HomeMy WebLinkAbout10-4781 SHERIFF'S OFFICE OF CUMBERLAND COUNTY
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Arrow Financial Services LLC Case Number
vs. 2010-4781
Jacinto Bruno
SHERIFF'S RETURN OF SERVICE
07/22/2010 05:45 PM -Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on July 22,
2010 at 1745 hours, he served a true copy of the within Complaint and Notice, upon the within named
defendant, to wit: Jacinto Bruno, by making known unto himself personally, at 2200 Cedar Run Drive, Ext
Apartment E, Camp Hill, Cumberland County, Pennsylvania 17011 its contents an t th a t' e
handing to him personally the said true and correct copy of the same.
MARK CONKLIN, DEPUTY
SHERIFF COST: $41.50
July 23, 2010
SO ANSWERS,
RON R ANDERSON, SHERIFF
(ci CountySuite SFenff. Teleosoff. Inc.
FILED-DF FIC,
NE'QTHDPrfi
Our file No.: 271210 a' r
APOTHAKER & ASSOCIATES, P.C. 2010 DEC _8? C !
520 Fellowship Road C306
Mount Laurel, NJ 08054 CUMBERLAND COON T
(800) 672-0215 FFMNSYLvAIA
Attorneys for Plaintiff
Attorney ID# 307949
ARROW FINANCIAL SERVICES LLC
Plaintiff,
vs.
JACINTO BRUNO
Defendant
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 August 18, 2010, STIPULATED by and between Plaintiff, ARROW
FINANCIAL SERVICES LLC, and Defendant, JACINTO BRUNO parties as follows:
1. Defendant agrees to pay the sum of $2,427.39, which sum Plaintiff agrees
to accept in full settlement of its claim herein, inclusive of counsel fees and court costs.
2. The sum aforesaid of $2,427.39 shall be paid by the by Defendant,
JACINTO BRUNO, to the attorneys for Plaintiff in the following manner:
a. $15.00 to be paid on or before August 31, 2010;
b. $50.00 to be paid on or before the 8th day of each month, beginning
September 8, 2010 until paid in full.
All checks are to made payable to ARROW FINANCIAL SERVICES
LLC, and sent to:
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
Gr
-.;
C: 4f.?i T7 i
DOCKET NO.: 10-4781 CIVIL TERM
Apothaker & Associates, P.C.
520 Fellowship Road C306
Mount Laurel, NJ 08054
Our file No.: 271210
3. In the event Defendant fails to pay in accordance with the terms set forth
in this Stipulation, then, and in that event, Plaintiff shall be entitled to obtain the entry of
Judgment against Defendant ex parte, in the sum of $2,427.39, giving Defendant credit
for any sums actually paid pursuant to the terms of this Stipulation.
4. In the event of default as aforesaid, Plaintiff shall be entitled to obtain the
entry of Judgment upon ex parte application, with supporting certification, and with
notice to Defendant only in the form of a copy of the application addressed to JACINTO
BRUNO by first-class, postage prepaid.
We hereby consent to the form and entry of the within Stipulation.
APOTHAKER & ASSOCIATES, P.C.
Attorneys for Plaintiff
A Law Firm Engaged inB 6et Collection
By:
, Esquire
JACINTO BRUNO
Our File No.: 271210
Apothaker Scian P.C.
By: David J. Apothaker, Esquire
Attorney I.D. #38423
520 Fellowship Road Suite C306
PO Box 5496
Mt. Laurel, NJ 08054-5496
(800) 672-0215
Attorneys for Plaintiff
ARROW FINANCIAL SERVICES LLC
Plaintiff
vs.
JACINTO BRUNO
Defendant
)
)
)
)
) NO.: 10-4781 CIVIL TERM
)
)
)
)
- 012 F C
OF THE: PROTHONOTAi,,
20111 OCT -3 Ph I: 15
C LIM BERL /VA
r
PENNS2, ND COUNTY
YL NIA
COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY
Civil Action
PRAECIPE TO ENTER JUDGMENT PURSUANT TO STIPULATION
TO THE PROTHONOTARY:
Please enter a judgment in favor of plaintiff, ARROW FINANCIAL SERVICES LLC,
and against Defendant, JACINTO BRUNO, for failure to comply with the teinis and conditions
of the Stipulation in Lieu of Judgment (Stipulation), filed with this Court on December 8, 2010, a
copy of which is attached hereto as Exhibit "A".
Assess damages in the amount of:
Stipulated Amount:
Less: Payments:
TOTAL
$ 2,427.39
( 1,925.00)
$ 502
David J. Apothaker, Thquire
Attorney for Plaintiff
Our File No.: 271210
Apothaker Scian P.C.
By: David J. Apothaker, Esquire
Attorney I.D. #3 8423
520 Fellowship Road Suite C306
PO Box 5496
Mt. Laurel, NJ 08054-5496
(800) 672-0215
Attorneys for Plaintiff
) COURT OF COMMON PLEAS OF
ARROW FINANCIAL SERVICES LLC ) CUMBERLAND COUNTY
)
Plaintiff )
vs. ) NO.: 10-4781 CIVIL TERM
)
JACINTO BRUNO ) Civil Action
)
Defendant )
David J. Apothaker, Esquire, certifies as follows:
1 I am an attorney with the Law Firm of Apothaker Scian 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 December 8, 2010, 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. All credits, if any, to which Defendant(s) is entitled, have been applied to the
balance and are reflected in Plaintiffs Praecipe to Enter Judgment.
5. Therefore, pursuant to the Stipulation, Plaintiff requests entry of Judgment in the
amount of $502.39.
I verify that the statements made in this Ce
that false statements herein are made subject to
unsworn falsification to authorities.
penal
on are true and correct. I understand
ies of 18 Pa.C.S. 44904, relating to
David J. A
Attorney for P
aker, Esquire
ainti ff
Our file No.: 271210
2$18)Er
'APOTHAKER & ASSOCIATES; . . -8 MI 31
520 Fellowship Road 006 CUMBERLAND couNTy
Mount Laurel, NJ 08054 PENNS YLVANi A
(800) 672-0215
Attorneys for Plaintiff
Attorney ID# 307949
FILED -OFFICE
HE PROTHONOTARY
) COURT OF COMMON PLEAS
ARROWFINANCIAL SERVICES LLC ) CUMBERLAND COUNTY
vs.
JACINTO BRUNO
Plaintiff,
Defendant.
)
) DOCKET NO.: 10-4781 CIVIL TERM
)
) 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 August 18, 2010, STIPULA IED by and between Plaintiff, ARROW
FINANCIAL SERVICES LLC, and Defendant,. JACINTO BRUNO parties as follows:
1. Defendant agrees to pay the sum of $2,427.39, which sum Plaintiff agrees
to accept in full settlement of its claim herein, inclusive of counsel fees and court costs.
2. The sum aforesaid of $2,427.39 shall be paid by the by Defendant,
JACINTO BRUNO, to the attorneys for Plaintiff in the following manner:
a. $15.00 to be paid on or before August 31, 2010;
b. $50.00 to be paid on or before the 8th day of each month, beginning
September 8, 2010 until paid in full.
All checks are to made payable to ARROW FINANCIAL SERVICES
LLC, and sent to:
Apothaker & Associates, P.C.
520 Fellowship Road C306
Mount Laurel, NJ 08054
' Ott file No: 271210
3. In the event Defendant fails to pay in accordance with the teinis set forth
in this Stipulation, then, and in that event, Plaintiff shall be entitled to obtain the entry of
Judgment against Defendant ex parte, in the sum of $2,427.39, giving Defendant credit
for any sums actually paid pursuant to the terms of this Stipulation.
4. In the event of default as aforesaid, Plaintiff shall be entitled to obtain the
entry of Judgment upon ex parte application, with supporting certification, and with
notice to Defendant only in the form of a copy of the application addressed to JACINTO
BRUNO by first-class, postage prepaid.
We hereby consent to the form and entry of the within Stipulation.
APOTHAKER & ASSOCIATES, RC.
Attorneys for Plaintiff
A Law Firm Engaged in OA Collection
By:
vallaro, Esquire
Our File No.: 271210
Apothaker Scian P.C.
By: David J. Apothaker, Esquire
Attorney LD. #38423
520 Fellowship Road Suite C306
PO Box 5496
Mt. Laurel, NJ 08054-5496
(800) 672-0215
Attorneys for Plaintiff
) COURT OF COMMON PLEAS OF
ARROW FINANCIAL SERVICES LLC ) CUMBERLAND COUNTY
)
Plaintiff )
vs. ) NO.: 10-4781 CIVIL TERM
)
JACINTO BRUNO ) Civil Action
)
Defendant )
AFFIDAVIT OF NON-MILITARY SERVICE
COMMONWEALTH OF PENNSYLVANIA
: SS.
COUNTY OF CUMBERLAND
David J. Apothaker, Esquire, 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
2200 CEDAR RUN DRIVE EXT APT E CAMP HILL, PA 17011-7464.
We inquired with the web site of the Defense Manpower Data Center, located at 1600
Wilson Boulevard, Suite 400, Arlington, VA 22209j 593, if the Defendant(s) is/are in any
branch of the military.
Mary M. Snavely -Dixon, Director of the De se Manpower Data Center has sent back
our inquiry indicated that the Defendant(s) is/are not he military.
David J. Apothaker, Esquire
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.
Department of Defense Manpower Data Center
Status Report
Pursuant to Se ,ice bf x°s Gari l i
Last Name: BRUNO
First Name: JACINTO
Middle Name:
Active Duty Status As Of: Aug -05-2014
Results as of : Aug -05-2014 05:26:15 AM
SCRA 3.0
On Active Duty On Active Duty Status Date
Active Duty Start Date
Active Duty End Date
Status
Service Component
NA
NA
No
NA
This response reflects the individuals' active duty status based on the Active Duty Slates Date
Left Active Duty Within 367 Days of Active Duty Status Date
Active Duty Start Date
Active Duty End Date
Status
Service Component
NA
NA
No
NA
This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date
The Member or His/Her Unit Was Notified of a Future Call -Up to Active Duty on Active Duty Status Date
Order Notification Start Date
Order Notification End Date
Status
Service Component
NA
NA
No
NA
This response reflects whether the individual or his/her unit has received early notification to report for active duty
Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of
the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and
Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty.
Mary M. Snavely -Dixon, Director
Department of Defense - Manpower Data Center
4800 Mark Center Drive, Suite 04E25
Arlington, VA 22350
The
Manpower The Defense Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility
'Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems.
The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 et seq, as amended) (SCRA) (formerly known as
the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the
individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any family
member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the
protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the
"defenselink.mil" URL: http://www.defenselink.mil/faq/pis/PC09SLDR.html. If you have evidence the person was on active duty for the active duty status
date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521(c).
This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active
Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active
duty on the Active Duty Status Date.
More information on "Active Duty Status"
Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less
than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service
authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by the
President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the
unit they support. This includes Navy Training and Administration of the Reserves (TARS), Marine Corps Active Reserve (ARs) and Coast Guard Reserve
Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S.
Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps).
Coverage Under the SCRA is Broader in Some Cases
Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be
reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods.
Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1).
Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website
certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service.
Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not
actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA
extend beyond the last dates of active duty.
Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA
are protected
WARNING: This certificate was provided based on a last name, SSN/date of birth, and active duty status date provided by the requester. Providing
erroneous information will cause an erroneous certificate to be provided.
Certificate ID: OCP4R55340F6UD0
OFFICE OF THE PROTHONOTARY
COURT OF COMMON PLEAS
TO: JACINTO BRUNO
2200 CEDAR RUN DRIVE EXT APT E
CAMP HILL, PA 17011-7464
) COURT OF COMMON PLEAS OF
ARROW FINANCIAL SERVICES LLC ) CUMBERLAND COUNTY
)
Plaintiff )
vs. ) NO.: 10-4781 CIVIL TERM
)
JACINTO BRUNO ) 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.
15( JUDGMENT FOR FAILURE TO COMPLY WITH THE TERMS
AND CONDITIONS OF THE STIPULATION IN LIEU OF
JUDGMENT
D JUDGMENT BY DEFAULT
7 JUDGMENT IN REPLEVIN
D JUDGMENT BY CONFESSION
JUDGMENT FOR POSSESSION
JUDGMENT ON AWARD OF ARBITRATORS
IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL:
ATTORNEY David J. Apothaker, Esquire at this telephone number: 215-634-8920