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Home My WebLink About07-3130APOTHAKER & ASSOCIATES, P.C. BY: I~avid J. Apothaker, Esq. `Attorney I.D.#38423 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 (215) 634-8920 Attorneys for Plaintiff CAPITAL ONE BANK c/o Apothaker & Associates, P.C. 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 Plaintiff, vs. KATHLEEN J LORD 57 CIRCLE DR CAMP HILL, PA 17011-2609 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY al U ? ? C e/-LPn 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 with 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 my 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 ONE. 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. CUMBERLAND COUNTY BAR ASSOCIATION Lawyer Referral and Information Service 800-990-9108 AVISO Le ban demandado a usted en la corte. Si usted quiere defenderse do estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta asentar una comparencia escrita o con un abogado v entregar a la corte en forma escrita sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del edemandante y requiere que usted compla con todas las provisioner de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes pare usted. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO. VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. CUMBERLAND COUNTY BAR ASSOCIATION Lawyer Referral and Information Service 800-990-9108 APOTHAKER & ASSOCIATES, P.C. BY: 'Qavid J. Apothaker, Esq. *Attorndy I.D.#38423 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 (215) 634-8920 Attorneys for Plaintiff CAPITAL ONE BANK c/o Apothaker & Associates, P.C. 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 Plaintiff, VS. KATHLEEN J LORD 57 CIRCLE DR CAMP HILL, PA 17011-2609 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 07 , 3 l3 d 010"'L`7? CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff, CAPITAL ONE BANK, is a company with its principal place of business located at c/o Apothaker & Associates, P.C., 2417 Welsh Road, Suite 21 #520, Philadelphia, PA 19114. 2. Defendant is KATHLEEN J LORD, an adult individual residing at 57 CIRCLE DR CAMP HILL, PA 17011-2609. 3. At the special instance and request of Defendant, Plaintiff sold and delivered to Defendant goods and/or services at the times, of the kinds, in the quantities, and for the prices set forth in Plaintiffs records. A true and correct copy of which is attached hereto, incorporated herein by reference and designated Exhibit "A". 4. Defendant received and accepted the goods and/or services described in Exhibit "A". 5. The prices set forth in Exhibit "A" are the fair, reasonable and market prices for said goods and/or services, and the prices which Defendant agreed to pay. 6. All credits, if any, to which Defendant is entitled, are set forth in Exhibit "A". 7. In addition, Plaintiff avers that Defendant has failed and continues to fail to make any payments, leaving a balance due and owing of $3,532.58 from January 05, 2004. 8. Although demand has been made, Defendant 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 $3,532.58 plus costs, and reasonable attorney's fees. APOTHAKER & ASSOCIATES, P.C. Attorne Plaintiff A Law Firm En aye in Debt Collection BY: Dated: 5/9/2007 Our File No.: 96850 s • VERIFICATION hereby states that I am 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 unsworn falsification to authorities. DATE: CAPITAL ONE BANK c/o Apothaker & Associates, P.C. 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 KATHLEEN J LORD 57 CIRCLE DR CAMP HILL, PA 17011-2609 STATEMENT OF ACCOUNT Debtor's Name: KATHLEEN J LORD Account Number: 4862362302541993 Date of Debt: January 05, 2004 Balance Due: $3,532.58 Our File No.: 96850 EXHIBIT "A" 'W Yl Cz? ? d 1 , -Y-7 Pia O _rrE --C 0 SHERIFF'S RETURN - REGULAR CASE NO: 2007-03130 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CAPITAL ONE BANK VS LORD KATHLEEN J RONALD HOOVER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon LORD KATHLEEN J the DEFENDANT , at 1520:00 HOURS, on the 25th day of May 2007 at 57 CIRCLE DRIVE CAMP HILL, PA 17011 NELVILLE LORD, SON by handing to a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge L/b -7 0 1 4- 18.00 12.48 .00 10.00 .00 40.48 Sworn and Subscibed to before me this day So Answers: R. Thomas Kline 05/29/2007 APOTHAKER & ASSOCIATES' By. Deputy Sher ff of A. D. Our File No.: 96850 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire Attorney I.D.# 38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff CAPITAL ONE BANK C/O David J. Apothaker, Esq. 520 Fellowship Road C306 Mount Laurel, NJ 08054 Plaintiff, VS. KATHLEEN J LORD 57 CIRCLE DR CAMP HILL, PA 17011-2609 Defendant. COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 2007-03130 Civil Action PRAECIPE TO SUBSTITUTE PARTY PLAINTIFF AS PER Pa RULE 2352 a TO THE PROTHONOTARY: Kindly substitute as Party Plaintiff, Capital One Bank (USA), N.A., in this action. The right to substitution is based upon the following facts: Capital One Bank (USA), N.A, is the successor, who by operation of law, has succeeded to the interest of, CAPITAL ONE BANK. Defendant's rights will not be prejudiced by this change. APOTHAKER & 4SSO)CIATES, P.C. for P aintiff By: David J. , Esquire Dated: October 1, 2008 r„ w Our File No.: 96850 APOTHAKER & ASSOCIATES, P.C. Attorney for Plaintiff BY: David J. Apothaker Attorney I.D.# 38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 CAPITAL ONE BANK (USA), N.A. Plaintiff, vs. KATHLEEN J LORD Defendant. TO THE PROTHONOTARY: COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 2007-03130 Civil Action PRAECIPE FOR DEFAULT JUDGMENT Kindly enter judgment against Defendant, KATHLEEN J LORD, in the default of an Answer, in the amount of $1,837.50 computed as follows: Amount claimed in complaint: $3,532.58 Amount Paid: - $(2,148.55) Interest from May 09, 2007 to 07/06/09 at the legal interest rate of 6.000 per annum $453.47 Costs $0.00 Attorney fees $0.00 TOTAL $1,837.50 I hereby certify that the appropriate Notices of Default, as attached have been mailed in accordance with Pa.R.Civ.P. 237.1 on the dates indicated on the Notices. I certify Defendant, KATHLEEN J LORD, last know address is 57 CIRCLE DR CAMP HILL, PA 17011- 2609 Dated: 7/6/2009 APOTHAKER & SO I TES, P.C. Attorney for aintiff A Law Firm En ged ' De ollectioi By: Dav . Apothaker Our File No.: 96850 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 CAPITAL ONE BANK (USA), N.A. ) COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff, ) VS. ) NO.: 2007-03130 KATHLEEN J LORD ) 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 57 CIRCLE DR CAMP HILL, PA 17011-2609. We inquired with the web site of the Defense power Data Center, located at 1600 Wilson Boulevard, Suite 400, Arlington, VA 22209-2593, if t e ndant(s) is/are in any branch of the military. Mary M. Snavely-Dixon, Director of the De nse anpower Data Center has sent back our inquiry indicated that the Defendant(s) is/are not in the mil' ary. David Apothaker Attorney or Plaintiff The above signed understands that the statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. APOTHAKER&AsSOCIATES, P.C. ATTORNEYS AT LAW Department of Defense Manpower Data Center 3UL-06-2009 08:13:39 Mitary 10 Status Report Pursuant to the Servkemembers Civil Re}icf Acs ?K Last First II"die B Name oW Date Active Duty, States Senice/rLgeacy LORD KATHLEEN J Based on the aformation you have furnished, the DNI C does not possess any information indicating dud the individual is curratly on active duty. € f Upon searching the information data banks of the Department of Defense Manpower Data Canter, based on the inform that you provided, the above is the current std of the in&vidual as to all branches of the Mme. "wy,n. ,?.?i-?- Mary M_ Snavely-Dixon, Director Department of Defense Manpower Data Center 1600 Wilson Bird, Suite 400 Arfgton, VA 22209-2593 The Defense Manpower Data Center (D DC) is an orb of the Department of Defense that mans the Defense Enro&nera and Elig` ity Reporting S1•stem (DEERS) database which is the afficial source of data on eligi for militar)_ medical cane and either ekgr`bility system;. The Department of Defense strongly suss the enforcement of the Servicemeembers Civil Rehef Act [50 USCS Apex- §; 501 et seq] (SCRA) (formerly the Sole rs' and Sailors' Civil Redef Act of 1940)_ D.MDC has issued hundreds of thou of 'does not possess any informs indicating duet the indic aal is currently on active &W rues, and has experienced a small error rate. In the eft the indiumsal reee€erewed ab<we, or any family member, friend, or representative assert in any manner that the individual is on act i-m duty, or is cam entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the persona's active duty status by contacting that person's Military Service via the "defenselinc.mir URL provided below. If you have evidence the person is on active-duty and you fal to obtain this addtional _ Sege veri6Cat provisions of the SCRA may be invoked against you.. If you obtain ffther morn 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,%il provide a new certificate for that quay. This response reacts current active duty status ody. For h toncal iaf , please contact the Merry Service SCRA points- of-contact. See: htts)A sv.-%=edefen e i &.mglm-p` PPC09S DR gnat WARNING: 'Tints certifi cafe was provided based on a name and Social Security mruaber (SSN) groPvicle+d by the requester. Providing an erroneous name or SS w1d cause an erroneous certificate to be provided. RaPartM BSGSatdLEZPEX Our File No.: 96850 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker Attorney I.D.#38423 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 (215) 634-8920 Attorney for Plaintiff CAPITAL ONE BANK COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff, vs. KATHLEEN J LORD NO. 2007-03130 57 CIRCLE DR CAMP HILL, PA 17011-2609 Defendant. NOTICE OF INTENTION TO TAKE DEFAULT TO: KATHLEEN J LORD DATE OF NOTICE: February 11, 2008 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 (10) days from the date of this notice as set forth above, a judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: CUMBERLAND COUNTY BAR ASSOCIATION Lawyer Referral and Information Service 800-990-9108 A ID J. APOTHAKER, ESQUIRE A Law Firm Engaged in Debt Collection 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 (215) 634-8920 Attorney for Plaintiff Attorney ID #38423 SHERIFF'S RETURN -REGULAR CASE NO: 2007-03130_P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CAPITAL ONE BANK VS LORD KATHLEEN J RONALD HOOVER Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania , who being ;duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon LORD KATHLEEN J the DEFENDANT , at 1520:00 HO URS, on the 25th day of May 2007 at 57 'CIRCLE DRIVE CAMP HILL, PA 17011 by handing to NELVILLE LORD, 'SON a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: So Answers: Docketing 18.00 Service 12 . 48 f? Affidavit .00 "- Surcharge 10.00 R. Thomas Kline .00 40.48 05/29/20107 APOTHAKER & ASSOCIATES' Sworn and Subscibed to By: before me this day .? Deputy Sher of A.D. FILET' =;- OF 71"Ic- -JAW CL! 41q. 00 P 0 AZTy e?.? I?1o88'7 ex* aa?q? OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS TO: KATHLEEN J LORD 57 CIRCLE DR CAMP HILL, PA 17011-2609 CAPITAL ONE BANK (USA), N.A. Plaintiff, vs. KATHLEEN J LORD Defendant. NOTICE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 2007-03130 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: 215-634-8920 ?1i3109