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Home My WebLink About07-3304APC~THA~ER & ASSOCIATES, P.C. BY: David 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. MATTIE WRIGHT 161 LINCOLN ST CARLISLE, PA 17013-1940 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY No.. D'Y - 33a / ~t v t ~~~L 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 han 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 notification. Hate 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 notification. Ademas, la corte puede decidir a favor del edemandante y requiere que usted compla con todas las provisiones 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 APOTHAYER & ASSOCIATES, P.C. BY: David J. ?~pothaker, 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. MATTIE WRIGHT 161 LINCOLN ST CARLISLE, PA 17013-1940 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: D7- ~ 3 o Y ~iw.~ CIVIL ACTION COMPLAINT FIRST COUNT 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 MATTIE WRIGHT, an adult individual residing at 161 LINCOLN ST CARLISLE, PA 17013-1940. 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 $2,159.44 from November 26, 2003. 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 $2,159.44 plus costs, and reasonable attorney's fees. APOTHAKER & ASSOCIATES, P.C. Attorney for Plaintiff A Law Firm Enga in Debt Collection BY: David pothaker Dated: 5/22/2007 Our File No.: 97076 VERIFICA"C[ON +~ •~'~ ,hereby states that (any ___ _~~~f ______ fbr plaintiff in this action, and that ! am authorized to take this Verification, and that the statements made in the tirregourg Civil Action Complaint arc true and correct to [hc best of my knowledge, information, and belief. The undersigned understands that the statements therein arc made subject to the penalties of 18 Pa.C.S.A. 4904 relating to unswom falsification to authorities. DATE: ~ ~ First 3 months half-price .~, / , a month; $8.85/mo.thereafter SIQN UP TODAY: ' 1-877-778-1207 Mention Offer Code: CORAL Or visit www.peoplepc.com/go/coral peoplepc~~ online u Abetter way to Intemet. PeoplePC Online offers the features you would expect from higher-priced Internet Service Providers at half price for the first 3 months! ® Email Virus Protection ® Pop-Up BlockerT"' Spam Controls Smart Dialer Phisher Security f~ Internet Call Waiting Caprtal~~® VISA ACCOUNT 4121-7416-2905-5976 Account Summa Previous Balance E1,233.93 Payments, Credits and Adjustments E.00 Transactions E35.00 Finance Charges E25.60 New Balance E1,294.53 Minimum Amount Due E1,294.53 Payment Due Date August 23, 2004 Tots! Credit Line E500 Total Available Credit 5.00 Credit Line for Cash E500 Available Credit for Cash E.00 At your service To call Customer Rehtions or to report a lost or stolen aril: 1-800-903-3637 For free online account service and spedal asstomer offers, log on to: wvrrs.capitalonacom Send payments to: Send inquiries ro: Attn: Remittann Procusing Capital One Services Capital One Services P.O. Box 85]47 P.O. Box 85015 Richmond, VA 23276 Richmond, VA 23285-5015 JuN za JuL z3, Ioo4 Page 1 of t Payments, Credits and Adjustments Transactions 1 23 JUL PAST DUE FEE ;35.00 You were assessed a past due fee of E35.00 on 07/23/2004 because your minimum payment was not received by the due date of 07/23/2004. To avoid this fee in the future, we recommend that you allow at least 7 business days for your payment to reach Capital One. Finance Charges Pleace iee reverre aidefor important i j atinn ~ Bo1on rote ~r v ''od'e Comspo ding FINAN~E .gpr m 0 rote APR Cj-IAR E m PURCHASES 51,246.26 .06847%P 24.99% 325.60 CASH 5.00 .06847%P 24.99% E.00 ANNUAL PERCF,NTAGE RATE applied this period 24.99% PLEASE RETURN PORTION BELOW WITH PAYMENT C`i~ei~~a 0000000 0 4121741629055976 23 1294530060001294535 New Balance E1,294.53 Minimum Arnount Due 51,294.53 Payment Due Date August 23, 2004 Total enclosed S Account Number: 4121-7416-2905-5976 Pl ace prmr ma,hng adbess and or r-med rbassges br/ a.rng b! orb/ark ink. Soreet APB. p Cary Srare ZIP Home Phnne Al~erna~c Phove a~naaAadrea ~ #9020664259927085# MAIL ID NUMBER ~ MATTIE WRIGHT 161 LINCOLN ST o CARLISLE PA 17013-1940 ° ~ ~ur~~~ur~~~uun~~n~~un~~~r~ui~u~~~un~~uui~~~ni~~ Capital One Bank P.O. Box 85147 ~s~rr~si~i~n~~n~~is) Richmond, VA 23276 ~u~s~u~~m~i~~nr~r~~u~~ui~~rn~~nuu~~r~n~~m~~n~r~ Pleare tu>ite your amount number ors you> check or money order made payable to Capita! One Barsk and mai! in the ersdored ersveJvpe. r~ ~c9. t h p ~ v ~~ ~. N o z ,~ ~ ~ ~ ~ _ ~T ~ /), ~' ~• l / ~ ..• ~ ` t. ~ / ~ Y , ~ ~ SHERIFF'S RETURN - REGULAR CASE NO: 2007-03304 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CAPITAL ONE BANK VS WRIGHT MATTIE RICHARD SMITH Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon WRIGHT MATTIE the DEFENDANT at 1248:00 HOURS, on the 6th day of June 2007 at 161 LINCOLN STREET CARLISLE, PA 17013-1940 MATTIE WRIGHT by handing to a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 4.80 Affidavit .00 Surcharge 10.00 00 G~~sjv~i ~.., 3 Sworn and Subscibed to before me this day of , So Answers: ~~ R. Thomas Kline 06/07/2007 APOTHAKER & ASSOC S By: eputy Sheriff A.D. Our File No.: 97076 APOTHAKER & ASSOCIATES, P.C. 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 (215) 634-8920 Attorneys for Plaintiff David J. Apothaker, Esquire Attorney ID #38423 CAPITAL ONE BANK ) COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff, ) vs. ) MATTIE WRIGHT ) NO.: 2007-03304 Defendant. ) Civil Action PRAECIPE TO ENTER DEFAULT. JUDGMENT TO THE PROTHONOTARY: Please enter a default judgment in favor of plaintiff, CAPITAL ONE BANK and against Defendant, MATTIE WRIGHT, for failure to answer or otherwise .respond to the Complaint -Civil Action. The Complaint was .served upon the defendants on June 6, 2007 by the CUMBERLAND Sheriff s Department. Copies of the proofs of service aze attached hereto as Exhibit "A". I certify, a copy of the Notice of Intention To Take Default was mailed on July 20, 2007, and also attached hereto. Assess damages in the amount of: (a) Balance: $2,159.44 (b) Interest from May 22, 2007 $29.80 TOTAL $2,189.24 APOTHAKER & ASSOCIATES, P.C. Attorneys for Plaintiff A Law Firm En~ed~i Debt Collection sy: is J. Dated: 8/15/2007 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker Attorney LD.#38423 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 (215) 634-8920 Attorney for Plaintiff CAPITAL ONE BANK COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff, vs. MATTIE WRIGHT NO.: 2007-03304 Defendant. Civil Action AFFIDAVIT OF NON-MII.ITARY 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 161 LINCOLN ST CARLISLE, PA 17013-1940. We inquired with the web site of the Defense Manpower Data Center, located at 1600 V~ilson Boulevard, Suite 400, Arlington, VA 22209-2593, if the Defendant(s) is/are in any branch of the military. Mary M. Snavely-Dixon, Director of the Defy~se~/Manpower Data Center has sent back our inquiry indicated that the Defendant(s) is/are not ir~the David J'"Apothaker Attorney for Plaintiff The above signed understands that the statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. ,Request for Military Status Department of Defense Manpower Data. Center Military Status Report Pursuant to the Servicemembers Civil Relief Act Page 1 of 2 AUG-15-2007 07:03:24 < Last 1~Tame First/Middle Begin Date Active Doty States Service/Agency WRIGHT MATTIE Based on the information you have furnished, the DMDC does not possess any information indicating that the individual is currently on active duty. 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 Military. rh~~ ,~.~.s,_a~^ 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 Department of Defense strongly supports the enforcement of the Servicemembers Civil Relief Act [50 USCS Appx. §§ 501 et seq] (SCRA) (formerly 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 active duty status by contacting that person's Military Service via the "defenselink.mil" URL provided below. If you have evidence the person is on active-duty and you fail to obtain this additional Military Service verification, provisions of the SCRA may be invoked against you. If you obtain fiu ther 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 current active duty status only. For historical information, please contact the Military Service SCRApcints-of-contact. See: http://www.defenselink.miUfaq~is/PC09SLDR.htm1 WARNING: This certificate was provided based on a name and Social Security number (SSN) provided hops://www.dmdc.osd.miUscra/owa/scra.prc_Select 8/15/2007 '~ 'SHERIFF'S RETURN - REGULAR CASE NO: 2Q07-fl33Q4 P COMMONWEALTH QFPHNNSYLVANIA: COUNTY OF CUMBERLAND CAPITAL ONE BANK VS a i WRZGHT MATTIE RICHARD SMITH , Sheriff or .Deputy Sheriff of Cumberland County, Pennsylvania, who being duly ewarn according to law, says, the within COMPLAINT & NQTIGE was served upon WRIGHT MATTIE the . DBFSNDANT at 1248:00 HAS, on the 6th day of June Z8b7 at 161 LINCOLN STREET CARLISLE, PA 1?Q13-1940 by handing to MATTTE WRIGHT a true and attested cogy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the c~antents thereof, bucket ing 1a . 0 0 ,~~~r.~r.C ~~, Service 4.80 ~I Affidavit .00 Surcharge 10.00 R. Thomas IC1ine .00 32.80 06/.0?/,2007 APOTHAKER & ASS. S Sworn and Subscibed to By: before me this day puty Sheriff of A.D. _, , , Fu:iiS ~. ~'r§f.~~Y':'jt`t, F: Vtf.'I>1~:,d'f~,,:~~3A7L ~_, Our File No.: 97076 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 Plaintiff, vs. MATTIE WRIGHT 161 LINCOLN ST CARLISLE, PA 17013-1940 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY N0.2007-03304 NOTICE OF INTENTION TO TAKE DEFAULT TO: MATTIE WRIGHT DATE OF NOTICE: July 20, 2007 IIVIPORTANT 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 (YO) 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 S~ DAVID 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 'yr r-> <' ". ~ ~ ~ ~ ~ ' ~ ~ _ ~ ,y r • N . 9 ~ +~+4 [ ."S ~+ Y ~ ~ ~~= _ y ~,,, ~1 ~' 4... 1 ~~ c.~ OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS TO: MATTIE WRIGHT 161 LINCOLN ST CARLISLE, PA 17013-1940 CAPITAL ONE BANK Plaintiff, vs. MATTIE WRIGHT Defendant. COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 2007-03304 Civil Action NOTICE 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