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Home My WebLink About08-1803Our File No.: 150832 APOTHAKER &1ASSOCIATES, 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. JAMES I YOUNG 402 N WEST ST CARLISLE, PA 17013-1962 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: d8 - 1803 bVil Tr" 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 demands. 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 provisions 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. JAMES I YOUNG 402 N WEST ST CARLISLE, PA 17013-1962 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. 0 k- /?a 3 C4l;:e „,, 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 JAMES I YOUNG, an adult individual residing at 402 N WEST ST CARLISLE, PA 17013-1962. 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 $10,484.41. 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 $10,484.41 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER & ASSOC TES, P.C. Attorney for P nt' A Law Firm Engaged ' De Collection BY: David J. Dated: 2/29/2008 Our File No.: 150832 VERIFICATION hereby states that I am for plaintiff in this action, and that I am authorized to take this Verification, and that the statemen&made in the foregoing Civil ActiQn 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: . . a C pitalW KYFF t , ??VlIIII Kee our finances rt • Know your credit limit and the amount of credit available for your use. • Maintain a good credit history ...it affects more areas of your life than just your ability to get a credit card. • Use a budget to help you see what you can afford to buy now and to help you save for the future. • Understand that the cost of credit includes fees as well as interest. • Request a copy of your credit report from a credit reporting bureau regularly. KYFF-1001 W Meows Account Previous Balance $5,814.19 Payments, Credits and Adjustments $.00 Transactions $35.00 Finance Charges $118.18 New Balance $5,967.37 Minimum Amount Due $5,967.37 Payment Due Due April 19, 2005 Total Credit Line $5,000 Total Available Credit $.00 Credit Line for Cash $5,000 Available Credit for Cash $.00 At your service To can Cwtoma Rd iom or to report a lost of stolm aril: 1-800-903-3637 Send psymau to: sad inqu na to: Attn: Rauttanm Proeasing Capital One Bsnk Capital One Savien P.O. Box 790216 P.O. Box 85015 Sr. Lows, MO 63179-0216 Richmond, VA 23285-5015 Important Account Information Please review the important information enclosed with your statement and keep a copy for your records. PLATINUM MASTERCARD ACCOUNT 5178-0521-3472-9223 Payments, Credits and Adiustments FEB 20 - MAR 19, 2005 Page 1 of 1 Transactions 1 19 MAR PAST DUE FEE $35.00 You were assessed a past due fee of $35.00 on 0311912005 bemuse your minimum payment was not received by the due date of 03119/2005. To avoid this fee in the future, we recommend that you allow at least 7 business days for your payment to reach Capital One. Due to the past-due status on one or more of your Capital One account(s) ending in 9223, 7400, your Charging privileges on these accounts have been suspended in accordance with your Customer Agreement(s). As soon as these accounts are bark in good standing, charging privileges on these accounts will be restored within 7-10 days For up-to-date payment-due information, you can call 1-800-955-7070. IfyouW already made your payment(s), please disregard this message. Thank you. Finance Charges Pkareserr znnrsidefor,n"taw,x&mma6on Ad--A, Periadr C npowdneg FIN'kK CE ? dm role R ?`I?, G$ PURCHASES 15,87097 .07189%P 26.2^ $118.18 CASH 1.00 .07189%P 26.21% 1.00 ANNUAL PERCENTAGE RATE applied this period 26.24% v PLEASE RETURN PORTION BELOW WITH PAYMENT ?One• 0000000 0 5178052134729223 19 5967370050005967373 New Balance $5,967.37 Minimum Amount Due $5,967.37 Payment Due Due April 19, 2005 Total enclosed $ Account Number: 5178-0521-3472-9223 s m Apt e City Sure ZIP Home Phone Alw= Phone #9007919111705450# MAIL ID NUMBER Capital One Bank JAMES I YOUNG 2062 KEHRSBORO DR P.O. Box 790216 CHESTERFIELD MO 63005-6528 St. Louis, MO 63179-0216 N Pleare writeyour a aoant number myour Check m money miler madepayable to Capital One Bank and mailin the a Ixedenvelope. P I - P i n t a d d , - e A m e g w Sel-as A l e eorbla4-L r Ap- 09 4? -n R? ? O LA 'V i b ? J i - f _ti µ - SHERIFF'S RETURN - NOT FOUND CASE NO: 2008-01803 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CAPITAL ONE BANK VS YOUNG JAMES I R. Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT YOUNG JAMES I but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT & NOTICE , NOT FOUND , as to the within named DEFENDANT , YOUNG JAMES I 402 N WEST STREET CARLISLE, PA 17013-1962 DEFENDANT MOVED OUT A COUPLE OF MONTHS AGO. NO FORWARDING ADDRESS ON FILE AT POST OFFICE. Sheriff's Costs: So answers: Docketing 18.00 Service 5.00 Glace Not Found 5.00 R. Thomas Kline Surcharge 10.00 Sheriff of Cumberland County 00 3 APOTHAKER & ASSOCIATES 04/15/2008 Sworn and Subscribed to before me this day of , A.D. Answer of Garnishee/Unable to Withhold 06/10/2008 OFFICE OF THE PROTHONOTARY 1 COURT HOUSE SQ CARLISLE, PA 17013 3323 Re: Insufficient Disposable Income Case Identifier: Obligor Name: Obligor Status: Obligor Status Date: Employer Name: Payroll Check Date: 061803 HOUGHT,CHRIS Active DARDEN RESTAURANTS/GMRI 06/13/2008 To Whom It May Concern: Due to insufficient disposable income, the above employee did not have a deduction for the payroll check date noted above. ADP Financial and Compliance Services is remitting this notice on behalf of the above employer. All questions concerning this remittance should be directed to (866) 324-5191 ADP Financial and Compliance Services By:ut?,{nc Name: Lynn Demshock Title: V.P. of Garnishment Services Under the penalties provided by applicable law, ADP Financial and Compliance Services certifies DRT1 that the statements set forth in this instrument are true and correct and that a copy of this completed response and the underlying garnishmenttwithholding order, to the extent required by applicable law, has been mailed via first class U.S. mail on the date hereof to the debtorlobligor, plaintiff and any other parties required by applicable law. J { cr? {yam I Our File No.: 150832 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 Plaintiff, vs. JAMES I YOUNG Defendant. RLED-O CE OF THE PR,"'TK^?410TARY 2010 FEB -9 A 9: 52 GUIs iL.. b "'OUNW PE '1;33 'LVN1,j A COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 08-1803 PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & A Law Firm By: David J. Dated: 1/30/2010 SOCIATES, P.C. laintiff Debt Collection Esquire