HomeMy WebLinkAbout11-6846SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson ^
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Sheriff 4w?e??, at.urttlrr,4ra
Jody S Smith 1 SEP 14 PM
Chief Deputy
Richard W Stewart rIUMBERLAND Ciia E ..,
?ENNBYL?t?',NCA
Solicitor
FIA Card Services Case Number
vs. 2011-6846
Dawn M. Alexander-Quintero
SHERIFF'S RETURN OF SERVICE
09/07/2011 03:20 PM - Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on September
7, 2011 at 1520 hours, he served a true copy of the within Complaint and Notice, upon the within named
defendant, to wit: Dawn M. Alexander-Quintero, by making known unto herself personally, at 1558 Boiling
Springs Road, Boiling Springs, Cumberland County, Pennsylvania 17007 its contents and at the same
time handing to her personally the said true and correct copy of the same.
DE IS FRY, DEP
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SHERIFF COST: $34.00
September 08, 2011
SO ANSWERS,
RON R ANDERSON, SHERIFF
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Our File No.: 323445
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
FIA CARD SERVICES, N.A.
vs.
Plaintiff
DAWN M ALEXANDER-QUINTERO
Defendant
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11 - ` f ?'T " I AIM 11: 1
7' i SL p;ND COUNT { tt
`EHN'SY VANIA
COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY
NO.: 11-6846-CIVIL
Civil Action
PRAECIPE FOR DEFAULT JUDGMENT
TO THE PROTHONOTARY:
Kindly enter judgment against Defendant, DAWN M ALEXANDER-QUINTERO, in the
default of an Answer, in the amount of $5,897.11 computed as follows:
Amount claimed in complaint: $ 5,897.11
Less: Amount Paid: ( 0.00)
Plus: Interest from August 22, 2011 to October 13, 2011
at the legal interest rate of 0.00% per annum 0.00
Attorney fees 0.00
TOTAL $ 5,897.11
I certify that Defendant, DAWN M ALEXAN QUINTERO, last known address is
1558 BOILING SPRINGS RD BOILING SPRINGS, fiA77007-9?690.
Dated: October 13, 2011
David J. Aptaaker, Esq.
Attorney for P aintiff
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OFFICE OF THE PROTHONOTARY
COURT OF COMMON PLEAS
TO: DAWN M ALEXANDER-QUINTERO
1558 BOILING SPRINGS RD
BOILING SPRINGS, PA 17007-9690
FIA CARD SERVICES, N.A.
Vs.
Plaintiff
DAWN M ALEXANDER-QUINTERO
Defendant
NOTICE
COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY
NO.: 11-6846-CIVIL
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. Apothaker, Esq. at this telephone number: 800-672-0215
Our File No.: 323445
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
FIA CARD SERVICES, N.A.
vs.
Plaintiff
DAWN M ALEXANDER-QUINTERO
Defendant
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 pei
unsworn falsification to authorities. ?i
David J.
Attorney f
COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY
NO.: 11-6846-CIVIL
es of 18 Pa.C.S.A. §4904, relating to
Iaothaker, Esq.
x Plaintiff
Dated: October 13, 2011
Our File No.: 323445
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
FIA CARD SERVICES, N.A.
vs.
Plaintiff
DAWN M ALEXANDER-QUINTERO
Defendant
COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY
NO.: 11-6846-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 1558
BOILING SPRINGS RD BOILING SPRINGS, PA 17007-9690.
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.
anpower Data Center has sent back
Mary M. Snavely-Dixon, Director of the Defe aheilitary.,,,-,
our inquiry indicated that the Defendant(s) is/are not in David J. Apo-Maker, 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
unswom falsification to authorities.
Request for Military Status
Page 1 of 2
Department of Defense Manpower Data Center Oct-13-2011 06:21:33
40 Military Status Report
Pursuant to the Service Members Civil Relief Act
Begin Active Duty Active Duty Service
Last Name First/Middle Date Status End Date Agency
Based on the information you have furnished, the
ALEXANDER- DAWN DMDC does not possess any information indicating
QUINTERO the individual status.
Upon searching the information data banks of the Department of Defense Manpower
Data Center, based on the information that you provided, the above is the current status
of the individual as to all branches of the Uniformed Services (Army, Navy, Marine
Corps, Air Force, NOAA, Public Health, and Coast Guard).
14 . 41?0_
Mary M. Snavely-Dixon, Director
Department of Defense - Manpower Data Center
1600 Wilson Blvd., Suite 400
Arlington, VA 22209-2593
The Defense Manpower Data Center (DMDC) is an organization of the Department of
Defense 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 Service Members 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 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 is on active duty, 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.htm1. If you have evidence the person is
on active duty 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).
https://www.dmdc.osd.mil/appj/scra/popreport.do 10/13/2011
Request for Military Status
Page 2 of 2
If you obtain additional information about the person (e.g., an SSN, improved accuracy
of DOB, a middle name), you can submit your request again at this Web site and we will
provide a new certificate for that query.
This response reflects active duty status including date the individual was last on active
duty, if it was within the preceding 367 days. For historical information, please contact
the Service SCRA points-of-contact.
More information on "Active Duty Status"
Active duty status as reported in this certificate is defined in accordance with 10 USC §
101(d)(1) for a period of more than 30 consecutive days. In the case of a member of the
National Guard, includes service under a call to active service authorized by the President
or the Secretary of Defense for a period of more than 30 consecutive days 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 TARs, Marine Corps ARs and Coast Guard 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) for a period of more than 30 consecutive days.
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.
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 SCRA extend
beyond the last dates of active duty.
Those who would 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 name and SSN provided by the
requester. Providing an erroneous name or SSN will cause an erroneous certificate to be
provided.
Report ID:IH3PH1013E
https://www.dmdc.osd.mil/appj/scraJpopreport.do 10/13/2011
FIA CARD SERVICES, N.A. ) COURT OF COMMON PLEAS
CUMBERLAND COUNTY
vs. )
DAWN M ALEXANDER-QUINTERO ) NO. 11-6846-CIVIL
To: DAWN M ALEXANDER-QUINTERO
1558 BOILING SPRINGS RD
BOILING SPRINGS, PA 17007-9690
Date of Notice: September 30, 2011
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 BAR ASSOCIATION
34 S. BEDFORD ST.
CARLISLE, PA 17013
717-249-3166
DAVID J. APOTHAKER, 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
323445
2172048 t,"F`ra° JTr.i,
GORDON & WEINBERG, P.C. ``'�° NOY 21 ���j�; � 3
BY: FREDERIC I . WEINBERG, ESQUIRE ! r J CO� ,__,r
Identification No. : 41360 ✓ pEr '�SY��'A 0U;;
JOEL M. FLINK, ESQUIRE
Identification No. : 41200
1001 E. Hector Street, Ste 220
Conshohocken, PA 19428
484/351-0500
FIA CARD SERVICES, N.A. COURT OF COMMON PLEAS
CUMBERLAND COUNTY
VS . DOCKET NO. : 11-6846-CIVIL
DAWN M ALEXANDER-QUINTERO
ENTRY OF APPEARANCE
TO THE PROTHONOTARY:
Kindly enter my appearance on behalf of the plaintiff in the
above-captioned matter.
GORDON & WEINBERG, P. C.
BY:
FREDER I . WEINBERG, ESQUIRE
JOEL M. FLINK, ESQUIRE
Attorney for Plaintiff
P012
CERTIFICATION OF SERVICE
I, FREDERIC I . WEINBERG, ESQUIRE, hereby certify that I, on
the date below, served a copy of the Substitution of Attorney and
Entry of Appearance Pursuant to Pa. R.C. P. 1028 (c) (1) , via First
Class Mail, postage pre-paid, to all other parties or their
counsel of record.
F I. WEINBERG, ESQUIRE
Dated: ((l/�/j