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Home My WebLink About10-5390Our File No.: 277459 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 BARCLAYS BANK DELAWARE 125 S WEST STREET WILMINGTON, DE 19801 Plaintiff, VS. JERRY L MANLEY 321 CORNMAN RD CARLISLE, PA 17013-9640 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: /()- 5390 G?? I 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 $9a.oo -0d of of 19sdcta U ",2q 057 Our File No.: 277459 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 BARCLAYS BANK DELAWARE 125 S WEST STREET WILMINGTON, DE 19801 Plaintiff, vs. JERRY L MANLEY 321 CORNMAN RD CARLISLE, PA 17013-9640 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is BARCLAYS BANK DELAWARE, 125 S WEST STREET, WILMINGTON, DE 19801 2. Defendant(s) is/are JERRY L MANLEY, an adult individual residing at 321 CORNMAN RD CARLISLE, PA 17013-9640. 3. At the special instance and request of Defendant, Plaintiff, BARCLAYS BANK DELAWARE, issued to Defendant(s), Account # ending in 7614. 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 $4,137.81. 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. WHEREFORE, Plaintiff demands judgment in favor of Plaintiff and against Defendant(s) for the sum of $4,137.81 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & ASS IATES, P.C. Attorney fo 1 ' tiff A Law Firm Engage ebt Collection, BY: David I ApothaVr, Esquire Dated: 8/12/2010 Our File No.: 277459 VERIFICATION David J. Apothaker, Esquire, Esg, 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 to unworn falsification to authorities. David J. Apotaker`fsT Attorney f6( Plaintiff DATE: 8/12/2010 BARCLAYS BANK DELAWARE JERRY L MANLEY 321 CORNMAN RD CARLISLE, PA 17013-9640 STATEMENT OF ACCOUNT Debtor's Name: JERRY L MANLEY Account Number: ending in 7614 Balance Due: $4,137.81 Our File No.: 277459 EXHIBIT "A" 277459 Request for Service R. Thomas Kline Sheriff Cumberland County Office of the Sheriff One Courthouse Square Carlisle, PA 17013 Ph: 717.240.6390 Fx: 717-240-6397 Plaintiffs: Court Number: BARCLAYS BANK DELAWARE Expiration Date: Type of Action: Civil Action Defendant/s: JERRY L MANLEY Serve Upon: JERRY L MANLEY Address for Service: 321 CORNMAN RD CARLISLE, PA 17013-9640 Alternate Address for Service: Type of Service: ( ) Personal (X) Adult in Charge () Deputize () Certified Mail () Posting Special Service Instructions: * * If service is to be made by deputized service to another county please specify which county Filing Attorney Information: Name: Apothaker & Associates, P.C. Address: 520 Fellowship Road C306 Mount Laurel, NJ 08054 Telephone: 215-634-8920 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson FILED-+~`-rICE ~i ~i tr r-~~ ~.-~.s4'lT~ii~~ Sheriff Jody S Smlth .~4~°~~°_, •~j ` a°r11~rr{~~~ Chief Deputy Richard W Stewart Solicitor Barclays Bank Delaware vs. Jerry L. Manley SHERIFF'S RETURN OF SERVICE e~ S~~' (~ ~~ 8~ 5 ~ PEi~Pv,~'s't.4r~~lA Case Number 2010-5390 09/07/2010 08:27 PM -Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on September 7, 2010 at 2027 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Jerry L. Manley, by making known unto Tina Manley, Daughter of defendant at 321 Cornman Road, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $33.40 September 10, 2010 DENNI RY, DEPU SO ANSWERS, ~'~ C RON R ANDERSON, SHERIFF Our File No.: 277459 APOTHAKER 8i 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 BARCLAYS BANK DELAWARE ?r- ?, ,.? ,•? c,. r .J C[1 vJ 1-147 %! COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff VS. JERRY L MANLEY NO.: 10-5390 CIVIL Civil Action Defendant PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment against Defendant, JERRY L MANLEY, in the default of an Answer, in the amount of $4,137.81 computed as follows: Amount claimed in complaint: $ 4,137.81 Less: Amount Paid: ( 0.00) Plus: Interest from August 12, 2010 to November 10, 2010 at the legal interest rate of 0.00% per annum 0.00 Attorney fees 0.00 TOTAL $ 4,137.81 I certify that Defendant, JERRY L MANLEY, la own address is 321 CORNMAN RD CARLISLE, PA 17013-9640. r David J. Ap aker, Esq. Attorney for Plaintiff Dated: November 10, 2010 Od '?iy p?l-?fki f?olh?eerr- l? gy a s?4?no /i.0iG Y17 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS TO: JERRY L MANLEY 321 CORNMAN RD CARLISLE, PA 17013-9640 BARCLAYS BANK DELAWARE VS. Plaintiff JERRY L MANLEY Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 10-5390 CIVIL 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. 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 Our File No.: 277459 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 BARCLAYS BANK DELAWARE VS. Plaintiff JERRY L MANLEY Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 10-5390 CIVIL 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. r David J. Apothaker, Esq. Attorney for Plaintiff Dated: November 10, 2010 Our File No.: 277459 APOTHAKER 8i 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 BARCLAYS BANK DELAWARE VS. Plaintiff JERRY L MANLEY Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 10-5390 CIVIL Civil Action AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND : SS. 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 321 CORNMAN RD CARLISLE, PA 17013-9640. 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. J ry M. Snavely-Dixon, Director of the Defen?s perfData Center has sent back Ma our inquiry indicated that the Defendant(s) is/are not in Yne tar David J. Apothaker, 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. I)t ,+tteamt of t)dknse A o' I7 Gmttc Sus-30-2914 473-29 0 1ik+ay Stoma Report Pi rsrrt to the Service Members Cavil PeNdAet A4i" Duo SUiti- : Asfiiw Asowy MANLEY JERRY L Based ua die iiiimmmeo a you bffvt fxnW3ed, 4w DMDC does sot possess my iofarusa D O imkMCatrus doe irdn+ibal stabs tiltoia sexv*wd die i ionw o m d@U banks tithe Dvauxat afDdeiae Mmpawa' Dim Ceneer, bawd an the aurmahm drib }w ProvW rt tba above is the currat,truss cf die iud? as to of braaehes of the Val-rod Services (Army. Nasty. Mxoo Caps, Air Face, NOAH, Pubic Health, ad Coast Creed). Mary M Snas* Diva, Direct- Depareuamt of Dd ase - Maapan w Data Center 1600 Wisoa Mn , Suite 400 AeiV"ck,'VA 222(9-2593 The Ddaw a Ma Vower Data Caster PMDC) a ar agpokatim of the Department dDdea se that arartaiuns the Defim" Eacieera sad EJiptuity Reporting Systam (DEERS) database Mich m &E,466-1 source ofdi an ASI -y for mTtry medical cxr and other y syaoe+ns. The DoD *am* supports dw eaRimmieut of die Sexsine M®bas Civi RefdAct (50 GSC App- §§ 501 et seq, as aracmied) (SC RA) Obmedy knows as die Satherf and Saius' Ct?i ReirfAd of 1940)- DMDC has issiied b odreds of tioutsawis of 'does not possess soy ioufamottm o&cdwg bawd dw indiwind is currently on activte dray" teWaaw , and has cqm smwed a,assn error rata. In the eveat the wa+idaai tdweinxt d above, or my fw* member, fii%4, or impresainitive asrem is my mmuser due die kdwkbA is ou ac&e duty, a is odrerwise eniided to the ptcut ram of dw SCRA, you are sire * coooina fed to obtain fx6er vesi6caota of die per WG? s Iwo by cowacotg dot persons Sasioe via tine'defeaseft-mr URL ft,r j= j?Ctl95ta Ityou Wv rwience the pawn is our act aye duty ad you fir to 4, 0-i this O&Ibwrl Serviet: Vetmeatioq Pan's provisions of tie SCRA may be iatrohod apaen4 you. Set 50 VSC App. §521{c). Wv our abuw addltaaad idoranOoa 4wA die person (e.p . an SSX iipr!o wed accwwv c( DOB, a avid k ame), ym raw wbwA your request agais at this Web silt and we wiM provide a ww cert&jdr fix that gaery. This rsvowe rests attire Awity atatas indu ft dux dw ii&vwixd was ieu on active duty. lit was wiibin die paeediap 367, days. For historical iformation please contact the Service SCRA pairs-of coetact A&re iP.Awmadan on "Acorns Dsgr Sauna" Arian duty states as reported i, lis curate is ddoed i+ accardroce wkh 10 LSC § 101(di(1) Sox a period of mare than 30 e servtive days. la die tw of a member of the Nariasd Guard, ioclades service order a cal m active service ndbo&ed by the President at dw Secretary, ofDdeme for a period of mare tbw 30 c*wev iur drys wider 32 M § 502() for proposes of respaed'ug to a aaened emagwy declared by the President and supported by Federal toads, AM Active Guard Reserve (AGR) members must be nso" a&wnst an nuiborixed oursb:tabon posiion if dw not dry support. Thu tidrtdrs Navy TARS. Mac= Caps ARs and Coast Guard RPAs_ Acwe Duty maw also appies to allntonned Service member who a an active duty cownissiaoed officer of due US Public HeaU Ser%ice or the NationA Oceanic and Adaltwspberk AAiauirn Mation (NOAH Co massioned Corps) for a period cf more than 30 ccasrcoiive days- CeiwW 1-nder dw SCR.4 it Broader in Sarre Carers CmwW under the SCRA is broader in some cases and incbdes sane eakgpries afpences an adiae duty fir purposes ofdw SCRA %to w.vuid not be reported as on Acwi v Duty wider gis certiCic'ate- M4any t was arders are amended to extend the period of amvt duty, wi&A would mieM SCRA prokxbo s- Persons sedmg to rdv as this wrebste cerNicatim shmAd dheck to makt sure tie orders on whirls SCRA prow dow we based bane not been amended to cdend tie i dwive dads d service. Fwtbamore, some prooectiaos cube SCRA may wend to peisam who hne received orders so report for amm duty or to be iadxbA but who beer sot actarfg begat active duty or actarfy reported for indactsa i The Last Date ever Active Duty merry is supodant because a umber ofpraiedicas of SCRA ereaid beyond die Lut dates d active Say. Those who monad rely to the catficate we aped to seek quualfied kgak canal to away that al tights go r'steed to Sertve mewkxn under the SCRA we protected. WAR_NING_ Tbs caoi6care was, provided based an aaawitic and S&t provided by due requester- Provi ft an euaneoos rsamc or SSN writ cape on arooem certificate to be provided R.epwt MTL"h'ION4TU 277459 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY BARCLAYS BANK DELAWARE ) COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. ) JERRY L MANLEY ) NO. 10-5390 CIVIL To: JERRY L MANLEY 321 CORNMAN RD CARLISLE, PA 17013-9640 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 S1 DAVID J. AP HA R, 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: October 26, 2010