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Home My WebLink About14-2844 Supreme C ;>t of Pennsylvania A Court+of�Co�mmo _Pleas For Prothonotary Use Only: Cii11Co a Sheet ' S4«.- w r Docket No: t CUMBkl AND S County �y t tin The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the filing and service ofpleadings or other papers as required by law or rules of court. Commencement of Action: S X Complaint El Writ of Summons -1 Petition El Transfer from Another Jurisdiction -i Declaration of Taking E C Lead Plaintiff's Name: Lead Defendant's Name: CAPITAL ONE BANK(USA)N.A. THOMAS N KOUNAS T Dollar Amount Requested: Mwithin arbitration limits I Are money damages requested? Ix; Yes 0 No (check one) Ooutside arbitration limits O N Is this a Class Action Suit? E3 Yes (D No Is this an MDJAppeal? 0 Yes rXs No A Name of Plaintiff/Appellant's Attorney: ARTHUR LASHIN ESQ#23425 0 Check here if,you have no attorney(are a Self-Represented [Pro Se] Litigant) Nature of the Case: Place an"X"to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim,check the one that you consider most important. TORT(do not include Mass Tort) CONTRACT(do not include Judgments) CIVIL APPEALS 0 Intentional El Buyer Plaintiff Administrative Agencies La' Malicious Prosecution x Debt Collection:Credit Card 0 Board of Assessment Motor Vehicle -: Debt Collection: Other ❑ Board of Elections Nuisance Dept.of Transportation S Premises Liability Statutory Appeal:Other 0 Product Liability(does not include E mass tort) I...' Employment Dispute: Slander/Libel/Defamation Discrimination C Other: 0 Employment Dispute:Other Zoning Board El ,I, I [3 Other: O MASS TORT C_l Asbestos N =i Tobacco 0 Toxic Tort-DES F1 Toxic Tort-Implant REAL PROPERTY MISCELLANEOUS E] Toxic Waste Ejectment U Common Law/Statutory Arbitration B 0 Other: ❑ Eminent Domain/Condemnation L_l Declaratory Judgment I. 11 Ground Rent I-i Mandamus 0 Landlord/Tenant Dispute 0 Non-Domestic Relations 0 Mortgage Foreclosure:Residential Restraining Order PROFESSIONAL LIABLITY 0 Mortgage Foreclosure:Commercial 13 Quo Warranto 1.1 Dental 0 Partition 0 Replevin O Legal O Quiet Title U Other: Medical Other: Other Professional: Updated 1/1/2011 CUMBERLANo COUNTY PENNSyLVAN1A LAW OFFICES OF HAYT, HAYT & LANDAU, LLC By: Arthur Lashin, Esquire Identification No. 23425 123 S . Broad Street Attorney for Plaintiff Suite 1660 Philadelphia, PA 19109-1003 (215) 928-1400 OUR FILE NO. 494378 CUMBERLAND COUNTY CAPITAL ONE BANK (USA) , N.A. COURT OF COMMON PLEAS CIVIL DIVISION 4851 COX ROAD GLEN ALLEN, VA 23060 VS. TERM. THOMAS N KOUNAS 84 SILVER CROWN DR ' MECHANICSBURG PA 17050 No. CIVIL ACTION "NOTICE "AVISO "You have been sued in court. If you wish to defend against "Le han demandado a usted en la corte. Si usted quiere the claims set forth in the following pages,you must take action defenderse de estas demandas expuestas en las paginas siguientes, within twenty(20)days after this complaint and notice are served, usted tiene veinte(20)dias,de plazo al patir de la fecha de la by entering a written appearance personally or by attorney and demanda y la notificacidn. Haoe faita asentar una comparencia filing in writing with the court your defenses or objections to the escrita o en persona o con un abogado y entregar a la corte an claims set forth against you. You are warned that if you fail to do forma escrita sus defenses o sus objeciones a las demandas en so the case may proceed without you and a judgment may be en- contra de su persona. Sea avisado qua si usted no se defiende,la tered against you by the court without further notice for any mon- corte tomara medidas y puede oontinuar la demanda en contra ey claimed in the complaint or for any other claim or relief request- suya sin previo aviso o notificacidn. Adem6s,la corte puede ed by the plaintiff. You may lose money or property or other rights decidir a favor del demandante y requiere que usted cumpla con important to you. todas las provisions de este demanda. Listed puede perder dinero IF YOU CANNOT AFFORD TO HERE A LAWYER THES OFFICE MAY BE o sus propiedades u otros derechos importantes para usted. ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT "LLEVE ESTA DEMANDA A UN ABOGADO MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE IMMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO ORNOFEE TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECC16N SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR CUMBERLAND COUNTY BAR ASSOCIATION ASISTENCIA LEGAL. 2 LIBERTY AVENUE 0 CARLISLE PA, 17013 � 717-249-3166 CIVIL ACTION 1 . Plaintiff CAPITAL ONE BANK (USA) , N.A. is a business entity, with offices located at: 4851 COX ROAD, GLEN ALLEN, VA 23060 . 2 . Defendant (s) THOMAS N KOUNAS is/are individual (s) residing at: 84 SILVER CROWN DR, MECHANICSBURG, PA 17050 . 3. Upon application by Defendant (s) a Credit/Revolving Charge Account was established for Defendant (s) , which was assigned account number ************6083 . 4 . Defendant (s) subsequently utilized the aforesaid account to make various purchases and/or receive cash advances, thereby incurring payment obligations to Plaintiff and/or Plaintiff' s predecessor in interest . 5. Defendant (s) defaulted by failing to adhere to repayment terms and in accordance therewith, the entire remaining balance became due and immediately payable. 6. As a consequence of the foregoing there is presently due and owing to Plaintiff by Defendant (s) the following amounts (see Exhibit "A" ) Unpaid Balance: $19, 401 . 30 Credits: $ . 00- TOTAL DUE: $19, 401 . 30 7 . Despite demand by Plaintiff, Defendant (s) has/have failed and refused to pay the aforesaid sum. WHEREFORE, Plaintiff demands that judgment be entered against Defendant (s) in favor of Plaintiff in the amount of $19, 401 . 30 together with costs . LAW OFFICES OF HAYT, HAYT & LANDAU, LLC r By: ARTHUR LASHIN 23425 Attorney for Plaintiff This communication is from a debt collector. This is an attempt to collect a debt and any information obtained will be used for that purpose. 1 CYCLE # 13 CAPITAL ONE CYCLE FACSIMILE REPORT 08/14/2013 - 09/13/2013 PAGE 3853 ACCT-ID: 02177546872 CARD# 5291497845686083 STMT-TYPE: ENGLISH REWARDS: N TPC: MP HOLD: 000 SAC-PGM: PREV-BALANCE: $19,157.39 PYMTS&CREDITS $0.00 INTR CHRGS $243.91 TRANSACTIONS: $0.00 NEW-BALANCE : $19,401.30 MINIMUM PYMT $3,476.00 LATE FEE $0.00 DUE-DATE 10/10/2013 CREDIT-LIMIT: 18000 CREDIT-AVAIL 0.00 CASH-LIMIT 7500 CASH-AVAIL 0.00 RPAY-TOTMTHS: 337 RPAY-TOTCOST $38,952.77 36MA-MTHPAY: $671.60 36MA-TOTCOST: $24,177.70 INTEREST-CTD: $243.91 INTEREST-YTD $2,079.30 FEE-AMT-CTD: $0.00 FEE-AMT-YTD $175.00 HIGH-LATEFEE: $35.00 HIGH-PNLTY-APR: 29.40% OVERALL-APR: 0.000 CLOSE-DATE LP,BRAILLE PREF: INS-CS: CHRGOFF-DATE: OOB: N MISS-ADDR: N BK-HOLD: N BANKRUPTCY: N LEGAL: N CTC-CHG-IND: NEW: N EBPP: N ARCH: N REASON: 00 HARDCOPY: 04 ACTIVE WATCH: WO CRED-RVK: PD CUR-PD: 07 CTC IND: INS: RETURN-MAIL: CLOSE: CHARGED-OFF: XFER: FRAUD: OL: 01 MULTI-IND: S PROV-ID: 000001 US PROF-CNTR: 0000000001 COB SERVICE-OWNER: 000023 Superprime OL-OPTIN-IND: MESSAGE-IDS: 00036 TBAL C/I BALANCE AMOUNT RATE CORR APR INTEREST CHRGS THOMAS N KOUNAS Purchases 0001 01 19,275.17 00.0408200 0014.900000000 243.91 84 SILVER CROWN DR Cash Advances 0002 00 0.00 00.0216400 0007.900000000 0.00 MECHANICSBURG PA 17050163584 US ACCOUNT BRAND DATA - ODS & SIMS BRND VNR PLCY ID: 00000000000 CUST SERV CONT PLCY ID: 00000000000 CPN CAL ID 0101 RWDS DISPLAY IND: Y BRND NAME BRND LOGO ID: 001 BRND DISPLAY IND: Y NH ALLWD IND Y CPN CODE NSC207 MINI CPN CODE: NSMC13 REMIT CPN CODE NSRC03 ODS RWDS URL ODS RWDS PHN GEN SERV URL www.capitalone.com/solutions GEN SERV PHN 1-800-258-9319 REWARDS COUPON CODES MILES CPN CODE : NSC320 CASH CPN CODE: NSC340 POINTS CPN CODE NSC330 TRANSACTION DATA SUMMARY NAME: THOMAS N KOUNAS CUST TYPE: 0 PRINT AREA: 001 NUM OF CREDITS: 00000 AMT OF CREDITS: $0.00 NUM OF PYMTS 00000 AMT OF PYMTS $0.00 NO CREDIT TRANSACTIONS FOR THIS CYCLE NAME: THOMAS N KOUNAS CUST TYPE: 0 PRINT AREA: 020 NUM OF DEBITS 00000 AMT OF DEBITS $0.00 NO DEBIT TRANSACTIONS FOR THIS CYCLE Department of Defense Manpower Data Center RI1N as of:API-23-201404:0246 AM The Defense Manpower Data Center DMDC is an organization of the Department of Defense DoD that maintains the Defense Enrollment and Eligibility P P P ( > s p ( ) s' v 6LRA 3.0 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 Servicemembers Civil Relief Act(50 USC App.§501 of 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 StatYLS Report individual is currently on active duty"responses,and has experienced only a small error rate.In the event the individual referenced above,or any family Pursuant to ServicerrietIlben Civil Relief Act member,friend.or representative asserts in any manner that the individual was on active duty for the active duty status date,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:hftp://w .defenselink.miVfaq/pis/PC09SLDR.html.If you have evidence the person was on active duty for the active duty status Last Name:KOUNAS date and you fail to obtain this additional Service verification,punitive provisions of the SCRA maybe invoked against you.See 50 USC App.§521(c). First Name:THOMAS N This response reflects the following information:(1)The individual's Active Duty status on the Active Duty Status Date(2)Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Dale(3)Whether the individual or his/her unit received early notification to report for active Middle Name: duty on the Active Duty Status Date. Active Duty Status As Of:Apr-23-2014 More information on"Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC§101(d)(1).Prior to 2010 only some of the active duty periods less on Aame Duy on Aviva Dory slaws pale than 30 consecutive days in length were available.In the case of a member of the National Guard,this includes service under a call to active service Alive o sun Dam Annie Du Em Dale sums semce co authorized b the President or the Secreta of Defense under 32 USC 502 f for purposes of responding to a national emergency declared b the NA NA No Y Secretary § () P P P 9 r9 Y Y President and supported by Federal funds.All Active Guard Reserve(AGR)members must be assigned against an authorized mobilization position in the TNs response re0ecls me mdwid.W acme du scows oases an me Active Duty wawa Dam unit they support.This includes Navy Training and Administration of the Reserves(TARs),Marine Corps Active Reserve(ARs)and Coast Guard Reserve Program Administrator(RPAs).Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Left Acme Duty WiNin 367 Days of Alive Duty status Date Public Health Service or the National Oceanic and Atmospheric Administration(NOAH Commissioned Corps). Al—Duty Start Data Aclrve Du End Dale Scows Sernee CoP nenr NA NA No NA Coverage Under the SCRA is Broader in Some Cases Tnis response renenla cancra lna individual len stove du status wimin 367 da ii renes ine A—I Di,tv smwz pate 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.SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Tne Member or Hi 11 unit was Notified ma Fumra LOWi,m Active Duty on AClve Duty sums Dam Title 32 periods of Active Duty are not covered by SCRA,as defined in accordance with 10 USC§101(d)(1). 1N Nobrka,n Start Dale Drder NotiOcalion E,Dam I staixis I Se Com nt NA NA I No I NA Many times orders are amended to extend the period of active duty,which would extend SCRA protections.Persons seeking to rely on this website Tnis,asPoasa scants wlremer Ina immiouai or-ha,Pan nus 1--d cony-noon con m-d mr anme duty 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 the SCRA Upon searching the data banks of the Department of Defense Manpower Data Center,based on the information that you provided,the above is the status of extend beyond the last dates of active duty. the individual on the active duty status date as to all branches of the Uniformed Services(Army,Navy,Marine Corps,Air Force,NOAA,Public Health,and Coast Guard).This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA 14 are protected J-1. t4 WARNING:This certificate was provided based on a last name,SSN/date of birth,and active duly status dale provided by the requester.Providing erroneous information will cause an erroneous certificate to be provided. Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center Certificate ID:G9G116F1OOFEOFO 4800 Mark Center Drive,Suite 041125 Arlington,VA 22350 CAPITAL ONE BANK(USA),N.A., Plaintiff, V. THOMAS N KOUNAS Defendant(s). AFFIDAVIT PERSONALLY APPEARED before the undersigned officer,duly authorized to administer oaths,Lola Buafo,who states under oath as follows: 1. I am over 18 years old and competent to testify to the matters set forth herein. I am an employee of Capital One Services,LLC,("COSLLC"),an agent and affiliate of Plaintiff CAPITAL ONE BANK(USA), N.A.("Capital One").COSLLC provides services to Capital One in connection with its credit card and related banking practices and my job responsibilities as Litigation Support Representative provide me with access to all relevant systems and documents of Capital One needed to validate the below information. I am authorized by Capital One to testify to the matters set forth herein. As a result of the scope of my job responsibilities,I have personal knowledge of the manner and method by which Capital One creates and maintains certain business books and records,including computer records of customer accounts. 2. The Capital One books and records are made in the course of Capital One's regularly conducted business activity and it is a regular practice of Capital One to make these books and records. Each of the Capital One books and records reviewed are made: (1)at or near the time the events they purport to describe occurred,by a person with knowledge of the acts and events;or,(2)by a computer or other similar digital means,which contemporaneously records an event as it occurs. 3. According to the books and records of Capital One,a Capital One account was opened in Defendant's(s')name for the purpose of obtaining an extension of credit. Subsequently,this account was used to acquire goods,services or cash advances in accordance with the Customer Agreement governing use of that account. Defendant(s)have failed to make the required periodic payments on the account. 4. The books and records of Capital One show that Defendant(s)is/are currently indebted to Capital One on account number XXXXXXXXXXXX6083 for the just and true sum of$19401.30 as of 04/21/2014,and that all offsets,payments,and credits have been allowed. This balance is comprised of Defendant's(s')outstanding debt on the date the account charged off(including any pre-charge-off transactions,interest,and/or fees)less any offsets, payments,or credits applied to the account after the charge-off date. 5. Nothing in the books and records of Capital One indicate or show that the Defendant(s)is/are a minor/minors,is/are mentally incompetent or is/are otherwise incapacitated. 6. I declare under the penalty of perjury that the foregoing is true and correct and if called as a witness I would competently testify,under oath,thereto. Given under my hand on: 3 a Dated: � )- / Lola Buafo County of Chesterfield,to wit: Commonwealth of Virginia SUBSCRIBED and sworn to before me,the undersigned Notary Public in and for the jurisdiction aforesaid, by Lola Buafo,who is personally known to me and who acknowledged before me his/her signature to the foregoing Affidavit. GIVEN under my hand and seal this day of �'� ,201 Notary Public + Q,TRITJ�� . TARY�"••AOr`. QpUBO : REG#326650 . N00000042594108 's MY COMM15SlON a 2. 545083503 %'� 71EXPIRES3112015 A088 .......... 0 HAYTo HAYT&LANDAU L'f � ,. .` 2 a CAPITAL ONE BANK(USA),N.A., Plaintiff, V. THOMAS N KOUNAS Defendant(s). VERIFICATION The undersigned does hereby verify subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities,that I am an employee of Capital One Services,LLC,and agent and affiliate of CAPITAL ONE BANK(USA),N.A.,Plaintiff herein,that I am duly authorized to make this Verification,and that the facts set forth in the attached Affidavit are true and correct to the best of my knowledge,information and belief and is based upon information which Plaintiff has furnished to counsel. I understand the attached Affidavit will be incorporated by reference into the Complaint in Civil Action filed in this matter. The language in the Complaint is that of counsel and not of Plaintiff. To the extent that the contents of the Complaint are that of counsel and are relevant to this Verification,Plaintiff has relied upon counsel in making thb s Veri Dated: l —c �—# 9 n�"C�-" Lola Buafo N00000042594108 545083503 A088 HAYT,HAYT&LANDAU N00000042594108 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson r- Sheriff ' ti�� THE PROTHONOTARY Jody S Smith Chief Deputy Richard W Stewart Solicitor QFF}.c °FIRE $SER 2614 MAY 14 HI 10 CUMBERLAND COUNTY PENNSYLVANIA Capital One Bank (USA) N.A. vs. Thomas Kounas Case Number 2014-2844 SHERIFF'S RETURN OF SERVICE 05/12/2014 08:15 PM - Deputy Dawn Kell, being duly sworn according to law, served the requested Complaint & Notice by "personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Thomas Kounas at 84 Silver Crown Drive, Silver Spring Township, Mechanicsburg, PA 17050. SHERIFF COST: $39.30 DAWN KELL, DEPUTY SO ANSWERS, May 13, 2014 RONNS' R ANDERSON, SHERIFF c) CountySuite Sheriff, Teleosoft, Inc. Nicholas Law Offices, PC Steve C. Nicholas, Esquire Pa. Supreme Court ID #06845 2215 Forest Hills Drive, Suite 37 Harrisburg, PA 17112-1099 (717) 540-7746 - phone (717) 541-1527 - fax steve_nicholas@comcast.net Attorney for Defendant CAPITAL ONE BANK (USA), N.A. 4851 Cox Road Glen Allen, VA 23060 Plaintiff v. THOMAS N. KOUNAS 84 Silver Crown Drive Mechanicsburg, PA 17050 Defendant �.{ E FRC iNONt rA 2WE4 JUN -3 !J1 9: 25 CUMBERLAND COUNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA No. 14-2844 - CV ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter the appearance of the undersigned on behalf of the Defendant Thomas N. Kounas the above captioned matter. Dated: `' ) 2014 NICHOLAS LAW OFFICES, P.C. By: Steve C. Nicholas, Esquire Pa. Supreme Court ID #06845 2215 Forest Hills Drive, Suite 37 Harrisburg, PA 17112-1099 Attorney for Defendant Nicholas Law Offices, PC Steve C. Nicholas, Esquire Pa. Supreme Court ID #06845 2215 Forest Hills Drive, Suite 37 Harrisburg, PA 17112-1099 (717) 540-7746 - phone (717) 541-1527 - fax steve_nicholas@comcast.net Attorney for Defendant CAPITAL ONE BANK (USA), N.A. 4851 Cox Road Glen Allen, VA 23060 Plaintiff v. THOMAS N. KOUNAS 84 Silver Crown Drive Mechanicsburg, PA 17050 Defendant r' ILED-'`w('¢i ICE I� (ir THE r-RO I HO O FA1- vi Mit JUN -3 AM : 26 CUMBERLAND COUNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA No. 14-2844 - CV NOTICE TO PLEAD You are hereby notified to file a written response to the enclosed Answer within twenty (20) days from service hereof or a judgment may be entered against you. NICHOLAS LAW OFFICES, P.C. By: vC� Steve C. Nicholas, Esquire I.D. No. 06845 2215 Forest Hills Drive, Suite 37 Harrisburg, PA 17112-1099 I -� (717) 540-7746 Dated: "�'"k 3 2014 Attorney for Defendant f Nicholas Law Offices, PC Steve C. Nicholas, Esquire Pa. Supreme Court ID #06845 2215 Forest Hills Drive, Suite 37 Harrisburg, PA 17112-1099 (717) 540-7746 - phone (717) 541-1527 - fax steve_nicholas@comcast.net Attorney for Defendant CAPITAL ONE BANK (USA), N.A. 4851 Cox Road Glen Allen, VA 23060 Plaintiff v. THOMAS N. KOUNAS 84 Silver Crown Drive Mechanicsburg, PA 17050 Defendant IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA No. 14-2844 - CV DEFENDANT'S ANSWER TO PLAINTIFF'S COMPLAINT AND NOW, Defendant Thomas N. Kounas, by and through her attorneys, Steve C. Nicholas, Esquire and the Nicholas Law Offices, PC, files this Answer to Plaintiff's Complaint, and in support thereof, aver the following: 1. After reasonable investigation, Defendant is without sufficient knowledge or information to form a belief as to the truth of the matter averred in this paragraph, and strict proof thereof is demanded at trial. 2. Admitted. 3. Admitted in part and denied in part. Defendant demands to be provided with a certified copy of any Credit/Revolving Charge Account established for Defendant; and executed by Defendant. After reasonable investigation, Defendant is without 4 sufficient knowledge or information to form a belief as to the truth of the matter averred in this paragraph, and strict proof thereof is demanded at trial. 4. After reasonable investigation, Defendant is without sufficient knowledge or information to form a belief as to the truth of the matter averred in this paragraph, and strict proof thereof is demanded at trial. 5. After reasonable investigation, Defendant is without sufficient knowledge or information to form a belief as to the truth of the matter averred in this paragraph, and strict proof thereof is demanded at trial. 6. After reasonable investigation, Defendant is without sufficient knowledge or information to form a belief as to the truth of the matter averred in this paragraph, and strict proof thereof is demanded at trial. 7. The averments set forth in Paragraph 7 constitute a conclusion of law to which no responsive pleading is required. To the extent a response is required, the averments are denied and strict proof is demanded at the time of trial. WHEREFORE, Defendant respectfully request this Honorable Court enter judgment in its favor and against Plaintiff, along with costs of suit. Dated: d P—t. 3 2014 Respectfully submitted, NICHOLAS LAW OFFICES, P.C. n/" Steve C. Nicholas, Esquire Pa. Supreme Court ID #06845 2215 Forest Hills Drive, Suite 37 Harrisburg, PA 17112-1099 (717) 540-7746 - phone (717) 541-1527 - fax Attorney for Defendant By: VERIFICATION I, Thomas N. Kounas, state I have read the foregoing Defendant's Answer to Plaintiff's Complaint, and I hereby certify that the statements made in the foregoing document are true and correct to the best of my knowledge, information and belief. I further understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. Dated: , 2014 Thomas N. Kounas Nicholas Law Offices, PC Steve C. Nicholas, Esquire Pa. Supreme Court ID #06845 2215 Forest Hills Drive, Suite 37 Harrisburg, PA 17112-1099 (717) 540-7746 - phone (717) 541-1527 - fax steve_nicholas@comcast.net Attorney for Defendant CAPITAL ONE BANK (USA), N.A. 4851 Cox Road Glen Allen, VA 23060 Plaintiff v. THOMAS N. KOUNAS 84 Silver Crown Drive Mechanicsburg, PA 17050 Defendant THE V THONOTAIO 2Gi+I JUN -3 Ali 9: 26 CUMBERLAND COUNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA No. 14-2844 - CV CERTIFICATE OF SERVICE I, Steve C. Nicholas, Esquire, do hereby certify that on this, the 34 day of June 2014, I served a true and correct copy of the foregoing Answer via First Class, United States mail, postage prepaid as follows: Arthur Lashin, Esquire Hayt, Hayt & Landau, LLC 123 S. Broad Street, Suite 1660 Philadelphia, PA 19109-1003 NICHOLAS LAW OFFICES, P.C. By: � L C/(/` Steve C. Nicholas, Esquire Pa. Supreme Court ID #06845 2215 Forest Hills Drive, Suite 37 j Harrisburg, PA 17112-1099 Dated: 01 --to tit / , 2014 Attorney for Defendant LAW OFFICES OF 20 , HAYT, HAYT & LANDAU, LLC4 / , By: Arthur Lashin, Esquire Attorney for Ply>f?f � Identification No. 23425 Y�VAN!��'��` 123 S . Broad Street Suite 1660 Philadelphia, PA 19109-1003 (215) 928-1400 CUMBERLAND COUNTY OUR FILE NO: 494378 CAPITAL ONE BANK (USA) , N.A. COURT OF COMMON PLEAS CIVIL DIVISION VS . THOMAS N KOUNAS No. 14-2844-CIVIL PRAECIPE TO DISCONTINUE WITHOUT PREJUDICE TO THE PROTHONTARY: Kindly discontinue the above captioned matter without prejudice. LAW OFFICES OF HAYT, HAYT & LANDAU, LLC By: ARTHUR LASHIN 2 4 Attorney for Plaintiff