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HomeMy WebLinkAbout10-4961 Our File No.: 2656p4 APOTHAKER & 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 VION HOLDINGS LLC 5555 GLENRIDGE CONNECTOR SUITE 200 ATLANTA, GA 30328 Plaintiff, vs. CHRISTINA L HOCKENSMITH 441 STONEHEDGE LN MECHANICSBURG, PA 17055-7010 Defendant. .., Fig f_~. ,~~ Tt _ • `~~? i ~ f " ~ r .~ i Z~~O v~~~ ~`:~ ~~'~~ . PM3:3[ G~:~f~, ',f~a' r . a;',; , ~ , ~~. COURT OF COMMON PLEAS CUMBERLAND COUNT//Y~~ NO.: 10 - 4411 l~iv i l ~~-~`~" 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 34 S. BEDFORD ST. CARLISLE PA 17013 717-249-3166 ~Qa.00 P~ 1A'T1'`/ ~~ lR1~5 ~?,~ ay6oo9 Our File No.: 265604 APOTHAKER & 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 VION HOLDINGS LLC 5555 GLENRIDGE CONNECTOR SUITE 200 ATLANTA, GA 30328 Plaintiff, vs. CHRISTINA L HOCKENSMITH 441 STONEHEDGE LN MECHANICSBURG, PA 17055-7010 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is VION HOLDINGS LLC, 5555 GLENRIDGE CONNECTOR SUITE 200, ATLANTA, GA 30328. 2. Defendant(s) is/are CHRISTINA L HOCKENSMITH, an adult individual residing at 441 STONEHEDGE LN MECHANICSBURG, PA 17055-7010. 3. Plaintiff, VION HOLDINGS LLC, is the Assignee and Successor in Interest of Account # ending in 5377; and said account was issued to Defendant(s) by CHASE BANK USA N.A., 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 $2,658.15. 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". above. 7. Although demand has been made, Defendant(s) has failed to make payment of the amount due as WHEREFORE, Plaintiff demands judgment in favor of Plaintiff and against Defendant(s) for the sum of $2,658.15 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & SS CIATES, P.C. Attorne for laintiff A Law Firm En e Debt Colleotio~ BY: _ David J. A Qt aker, Esquire Dated: 7/21 /2010 Our File No.: 265604 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 tq~`un,~worn falsification to authorities. David J. Apc Attorney Esquire DATE: 7/21/2010 Global Debt Registry ACCOUNT HISTORY REPORT Account Information Original Registry Date: Registry ID Number: Issuer Account Number: .2009/10/30 ', 9990000411685377 ` xxxx~xxx Original Issuer: ;CHASE BANK USA, N.A. Open Date: ' 2007/07/22 i Delinquency Date: :2007/12/21 Charge Off Date: 2008/11/30 Original Charge-Off Balance: $ 2,658.15 Principal Balance at Charge-Off $ 1,778.25 Interest at Charge-Off: ~~ $ 879.90 Charge-Off Fees: ! Charge-Off Other: _____ 1 Interest Rate at Charge-Off: ~ Media Available: y ;Eligible for Resale: Y Account Holder Information Debtor Last Name: HOCKENSMITH Debtor First Name: :CHRISTINA L Debtor Middle Name: Social Security Number: XXX-XX-4817 Co-Debtor Name: j Co-Debtor SSN: Chain of Ownership Summary Transfer of Portfolio Balance at Service Ownership. Date Owners Certification No. Certification Level CHASE BANK USA, N.A. 1000039 s 2,858.15 31A 2009H0/30 VION HOLDINGS, LLC 1000041 S 2.658.15 Last Payment Date: ~ 2008/07/10 .Last Payment Amount: $ 52.00 Last Scrubbed Date: www.GlobalDebtRegistry.com/tecros ' Global Debt Registry ©2010 Statement for account number: 5377 New Balance Payment Due Date Minimum Payment CHASE o $2,656.15 12/11/08 $698.00 $1,783.15 • Make your eMek payable to: Chase Card Services. Please write amount enclosed. New address or a-mail? Print on bads. 5377001783150D2658150000009 22866 BEX 932609 D CHRISTINA L HOCKENSMITH 441 STONEHEDGE LN MECHANICSBURG PA 17055-7010 Ir11111r1r~1r.111rrlr~llrrrl,Irrr~llrlrlrrrllrrlrirrrll..llr11 CARDMEMBER SERVICE PO BOX 15153 WILMINGTON DE 19886-5153 lurlllroll!nulrlulrl~lrnlllwurllllnnlulu~lllrlul 1: 5000L60281: 203iL43265377411• Opening/Cbsing Date: CHASE O ' 10/22/08 -11/21/08 CUSTOMER SERVICE I U S 1 800 9 5 ' ' ' Mir im m Payment Due: n . . - - 4 -200D $i i s sroe Espanol 1888-446-3308 TDD 1-800-955-8060 Pay by phone 1$0036-7958 Outside U.S. call collect VISA ACCOUNT SUMMARY Account Number: - 5377 102-594-8200 Previous Balance $2,557.29 Total Credit Line $1 700 ACCOUNT INQUIRIES Purchases, Cash, Debits +E39.00 Available Credit $0 P•O. Box 15298 Finance Charges +$61.86 Cash Access Line $1 700 Wilmington, DE 19650.5298 New Balance $2,658.15 Available for Cash $0 PAYMENT ADDRESS P.O. Box 15153 Wilmington, DE 19886-5153 VISIT US AT: www. chase. tom/cred itcard s The outstanding balance on your credit card acx:ount is scheduled to be written ott as a bad debt shortly. As a result, your credit bureau will be updated with a negative rating that could last for up to seven years. We can still help, but you need to call us now at 1-88&792-7547 (tolled 1-302-594$200). FLEXIBLE REWARDS SUMMARY To redeem your Flexible Rewards points, call Previous points balance p 1-600.603-2265, or log on to Points earned on purchases this period 0 www.chase.com/creditcards for 24-hour access New total points balance p to your rewards program. TRANSACTIONS Trans Amount Date Reference Number Merchant Name or Trensaction Description Credit Debit 11/10 LATE FEE $39.00 FINANCE CHARGES Finance Charge Daily Periodic Rate Corresp. Average Daily Due To Trensadion Acwmulated FINANCE Category 31 days in cycle APR Balance Periodic Rate Fee Fin Charge CHARGES Purchases V .07668% 27.99% 52,334.21 $55.49 $0.00 $0.00 $55.49 Cash advances V .07668% 27.99% $267.66 $6.37 $0.00 $0.00 $6.37 Total finance charges $61 86 Effective Annual Percentage Rate (APR): 27.99% Please see IMonnation About Your Account section for balance computation method, grace period, and other important infonnadon The Corresponding APR is the rate of interest you pay when you tarty a balance on any transaction category. The Effective APR represents your total finance charges - including trensactlon fees such as cash advance and balance transfer fees -expressed as a percentage. 0000061 FIS33335 D 10 006 V 9 21 09!1121 Psge 1 of 1 65696 MA MA 22868 32610060100002268801 }~ 0050 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ~$~tttn At ~Itlrl~rr~~~~ ~;. -,~~; ~~ic~~F T~~s~,~~iF~ ~;L . ~~,f -. f ~~~~ ~u~ 1.3 ISM z~ I I J` ,-.,, ;~ Gl4 i:_: ~_ - .._ ~- Vion Holdings, LLC vs. Christina L. Hockensmith Case Number 2010-4961 SHERIFF'S RETURN OF SERVICE 08/10/2010 08:00 PM -Valerie Weary, Deputy Sheriff, who being duly sworn according to law, states that on August 10, 2010 at 2001 hours, she served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Christina L. Hockensmith, by making known unto Dan Hockensmith, adult in charge at 441 Stonehedge Lane, Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time handing to him personally the said true and correct copy of the same. /~ VALERIE WEARY, DEPUTY SHERIFF COST: $37.00 August 11, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF (cj CountySuite Sheriff, Teleosoft. Inc. Our File No.: 265604 ' 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 VION HOLDINGS LLC ) Plaintiff ) VS. ) CHRISTINA L HOCKENSMITH ) } Defendant ) ca - °iJ p ? t"r'1 _ ? ? -ter - ? cis ? c?a c? c.a M " ? COURT OF COMMON PLEAS,?OF` CUMBERLAND COUNTY NO.: 10-4961 CIVIL TERM Civil Action PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment against Defendant, CHRISTINA L HOCKENSMITH, in the default of an Answer, in the amount of $2,658.15 computed as follows: Amount claimed in complaint: $ 2,658.15 Less: Amount Paid: ( 0.00) Plus: Interest from July 21, 2010 to September 21, 2010 at the legal interest rate of 0.00% per annum 0.00 Attorney fees 0.00 TOTAL $ 2,658.15 I certify that Defendant, CHRISTINA L HOCKEN ITH, last known address is 441 STONEHEDGE LN MECHANICSBURG, PA 17055-701P./ 1 Dated: September 21, 2010 David J. Apotkaker, Esq. Attorney for Pla tiff " s 265604 VION HOLDINGS LLC VS. OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY CHRISTINA L HOCKENSMITH To: CHRISTINA L HOCKENSMITH 441 STONEHEDGE IN MECHANICSBURG, PA 17055-7010 COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 10-4961 CIVIL TERM 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 34 S. BEDFORD ST. CARLISLE, PA 17013 717-249-3166 BAR S DAVID J. AP THAKER, ESQUIRE APOTHAKER & 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 Date: September 02, 2010 Our File No.: 265604 APOTHAKER & ASSOCIATES, P.C. By: David J. Apothaker Attorney LD.# 38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff VION HOLDINGS LLC COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff VS. CHRISTINA L HOCKENSMITH NO.: 10-4961 CIVIL TERM Civil Action Defendant 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 8 Pa.C.S.A. §4904, relating to unsworn falsification to authorities. David J. Apothaker, Esq. Attorney for Plaintiff Dated: September 21, 2010 Our File No.: 265604 ' 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 VION HOLDINGS LLC ) } Plaintiff ) vs. ) CHRISTINA L HOCKENSMITH ) Defendant ) COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 10-4961 CIVIL TERM 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 441 STONEHEDGE IN MECHANICSBURG, PA 17055-7010. We inquired with the web site of the Defense Manpo r Data Center, located at 1600 e Defendant(s) is/are in any th Wilson Boulevard, Suite 400, Arlington, VA 22209-259V branch of the military. Mary M. Snavely-Dixon, Director of the Defense power ata Center has sent back our inquiry indicated that the Defendant(s) is/are not in the rAf itary. David J. Apothaker, Esq. Attorney for Plaintiff I verify that the statements made in this Certification are true and correct. 1 understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904, relating to unsworn falsification to authorities. DepsllEmeetofI efimse Mampower Data Center Sep-21=2010lil:°r.231 N ata n, Status Report putsuaut to the Sen;ce Mier ers Cmit Relief Ace --K Last ;Masse Fr le Bit& Data Andrea Doty Stares Arose Dow Ead Duce Service ? HOCKENS1dTTE1 CMISTNA Based on the irfcm? you have fnrrezhed, tat DMDC does tea possess any si=Mhoa L micaung the iu &xhk i staus. t; ` the idbEaaapon data bmYks of fire Dept of Deft;s'-x 4lam povwer Data f latter: based On the afonitaWO you prmidsd, the above 6 the cuarera status gibe r irhtal as to as bran ctwi of the Valbruied Sersiacs (Amy, ;easy, Marime Craps, As Fare, NOA A- Pubk Health. and Coast 0iuardl. Mary ?Mi. Sam*-Dbm Director DquftUMt ofDcfem,- MWPMW DUD Center JW &*sm Blvd> Stale 4 A iegton, VA 22.109-2593 The Def' Ada iparyes Data Center (DWO is an organkawn of the Departrrtem of Defenmr d w maintains the Dden'se Enrolimal and E3igbi'dp Report System (DEEM database sixth is the offrdal source of data on ehgbiky fix miy medical care and odsea elgiblitv system The DbD strana v supports du va6xcemrnt of thr Senice'sirmbers Cash Rchcf Act (50 USC App S 501 et seat„ as amcpded) (SCRA) r{ocmatv kssu v%v as dbe Solders' and Suers' Chit FAd Act e 1940)_ DMDC has issued 1nmdreds of 6ouum3x of 'dtrrb txri possess air, iafontambon i<tdi g that the aufmidual is curready cc sense duty' responses, and has experienced a sate emot rate In the n-ent the ind ideal referenced above. cr an-, famk. meudaer, friend, or representatnro asserts is my manner tip' doe im&uht) is on armor rimy, as is ohm-%ise coaled to tLc ptotectkms of die SCRA, you are strogO encouraged to obtain kmrd err %w&a6m of the persai s stam by coomiing that petiosi s 5tntice via the `defewelink not" LRL t r _ titer 4dMsel&,l ¢m fau via FCO9SLE?R ?ml If you ltas-e mike the person is on artier dLri and }on fax to obtain this addsional Stoke rerilicahon, punitive prosimom of tlx SCRA may be im oked armust you. Sce 50 L'SC App. §{21(c) Vyo you abtaim addoc al i mateoa abo4s d>,- person (e g 1 an SS\, irrprm=ed accuracy of DM' a riad& aortas, ytsv + an WAWA gnus request again at this 1'i'eb site aid we uy1 provide a rxw certi6catc fix that quer This response fedects, sense, r slants' including : date The O&idcw was fast on acct dirty, It was Wkba due precerl+tag 36'. days. For listorical ' please ca tart the Service SCRA points-of-contact- Maw ikon on "Attire DW Sum" Active duty staum as reported in this crrtiSc" is defined tat aecordm., with 1 o Li SC § 101(d)(1) for a period of more than 30 tonsecutioe daps, to die ease of a member of the \ationd CrLvnI includes service under a. cal to noire senice authorized by die President or flue Secretary 4oMetewt for a period of more than 30 eun',!ctrnt days under 3_' t'SC y 50:{f) for pwpoiea o rc ing to a manualeuvergew--y declared by the PresidcrA and supported b Federal fiords AJ Ar*r Guard Reserve (A rGR) members muu be assigmed aparst an authorized awbazation pos6on is the uni thc> support This i lacks N- -m v TARS, 54atine Corps ARs and !Cowl Owd RPAs. Aetiv a Don status arse appkes to a Undormed Service meurbtr wbo is err} Ac we dory romttttiFSinoctl o vet cfdtt L .S, public HeOt Service or the I a6oud Oceark sat! Aurtosp Aim rrstratioa OgOAA Commissioned Carps) fora par od,tf mcax thaw 3o coosea*ve dwjs_ C'rrraw L'rtrdm &e SGiI'.at u $roader is 'flaw twAso Coverage under the SCRA is broader m som cases and adootes sotoe categories of'persaos on active day far purposes afdr SM vdi o would not be reported as as Aetim Daly wxW fl is eertificata. -Mm tits orders we amended to extend the period of v duty, whKh would cxtmd SCRA protections. Persom acelor g to rerg on ft websime e t fficartan should dreck to make sire the orders on wh" SCRA pratrchom we based haMr not been notoded to extend die i du€ive date% of service, Fire, soap ptowtioaa of die SCP A may extend to persons who have reemed orders to report fir mcmt darn or to be xxkKted, but aiio havr nett actualy begun active dirty or actual-,, reported for i duct m Ile Last Deal on Actin a Dirt} tutrc is important beet a ousubts ofprotectiow of SC RA ettirnd be; and the Est chars of ne" duty: Ttose wbo xoeid trip usn dxs curate are urged to seek gaMlod kgal counsel to ensure that a& rigift guaranteed to Service member's wider the CRA are protested. STAR-N-N k This ccrifiieate was prided based an amame and SSN provided by ttte regmrsta: Providing amamass name at SSti wti chase an erg osocius ce t>dcate to be provided Report a.AHC<CPK41U OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS TO: CHRISTINA L HOCKENSMITH 441 STONEHEDGE LN MECHANICSBURG, PA 17055-7010 VION HOLDINGS LLC q &1 - 1c) COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff VS. CHRISTINA L HOCKENSMITH NO.: 10-4961 CIVIL TERM 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: 800-672-0215 6T -o? l -10