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Home My WebLink About08-0376Our File No.: 135080 APOTHAKER & 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. RICARDO ALMEIDA 310 E NORTH ST CARLISLE, PA 17013-2540 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 08 - 3'710 buil'Term 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. 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 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: 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. RICARDO ALMEIDA 310 E NORTH ST CARLISLE, PA 17013-2540 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. 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 RICARDO ALMEIDA, an adult individual residing at 310 E NORTH ST CARLISLE, PA 17013-2540. 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 $1,701.92. 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 $1,701.92 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER & ASSOCIATES, P.C. Attorney ??intiff A Law Firm Enga d ' Debt Collection BY: David J. Dated: 1/8/2008 Our File No.: 135080 VERIFICATION Lut , 6/(,,4? , hereby states that I am for plaintiff in this J - 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 unworn falsification to authorities. DATE: ? .1 • Now Wfth t FREE Accelerator • /or the fkw 12 a?avnhet-a $00 value 97 e month for first 3 morr8re; $9-Wmo. thereafter SIGN UP TODAVI ' 1-888-587-9669 Mention Offer Code: PEARL Or visit www.peoplepe.com/go/pearl Capftalowe Account Summary Previous Balance $928.16 Payments, Credits and Adjustments $.00 Transactions $29.00 Finance Charges $20.64 New Balance $977.80 Minimum Amount Due $977.80 Payment Due Date March 19, 2005 Total Credit Line $500 Total Available Credit $.00 Credit Line for Cash $500 Available Credit for Cash $.00 At your service To all Cunoma Relatiom or to re art a lon or nolen card: 1-800-903-3637 For free online account service and ape ial oatomer offer, log on to: w .C*td-coon Sand paymants to: Send inqui.. to: Attm Remittance P-sing Capital One Savior Capital One Services. . P.O. Bor 85147 P.O. B. 85015 Richmond, VA 23276 Richmond, VA 23285-5015 PLATINUM VISA ACCOUNT 4862-3623-9100-1867 peoplepu online u A better way to Internet. PeoplePC Online offers all the features you would expect from higher-priced Internet Service Providers, including: ® Virus Protection powered by synant.- ® Pop-Up BlockerTM Spam controls ap Smarter Smart Dialer Technology ® LN More Email Addresses ® % Internet Call Waiting JAN 20 - FEB 19, 2005 Page 1 of 1 Payments, Credits and Adjustments Transactions 1 19 FEB PAST DUE FEE $29.00 You were assessed a past due fee of $29.00 on 02/1912005 because your minimum payment was not received by the due date of 02/1912005. To avoid this fee in the future, we recommend that you allow at least 7 business days for your payment to reach Capital One. FinanceChatges Please ru -mesideforimportantinform ation Ba! arm °dtO PIl;, ...+ C ?pRdmd a AK? PURCHASES CASH 1938.10 3.00 .07096% 25.90% 0709696 25 90% 320.64 . . 3.00 ANNUAL PERCENTAGE RATE applied this period 25.90% PLEASE RETURN PORTION BELOW WITH PAYMENT ?,Oa 0000000 0 4862362391001867 19 09778 00100000977803 New Balance $977.80 Minimum Amount Due $977.80 Payment Due Daze March 19,266 Total enclosed $ Account Number. 4862-3623-9100-1867 P4-print madiedadavsr and/or e-mod'Amr-61 -ins kJ or kl Fink onset Apt Y - - Cary s_ ZIP Akerate -? #9005176538834999# MAIL ID NUMBER Capital One Bank RICARDO ALMEIDA P.O. Box 85147 310 E NORTH ST Richmond, VA 23276 m -? CARLISLE PA 17013-2540 Pleare write yow account number on yow check or money order made payable to Capital One Bank and mail in theenclmed ereoelope. r 4 w 44 00 ? b r? c:- C '?I ?i 0 SHERIFF'S RETURN - REGULAR CASE NO: 2008-00376 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CAPITAL ONE BANK VS ALMEIDA RICARDO KENNETH GOSSERT Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon ALMEIDA RICARDO the DEFENDANT at 2048:00 HOURS, on the 17th day of January , 2008 at 310 E NORTH STREET CARLISLE, PA 17013 JENNIFER ALMEIDA. WIFE 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 Service Affidavit Surcharge n //.Z y/0 & `L 18.00 4.80 .00 10.00 .00 32.80 Sworn and Subscibed to before me this day of , So Answers: R. Thomas Kline 01/18/2008 APOTHAKER & ASSOCIATES By: / [ - D u rl? iff A. D. Our File No.: 135080 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 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff, VS. RICARDO ALMEIDA NO.: 08-376 Civil Action Defendant. PRAECIPE TO ENTER DEFAULT JUDGMENT TO THE PROTHONOTARY: Please enter a default judgment in favor of plaintiff, CAPITAL ONE BANK, and against Defendant, RICARDO ALMEIDA, for failure to answer or otherwise respond to the Complaint - Civil Action. The Complaint was served upon the defendants on January 17, 2008 by the CUMBERLAND Sheriff's Department. Copies of the proofs of service are attached hereto as Exhibit "A". I certify, a copy of the Notice of Intention To Take Default was mailed on April 24, 2008, and also attached hereto. 135080 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY CAPITAL ONE BANK ) VS. ) RICARDO ALMEIDA ) To: RICARDO ALMEIDA 310 E NORTH ST CARLISLE, PA 17013-2540 COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 08-376 NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT Date of Notice: April 24, 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 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 Lawyer Referral and Information Service 800-990-9108 _/s/ David J. Apothaker 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 SHERIFF'S RETURN - REGULAR CASE NO: 2008-00376 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CAPITAL ONE BANK VS ALMEIDA RICARDO KENNETH GOSSERT ??? FEB 13 2408 [[!I , sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon ALMEIDA RICARDO the DEFENDANT , at 2048:00 FOURS, on the 17th day of January , 2008 at 310 E NORTH STREET CARLISLE, PA 17013 JENNIFER ALMEIDA, WIFE 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 32.80 Sworn and Subscibed to before me this day of So Answers: R. Thomas Kline 01/18/2008 APOTHAKER & ASSOCIATES By : ? D 'a ? iff A.D. yl ? ':tr $ 6' t9 rv a,,? cry s ,i OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS TO: RICARDO ALMEIDA 413 W LOVTHER ST CARLISLE, PA 17013 CAPITAL ONE BANK Plaintiff, vs. RICARDO ALMEIDA Defendant. 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 NOTICE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-376 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. IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: ATTORNEY David J. Apothaker, Esq. at this telephone number: 215-634-8920 J 47 :4 - - -- A P OLX'7 mR