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Home My WebLink About10-28384h Our File No.: 254175 APQTHAUR & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire Attorney I.D. #38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff CHASE BANK USA, N.A. 3700 WISEMAN BLVD BLDG 2 1ST FLOOR SAN ANTONIO, TX 78251 Plaintiff, vs. BRYAN J GABNER 6 PLAINVIEW RD CAMP HILL, PA 17011-7928 Defendant. 2010 APR 28 F'ry' 1: 7 Ct,m COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: ID -oJ53d ?tutl 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 C"is 04.00 Pb A77y C0 1'7 8,U I e Our File No.: 254175 APQTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker•, Esquire Attorney I.D. 438423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff CHASE BANK USA, N.A. 3700 WISEMAN BLVD BLDG 2 1 ST FLOOR SAN ANTONIO, TX 78251 Plaintiff, VS. BRYAN J GABNER 6 PLAINVIEW RD CAMP HILL, PA 17011-7928 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is CHASE BANK USA, N.A., 3700 WISEMAN BLVD BLDG 2 1 ST FLOOR, SAN ANTONIO, TX 78251. 2. Defendant(s) is/are BRYAN J GABNER, an adult individual residing at 6 PLAINVIEW RD CAMP HILL, PA 17011-7928. 3. At the special instance and request of Defendant, Plaintiff, CHASE BANK USA, N.A., issued to Defendant(s), Account #4266902024460790- 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 $6,581.34. 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. r- WHEREFORE, Plaintiff demands judgment in favor of Plaintiff and against Defendant(s) for the sum of $6,581.34 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & A O IATES, P.C. Attorney f r P ' tiff A Law Firm Enaa d i Debt C ection BY: David J. ApoNker, Esquire Dated: 4/21/2010 Our File No.: 254175 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 belief. The undersigned understands that the statements therein are made subject to the penalties of 18 Pa.C.S.A. 4904-jelating to unworn falsification to authorities. David J. Apot , Esquire Attorney for Plaintiff DATE: 4/21/2010 CHASE BANK USA, N.A. BRYAN J GABNER 6 PLAINVIEW RD CAMP HILL, PA 17011-7928 STATEMENT OF ACCOUNT Debtor's Name: BRYAN J GABNER Account Number: 4266902024460790 Balance Due: $6,581.34 Our File No.: 254175 EXHIBIT "A" SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Edward L Schorpp Solicitor Chase Bank USA, N.A. vs. Bryan J. Gabner ~. . ~~ ~~.~ 2fll0 ~~Y i 3 ~i~ ~= 4Q ~;~~~ F _ . ~•ueiF ~`~f+) ~i~Y~.~irl~~~/a Case Number 2010-2838 SHERIFF'S RETURN OF SERVICE 05/11/2010 04:14 PM -Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on May 11, 2010 at 1610 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Bryan J. Gabner, by making known unto Nina Gabner, Wife of defendant at 6 Plainview Road, Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to her personally the said true and correct copy of the same. GERALD WORTHINGT ,DEPUTY SHERIFF COST: $41.50 May 12, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF ic; Cara?ySulee Sheriff TeteaSOft. h'rt;. r JASON M. RETTIG, PABN 200948 418 WILLARD RD HATBORO, PA 19040 (267) 879-9054 Attorney for Defendant BRYAN GABNER ,~~ ~~ O~I~ 0~ ~~~~ ~~~~ ~~ ~ ~ ~fyl 3 ~'S/ f71~r/GtY~~~ l~~iGf/7~ ~-lrlr~..S~l~ar~, ~.- V~,` IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHASE BANK USA N.A. Plaintiff, vs. BRYAN GABNER Defendant. Case No: 10-2838- Civil Term CIVIL ACTION -LAW PRAECIPE TO ENTER APPEARANCE To the Prothonotary: Please enter my appearance for BRYAN GABNER, defendant, in the above titled case. DATED: May 19, 2010 JA M. RETTIG, PABN 200948 418 WIL,LARD RD HATBORO, PA 19040 (267) 879-9054 Attorney for Defendant BRYAN GABNER VERIFICATION I, Defendant, BRYAN GABNER, verify that the facts set forth in this answer are true and correct to the best of my knowledge, information, and belief DATED: s/~0 / D Defendant BRYAN GABNER . , • .. JASON M. RETTIG, PABN 200948 418 WILLARD RD HATBORO, PA 19040 (267) 879-9054 Attorney for Defendant BRYAN GABNER ~, r _ ~~ 2~l~~~~.~F' ~7 Fit 351 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHASE BANK USA N.A. vs. BRYAN GABNER Plaintiff, Defendant. Case No.: 10-2838-Civil Term CNII. ACTION -LAW ANSWER AND NOW, this 19`~ day of May, 2010, comes the defendant BRYAN GABNER, by and through his attorney Jason Rettig, who admits, denies, and alleges as follows: 1. Defendant, BRYAN GABNER, admits to the facts contained in paragraph one, that the plaintiff, Chase Bank is a corporation with its principal place of business located at (c/o David Apothaker 520 Fellowship Rd, C306 Mt. Laurel, NJ 08054) 2. Defendant, BRYAN GARNER, admits to the facts contained in paragraph two, that he is an adult individual residing at 6 Plainview Rd Camp Hill, PA 1701 l . 3. Defendant, BRYAN GABNER, admits facts alleged in paragraph three, at his special instance and request, the Plaintiff issued to her account No. 4266902024460790. 4. Defendant, BRYAN GABNER, admits facts alleged in paragraph four, that he accepted the account. 5. Defendant, BRYAN GABNER, admits facts alleged in paragraph five, that the account is in default but does not have sufficient information to admit or deny the amount of unpaid balance as $6581.34 6. Defendant, BRYAN GABNER, admits facts alleged in paragraph six, that all credits, if any, to which he is entitled, are set forth in Exhibit "A". 7. Defendant, BRYAN GABNER, admits alleged in paragraph seven, that although demand has been made, he has failed to make payment of the amount allegedly due. WHEREFORE, the defendant respectfully requests this honorable court enter judgment in favor of the defendant and that Complainant take nothing by said Complaint; that Defendant recover its cost of action herein; and such other relief as the Court may deem proper. Respectfully submitted, DATED: May 19, 2010 JASO . RETTIG, PABN 200948 418 WILLARD RD HATBORO, PA 19040 (267) 879-9054 Attorney for Defendant BRYAN GABNER Our File No.: 254175 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire Attorney I.D.# 38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff CHASE BANK USA, N.A. Plaintiff, vs. BRYAN J GABNER i; l BErc L h `n COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 10-2838 CIVIL TERM Defendant PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & ASSOCIATES, P.C. Attorne or Plaintiff A Law Firm E av-e in Debt Collection By: David J Dated: 4/25/2012 , Esquire 11111111 Ill 111111111111111111