA eattud beyond the last dates ofat duty. Those who would rely on this en ifieate arc urged to seek qua56ed kegs cacrosel to ensure that fights. lassraoteed to Stout members tinder SCRA we protected. `3'AR ZVG. Ties cat katc was prod based an a name and SSN profited by the requeAm. Prmi fang an erroutovs name or SS?N nit cause an erroneous certdicate to be provided, R,epert a,4 n?QPBT3V 218762 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY RJM ACQUISITIONS LLC ) COURT OF COMMON PLEAS CUMBERLAND COUNTY VS. ) LAURA BABCOCK ) NO. 09-5964 To: LAURA BABCOCK 305 OAKVILLE RD SHIPPENSBURG, PA 17257 NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT Date of Notice: September 29, 2069 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 BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 D VID J. APOTHAKER, ESQUIRE A OTHAKER & 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 ',r? TI L•_ 00 Pp ?" a OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS TO: LAURA BABCOCK 305 OAKVILLE RD SHIPPENSBURG, PA 17257 RJM ACQUISITIONS LLC VS. Plaintiff LAURA BABCOCK NOTICE Defendant COURT OF COMMON PLEAS OF . CUMBERLAND COUNTY NO.: 09-5964 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: 800-672-0215 „fro/0j