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HomeMy WebLinkAbout10-7881Odr File No.: 298660 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 CHASE BANK USA, N.A. 200 WHITE CLAY CENTER DRIVE NEWARK, DE 19711 Plaintiff, VS. KEMAL PEGRAM 597 W NORTH ST CARLISLE, PA 17013-2223 Defendant. R 2110 DEC 28 t, "UIMBERLANo COA? REINNSYLVA [wf.k. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 16--? F9 I Ci('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 © 00V 061 ????a goy Q? . Our File'No.: 298660 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 CHASE BANK USA, N.A. 200 WHITE CLAY CENTER DRIVE NEWARK, DE 19711 Plaintiff, vs. KEMAL PEGRAM 597 W NORTH ST CARLISLE, PA 17013-2223 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is CHASE BANK USA, N.A., 200 WHITE CLAY CENTER DRIVE, NEWARK, DE 19711 2. Defendant(s) is/are KEMAL PEGRAM, an adult individual residing at 597 W NORTH ST CARLISLE, PA 17013-2223. 3. At the special instance and request of Defendant, Plaintiff, CHASE BANK USA, N.A., issued to Defendant(s), Account # ending in 3527. 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 $3,960.13. 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 $3,960.13 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & Attorney A Law Firm Eniz RTES, P.C. Debt BY: David J. Apokaker, Esquire Dated: 12/15/2010 Our File No.: 298660 VERIFICATION David J Apothaker Esquire Es q. 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 The undersigned understands that the statements therein are made subject to the penalties of 18 Pa.C.S.A. ing to unworn falsification to authorities. David J. ApotlvCe-r, Esquire Attorney for Plaintiff DATE: 12/15/2010 CHASE BANK USA, N.A. KEMAL PEGRAM 597 W NORTH ST CARLISLE, PA 17013-2223 STATEMENT OF ACCOUNT Debtor's Name: KEMAL PEGRAM Account Number: ending in 3527 Balance Due: $3,960.13 Our File No.: 298660 EXHIBIT "A" SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor 1-1 H m 7 T11E. i' f `°? 2011 JA -7 P 12: 4'1 Chase Bank USA, N.A. vs. Kemal Pegram Case Number 2010-7881 SHERIFF'S RETURN OF SERVICE 12/28/2010 08:50 PM - Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on December 28, 2010 at 2050 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Kemal Pegram, by making known unto himself personally, at 597 W. North Street, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to him personally the said true and correct copy of the same. i- R ERT BITNER, DEPUTY SHERIFF COST: $33.40 January 04, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF J -# Our file No.: 298660 J Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff r1%3TH0NOTAR`i 2011 FEB 28 Am 8* 12 UMBERLAND COUNTY k.PENNSYLVANIA CHASE BANK USA, N.A. Plaintiff, vs. KEMAL PEGRAM Civil Action STIPULATION IN LIEU OF JUDGMENT Defendant. The matters and things in controversy having been discussed by and between the parties, and a settlement having been agreed upon: It is on February 03, 2011, STIPULATED by and between CHASE BANK USA, N.A. ("Plaintiff') and KEMAL PEGRAM ("Defendant"), as follows: 1. Plaintiff filed suit in the above captioned matter seeking damages in the amount of $3,960.13. 2. Defendant agrees to pay to Plaintiff the sum of $3,960.13, which sum Plaintiff agrees to accept in full settlement of its claim herein. 3. As of this date, payments totaling $0.00 have been applied to the aforementioned sum. 4. Defendant shall remit payment(s) in the following manner: a. $415.00 to be paid on or before February 25, 2011; b. $101.29 to be paid on or before the 25th day of each month, beginning March 25, 2011 until paid in full. 5. All checks shall be made payable to "CHASE BANK USA, N.A.", and sent to the office of Plaintiff's attorney, Apothaker & Associates, P.C., located at the following address: Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 COURT OF COMMONS PLEAS CUMBERLAND COUNTY DOCKET NO.: 10-7881-CIVIL 1 y .. 6. In the event Defendant fails to pay in accordance with the terms set forth in this Stipulation and the default is not cured within ten (10) days, then Plaintiff shall be entitled to obtain the entry of Judgment against Defendant in the suit amount specified in paragraph one (1) of this stipulation less any sums paid pursuant to this Stipulation, upon ex parte application, with supporting certification, and with notice to Defendant in the form of a copy of the application addressed to Defendant by first-class, postage prepaid. We hereby consent to the form and entry of the thin Stipulation. B Be ' J. Cavallaro, Esquire omey ID# 307949 pothaker & Associates, P.C. Attorneys for Plaintiff By: ) KEMAL P M Defendant 2 Our File No.: 298660 Mc M = APOTHAKER & ASSOCIATES, P.C. xrn WW i -,?; BY: David J. Apothaker, Esquire cnp Attorney I.D.# 38423 rte- ; 520 Fellowship Road C306 v? Mount Laurel, NJ 08054 yz-, w (800) 672-0215 -; a Attorney for Plaintiff CHASE BANK USA, N.A. COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff, vs. KEMAL PEGRAM Defendant. NO. 10-7881-CIVIL PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER SOCIATES, P.C. Attorn s r Plaintiff A Law Firm En al in Debt Collection By: David J. Ap ker, Esquire Dated: 5/8/2012 111111111111111111111111111111