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Home My WebLink About10-5612.' -Our File No.: 287586 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 AMERICAN EXPRESS CENTURION BANK 4315 S 2700 WEST SALT LAKE CITY, UT 84184 Plaintiff, vs. RICHARD ROSWOG 666 STATE ST LEMOYNE, PA 17043 Defendant. C?F Tt-4 a `f , i? }` 30 P t? 25 CUMBEFit,AN D C? `iTY f?Ni?SYL COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 10 - 5(pla 0,-t V?1Te,m 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 PA A`MI As t85 a y 7q &o I . % Our File No.: 287586 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 AMERICAN EXPRESS CENTURION BANK 4315 S 2700 WEST SALT LAKE CITY, UT 84184 Plaintiff, vs. RICHARD ROSWOG 666 STATE ST LEMOYNE, PA 17043 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. CIVIL ACTION COMPLAINT FIRST COUNT I . Plaintiff is AMERICAN EXPRESS CENTURION BANK, 4315 S 2700 WEST, SALT LAKE CITY, UT 84184. 2. Defendant(s) is/are RICHARD ROSWOG, an adult individual residing at 666 STATE ST LEMOYNE, PA 17043. 3. At the special instance and request of Defendant, Plaintiff, AMERICAN EXPRESS CENTURION BANK, issued to Defendant(s), Account # ending in 4003. 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 $1,408.67. 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. A1thQugh 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 $1,408.67 and requests this Court award costs to the extent permitted by applicable law. APOTH=E SSOCIATES, P.C. Atttaked ey or Plaintiff A Law Firm in Debt Collection BY: David J. A`pothaker, Esquire Dated: 8/13/2010 Our File No.: 287586 i 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 relang to unsworn falsification to authorities. David J. Apothak , Attorney for Pl ' ti DATE: 8/13/2010 AMERICAN EXPRESS CENTURION BANK RICHARD ROSWOG 666 STATE ST LEMOYNE, PA 17043 STATEMENT OF ACCOUNT Debtor's Name: RICHARD ROSWOG Account Number: ending in 4003 Balance Due: $1,408.67 Our File No.: 287586 EXHIBIT "A" SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor American Express Centurion Bank Case Number vs. Richard S. Roswog 2010-5612 SHERIFF'S RETURN OF SERVICE 09/14/2010 05:51 PM - Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on April 14 2010 at 1751 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Richard Roswog, by making known unto himself personally, at 666 State Street, Lemoyne, Cumberland County, Pennsylvania 17043 its contents and at the same time handing to him personally the said true and correct copy of the same. MI HAEL BARICK, DEPUTY / SHERIFF COST: $42.40 September 15, 2010 SO ANSWERS, RONW R ANDERSON, SHERIFF .77 `J :TIM Cn C7 ' - ' Co ) " LI C - { 47 i Our File No.: 287586 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 AMERICAN EXPRESS CENTURION BANK Plaintiff VS. RICHARD ROSWOG Defendant Civil Action PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment against Defendant, RICHARD ROSWOG, in the default of an Answer, in the amount of $1,408.67 computed as follows: Amount claimed in complaint: $ 1,408.67 Less: Amount Paid: ( 0.00) Plus: Interest from August 13, 2010 to November 5, 2010 at the legal interest rate of 0.00% per annum 0.00 Attorney fees 0.00 TOTAL 4 $ 1,408.67 I certify that Defendant, RICHARD ROSWOG,14sttown address is 666 STATE ST LEMOYNE, PA 17043. I Dated: November 5, 2010 41tl. dd fi#? ?,O&ht4 W- 044 ;MtV F° FF; E TH7 Clul"IBEI-J- 'A' r•n q?n E^4l! j) 'ti COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 10-5612 CIVILTERM David J. Apoth er, Esq. Attorney for Plaints OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS TO: RICHARD ROSWOG 666 STATE ST LEMOYNE, PA 17043 AMERICAN EXPRESS CENTURION BANK Plaintiff VS. RICHARD ROSWOG Defendant NOTICE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 10-5612 CIVILTERM 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. Anothaker, Esq. at this telephone number: 800-672-0215 Our File No.: 287586 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 AMERICAN EXPRESS CENTURION BANK COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff vs. RICHARD ROSWOG Defendant NO.: 10-5612 CIVILTERM 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 f 18 Pa.C.S.A. §4904, relating to unsworn falsification to authorities. David J. Apo er, Esq. Attorney for Plaintiff Dated: November 5, 2010 Our File No.: 287586 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 AMERICAN EXPRESS CENTURION BANK Plaintiff VS. RICHARD ROSWOG COURT OF COMMON PLEAS OF CUMBERLAND COUNTY } } } NO.: 10-5612 CIVILTERM Civil Action Defendant 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 666 STATE ST LEMOYNE, PA 17043. 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. n Mary M. Snavely-Dixon, Director of the Defse anpow Data Center has sent back our inquiry indicated that the Defendant(s) is/are not i4 the j?nilitaq( David J. Apothake_`r 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)eparttuett dDdeme Maapaws Data Crater ?a+r 45-:018 0814:20 snowy Sta6r Repast Patsuaw to the Service Members Canal RddAd v 3 -;, ? ??tt?a D? Aa1re? fir?.fuA>at ? «Atgh+a? k? lialri ? ';fir ROSWOG RICHARD Based on the mformaoom You have f rwshed, tbt DMDC don sot possess say w(onnadoa tee indn UNA mt- Upon o - d ing 16e irEorrraeba data banks tithe D epattreeat of Define Manpower Data Career, based oo the is£omsr6m That )me provided the above is tic crarent stator dbe im&Ad al as to err branclim dihe L;aiaemed Smices (Amt', Navy, Marine Carps, Air Force, NOAA, Pubic Hedt and Cost Guwd). A131 it Mary M Ssar sty-Dboam, Director Dque tsed of Ddme - Manpower Data Cater 1600 MamBhd.. Sete 400 Asliq os. VA 22209.2393 The Defaaese Manpower Data Canter (D%M )C) a anmpa mom save Depaaaomat dDdme that oat um the Defieuse Faallmard and EliplOy Rcpaftw System 9EEKS) ddab asc wtich a the amat source of dda on ciOAy for military medical care and adwr efVW syebesaa, The DoD s =qoy supports Abe asfinee went of Ilse Service Members Civi Relief Ad (50 USC App. ¢§ 501 et seq as amended) (SCIlA) t bmedy imaxm a tee Soldiers; and Sauer CAS RzWAd of 1980) DMDC bed issred l nadteds of thcummds of 'does ant possess my' ors 4 6&ca6ot tint doe imbvWmd is tau uty ea active ddq' reWcosm sad hu cVc mctd a smack error tale. In toe evear the iarbvis W rtferenced above, or any Eaaailr sommim, Mead, or sapresm aim asserts arty mom that the iaa8ai3ad is on, active dity, at is adws iest entided to the prooertioes of tee SCRA. we Mmg#y a scum to obtain fatt6er tes?icaooa duo paanaa's tiapr by cattacdai tat peaods 5ervide via Oar "dtitml' URL btka.(vww " If you have oideam d w person is cc active duty mad yon sit wa obtain skis ad36omd Service v'1!rilkmlio4 pie pcaeideas tithe SCRA may be iav'oked against yon. See 50 L'SC App.. 3131 d). V yon obt+ia adMoad Wmmmlitm about dw person (t t, so SS*i, iapnaved accuracy of 1M, a aTidde mmre), yea cm wbam your request again d dis Web sift and we vol provide a new eerti6rs8e fix that query Tbo nwome reflects active Awly statss ado&* date the individual was last on acwt duty, Is was ,zap the preceding 36" drys. For laimicA infioCmalion please contact the Service SCRA points-of euntact. Mom iMAr a on "Actim ZNW Smwr Active $tY testes repod6od in this cati6oate is netted in accordance with 10 L'SC f 101(4)(1) for a peed of snore din 30 eomeeuOve dayr. In tee case t( a neater of the Vatiood Crowd, kd tadm service under a sal to active service a dw&ed by &e Pteaideet a the Secretary of Ddmme hoc a period of mm than 30 consecutive days under 32 V$C § 5020 Sot pugxxm of respoadig to a eartionaas emerpeacy declared by sae President and supported by Federal fords. AN Ac*vc Gard Resent (AGR} members amt be assigned momast an authorized mobiLution position in tae sand tarry support. This iacudes Navy T'ARs. 4lenink Caps Alts and Coast Guard RPAs. Am-e Duty stales also nppin to a Untamed Service member who is an active duty cauanisoicced officer of the U.S. Pubk Health Service or d Nariooaal Oceanic aped Atmospitcdic Adminimmica (NOM siceiedd Corps) for a period a'mor'e than 30 coosecubvc days. C'vw^w t nder floe SM4 it Am der iw Sonar Cato Coverage under ere SCRA is broader in some cues sad iocisdes some categories of passed on acth-c duty for purposes cffor SCRA %to would rot be reported as an Active bat) under this certfiralt. Many tamrs orders we amended to extend the pound d£active duty, whist would cdcad SCRA protections. Perum seeking to rely oa die wed cei1f16cadw Amid dbecic to make sere the orders an which SCRA proomtiam ace based bow not been amended io cadent doe kdaaive dtues of service. Fu dwrosore, same pcotecbm den SCRA malt extend to persom who have received ardess so repot Ica' active day or to be Wocted„ but who have sot Seto* begot active duty or actually reported for madocfoa The Lett Date an Active Doty tufty is inspottant because a amber ofp n*ectios of SCRA es2md beyond the last dates of=*.ie duty, Those who world rely on tors daulitaee air urged to seelc gasified legal counsel to emme fleet A rights guaranteed to Service neuters under the SCR0. we protected R`AMNL?lCr. Tbn cafficate was provided based an a nmw and SSN provided by the requests. Providing an emaneom now at SSN wil arse an eaameous cerbillicate to be provided. Repot IDEBCHP23FAO 287586 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY AMERICAN EXPRESS CENTURION BANK ) COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. ) RICHARD ROSWOG ) NO. 10-5612 CIVILTERM To: RICHARD ROSWOG 666 STATE ST LEMOYNE, PA 17043 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 DAVID J. AP T 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 08, 2010