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HomeMy WebLinkAbout08-3076'''fur file No.:157804 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 (USA), N.A. c/o Apothaker & Associates, P.C. 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 Plaintiff, VS. ELAINE A MEREDITH 48 RUSTIC DR SHIPPENSBURG, PA 17257 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 08 - am, 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 (USA), N.A. c/o Apothaker & Associates, P.C. 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 Plaintiff, VS. ELAINE A MEREDITH 48 RUSTIC DR SHIPPENSBURG, PA 17257 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: D,?- 367& CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff, CAPITAL ONE BANK (USA), N.A., 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 ELAINE A MEREDITH, an adult individual residing at 48 RUSTIC DR SHIPPENSBURG, PA 17257. 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 $2,296.37. } -- ` ' 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 $2,296.37 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER &ASSCICIATES, P.C. A Law Firm Endaged ij& Debt Collection BY: Dated: 4/29/2008 David Our File No.: 157804 VERIFICATION 1 , hereby states that I am ,a 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 unswom falsification to authorities. DATE: vim" • ? ------------------------- -------- Show Mom your love! Special savings for Capital One* Cardholders! I 1* on your next purchase when i you use Promotion Code C"66 (See reverse for details) ' Save l 50 Save this code! Offer good all year long! Remember: Mother's Day is Sunday, May 141h is Bowers coma Call 1-800-FLOWERS•(1-800-356-9377)or Click www.1800flowers.com today! Your florist of choice. ------------- - --------------------------------------------------------------------------------Q, se-1110W P-ML- Summary Previous Balance $1,209.14 Payments, Credits and Adjustments $.00 Transaction $41.00 Finance Charges $27.77 New Balance $1,277.91 Minimum Amount Doe $1,277.91 Payment Due Date May 09, 2005 Total Credit Line $750 Total Available Credit $.00 Credit Line for Cash $750 Available Credit for Cash $.00 At your service To oill Cmtomer Reladom or to report a loot or stolen ard: 1-800-903-3637 For free online account service and special antomer offers, log on to: -.apitalone.com Send payments to: Send inquiries to: Arta: Remittance Promsing Capital Oae Bank Capital One Serviw P.O. Box 790116 P.O. Box 85015 St. Louis, MO 63179-0216 kkhmond, VA 23295-5015 PREMIER VISA ACCOUNT MAR 10 - APR 09, 2005 4106-0821-1201-1286 Pagel of 1 Payments, Credits and Adjustments Transactions 1 09 APR CAPITAL ONE MONTHLY MEMBER FEE $6.00 2 09 APR PAST DUE FEE 35.00 Your request to dose your account has been received. Your account will be dosed when it reaches a $0 balance. Until then, you will continue to receive statements and must continue to make payments. All terms and conditions of the account will apply while a balance remains. Please remember to cut your cards and cancel all charges which automatically bill to your account. You were assessed a past due fee of $35.00 on 04/09/2005 because your minimum payment was not received by the due date of 04/09/2005. To avoid this fee in the f ltme, we recommend that you allow at least 7 business days for your payment to reach Capital One. FinanceCharges Plexeseerete eiideforimportantinfamatim Balm-ee rate P-1d. &I AN - r m gep&dm " rate 2 _ 0 PURCHASES $1,222.71 .07326%P 26.74% $27.77 CASH $.00 .07326%P 26.74% $.00 PLEASE RETURN PORTION BELOW WITH PAYMENT ?- 0000000 0 4106082112011286 09 1277910030001277912 New Balance $1,277.91 Minimum Amount Due $1,277.91 Payment Due Date May 09, 2005 Total enclosed $ Account Number, 4106-0821-1201-1286 ANNUAL PERCENTAGE RATE applied this period 26.74% Pkupru-tmad.g.arrru m-h e-moitef, T-Pef ruby bl or black ink. City Apt. Hom< Plnoe Al-.. Pbooc #9010000450041487# MAIL ID NUMBER Capital One Bank ELAINE A MEREDITH P.O. Box 790216 Irlsslsssllrrltlltlssl m 3614 SAINT THMS WLMSN m St. Louis, MO 63179-0216 CHAMBERSBURG PA 17201 T IJlrttdlrrrJlLtdllLdhttttLltrdlJlttttdldlttLdJ ? !`l!!? Please r teyavr account number on your checf or money order made payabk to Capital One Bank and mail in the enckred envelope. r ? ? ,?j n rya 04 v 1 d ?r(Jy sy r't ; ? , , ?' 3s„ Z ^ -?C rY't `-o r m .? N SHERIFF'S RETURN - REGULAR CASE NO: 2008-03076 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CAPITAL ONE BANK USA NA VS MEREDITH ELAINE A KENNETH GOSSERT Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE the MEREDITH ELAINE A was served upon DEFENDANT , at 1508:00 HOURS, on the 16th day of May , 2008 at 48 RUSTIC DRIVE SHIPPENSBURG, PA 17257 ELAINE MEREDITH 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 sp 1/O1 C/L 18.00 20.00 .00 10.00 .00 48.00 Sworn and Subscibed to before me this day of , So Answers: ?l R. Thomas Kline 05/19/2008 APOTHAKER & ASSOCIATES By. eputy Sherif A. D. } Our file No.: 157804 ' Z APOTHAKER & ASSOCIATES, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff Attorney ID# 55140 CAPITAL ONE BANK (USA), N.A. Plaintiff, Vs. ELAINE A MEREDITH Defendant. 2010 MAR 10 P91 3: 41 CU1r9 'l i°?1 ?+-?r COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO.: 08-3076 Civil Action STIPULATION IN LIEU OF JUDGMENT The matters and things in controversy having been discussed by and between the parties, and a settlement having been agreed upon: It is on February 23, 2010, STIPULATED by and between Plaintiff, CAPITAL ONE BANK (USA), N.A., and Defendant, ELAINE A MEREDITH parties as follows: 1. Defendant agrees to pay the sum of $2,473.61, which sum Plaintiff agrees to accept in full settlement of its claim herein, inclusive of counsel fees and court costs. 2. As of this date, payments totaling $1,400.00 have been applied to the amount of $2,473.61, and the amount due and owing as of February 23, 2010 is $1,073.61. 3. The sum aforesaid of $1,073.61 shall be paid by the by Defendant, ELAINE A MEREDITH, to the attorneys for Plaintiff in the following manner: a. $50.00 to be paid on or before the 15`h day of each month, beginning March 15, 2010 until paid in full. All checks are to made payable to CAPITAL ONE BANK (USA), N.A., and sent to: Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 . ' Our file No.: 157804 4. In the event Defendant fails to pay in accordance with the terms set forth in this Stipulation, then, and in that event, Plaintiff shall be entitled to obtain the entry of Judgment against Defendant ex parte, in the sum of $2,473.61, giving Defendant credit for any sums actually paid pursuant to the terms of this Stipulation. 5. In the event of default as aforesaid, Plaintiff shall be entitled to obtain the entry of Judgment upon ex parte application, with supporting certification, and with notice to Defendant only in the form of a copy of the application addressed to ELAINE A MEREDITH by first-class, postage prepaid. We hereby consent to the form and entry of the within Stipulation. APOTHAKER & ASSOCIATES, P.C. A Law Firm Engaged i By: ELAINE A MEREDITH ?L Our File No.: 157804 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. M{1 OF THE PPOT OTRRY 28M AN -2 AM 10 0& UNTY PEPNSYLW,. LA COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff vs. ELAINE A MEREDITH NO.: 08-3076 Civil Action Defendant PRAECIPE TO ENTER JUDGMENT PURSUANT TO STIPULATION TO THE PROTHONOTARY: Please enter a judgment in favor of plaintiff, CAPITAL ONE BANK (USA), N.A., and against Defendant, ELAINE A MEREDITH, for failure to comply with the terms and conditions of the Stipulation in Lieu of Judgment (Stipulation), filed with this Court on March 10, 2010, a copy of which is attached hereto as Exhibit "A". Assess damages in the amount of: Balance: $ 2,473.61 Less: Payments: ( 50.00) Plus: Interest from March 10, 2010 14.57 TOTAL ( / / $ 2,438.18 David J. Apothaker, Esq. Attorney for Plaintiff 414- 00 p PO Dated: May 21, 2010 C*' 18a 1,31 0 Igagqg K ?Ou?i? Our File No.: 157804 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. ELAINE A MEREDITH NO.: 08-3076 Defendant David J. Apothaker, Esquire, certifies as follows: Civil Action 1. I am an attorney with the Law Firm of Apothaker & Associates, P.C., attorneys for the Plaintiff in the above captioned matter, and as such, have full and complete knowledge of the facts herein. 2. The matter was settled by and between the parties by Stipulation in Lieu of Judgment (Stipulation), on March 10, 2010, a copy of the Stipulation is attached hereto and marked as Exhibit "A". 3. Defendant breached this agreement by failing to make payments in accordance with the terms of said Stipulation. 4. Therefore, pursuant to the Stipulation, Plaintiff is proceeding towards the entry of Judgment in the amount of $2,473.61, giving the Defendant credit for payments made totaling $50.00, plus interest in the amount of $14.57, for a total of $2,438.18. I verify that the statements made in this Certification are true and correct. I understand that false statements herein are made subject to the penaWes f 18 Pa.C.S.A. §4904, relating to f unsworn falsification to authorities. David J. A thaker, Esq. Attorney f Plaintiff Dated: May 21, 2010 Our File No.: 157804 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. VS. Plaintiff ELAINE A MEREDITH Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-3076 Civil Action 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 48 RUSTIC DR SHIPPENSBURG, PA 17257. We inquired with the web site of the Defense Manpower Data Center, located at 1600 Wilson 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 Def s M wer Data Center has sent back our inquiry indicated that the Defendant(s) is/are not ' e itary. David J. Apothaker, Esq. Attorney for Plaintiff I verify that the statements made in this Certification are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904, relating to unsworn falsification to authorities. Deparaaaea afbease Manpower Dare Cestu hokslySb" Report Paasrraak b 6e Ser?ice Membm Chi RefefAct Iday-21-2010 07.1401 1e iafo MOM you have The DbOX clots apt poum my' $prasa6ta 6e i orirlai stem. 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Many buns mdes we amended to e seed 6e period ofacbm do}, whirls wv%ld =dead SCRA prokscboos, pers,=,addse ao ray as 66 weebsrlbe aeedReaalm sLssid deck to moire sore the ordit an vA" SCRA pecwersiaas we bated Mw sot been aeaded to teaaaod 6e rive daces daervice: Fa6®tore, cone prowcuoer dt6e 5CR+4 a rsamd b petsoas s?o brave rcc+ao+ed ardras run neport?ar acfisa they or gip bx isdocted, bat wbp haw rat ?y tre@ta aaciMrs dtti* or aclr"!y repoHed$er a dac*w The Last Date as Attoe D* ofty is kVor d botam e a taaabu 4proeections of SCRA erinsd br7oMd 6e Let loses of aeave dory. Tboft wLo world ealr as bit exrUfeaar we wpd to seek odd legal aasesd to mwrr 6aa at 4ift gaewsatecd to Suvice anewba trader 6e SCRA are paaaarected WARNLV& This cMitraat was pravlded based an aamoe and SSN provided by the ro*xsux- Ptwiiag as curve ow saw at SSN wA case an awaso u ee rWkse io be provided. Aapnst MJ42413MT Lip= se"a+claag 6e iefasarabw daa braab aithe Dge ramert dDtfaae Mmpowar Data Comm based os 6t iofonemon rot ym prwided to above is 6a cawawt staan d6e isaTlvidsai ss to al btasc m of 6e th&xmod Se %*= (Awry. Davy. Marine Caps. Air Bocce, NOAA, Peiatc McMW and Co" C,a:ti). Our file No.: 157804 ' ?.. APOTHAKER & ASSOCIATES, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff Attorney ID# 55140 ) CAPITAL ONE BANK (USA), N.A. ) Plaintiff, } vs. ) ) ELAINE A MEREDITH } Defendant. } =-x ° ` -ra 7 ? COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO.: 08-3076 Civil Action STIPULATION IN LIEU OF JUDGMENT The matters and things in controversy having been discussed by and between the parties, and a settlement having, been agreed upon: It is on February 23, 2010, STIPULATED by and between Plaintiff, CAPITAL ONE BANK (USA), N.A., and Defendant, ELAINE A MEREDITH parties as follows: 1. Defendant agrees to pay the sum of $2,473.61, which sum Plaintiff agrees to accept in full settlement of its claim herein, inclusive of counsel fees and court costs. 2. As of this date, payments totaling $1,400.00 have been applied to the amount of $2,473.61, and the amount due and owing as of February 23, 2010 is $1,073.61. 3. The sum aforesaid of $1,073.61 shall be paid by the by Defendant, ELAINE A MEREDITH, to the attorneys for Plaintiff in the following manner: a. $50.00 to be paid on or before the 15'h day of each month, beginning March 15, 2010 until paid in full. All checks are to made payable to CAPITAL ONE BANK (USA), N.A., and sent to: Apothaker & Associates, P.C., i' 520 Fellowship Road C306 MountLaurel, NJ 08054 l _ _ Our file No.:. 157804 4. In the event Defendant fails to pay in accordance with the terms set forth in this Stipulation, then, and in that event, Plaintiff shall be entitled to obtain the entry of Judgment against Defendant ex parte, in the sum of $2,473.51, giving Defendant credit for any sums actually paid pursuant to the terms of this Stipulation. 5. In the event of default as aforesaid, Plaintiff shall be entitled to obtain the entry of Judgment upon ex parte application, with supporting certification, and with notice to Defendant only in the form of a copy of the application addressed to ELAINE A MEREDITH by first-class, postage prepaid. We hereby consent to the form and entry of the within Stipulation. APOTHAKER & ASSOCIATES, P.C. Attorneys for Plaintiff A Law Firm Engaged ia0t.Coliwtioi By: Esquire ELAINE A MEREDITH 157804 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY CAPITAL, ONE BANK (USA), N.A. ) COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. ) ELAINE A MEREDITH ) NO. 08-3076 To: ELAINE A MEREDITH 48 RUSTIC DR SHIPPENSBURG, PA 17257 NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT Date of Notice: June 17, 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 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 L DAVID J. APOTHAKER, ESQUIRE APOTHAKER & ASSOCIATES, PC 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 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS TO: ELAINE A MEREDITH 48 RUSTIC DR SHIPPENSBURG, PA 17257 CAPITAL ONE BANK (USA), N.A. Plaintiff VS. COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-3076 ELAINE A MEREDITH Defendant 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. JUDGMENT FOR FAILURE TO COMPLY WITH THE TERMS AND CONDITIONS OF THE STIPULATION IN LIEU OF JUDGMENT JUDGMENT BY DEFAULT ? JUDGMENT IN REPLEVIN F] JUDGMENT BY CONFESSION ? JUDGMENT FOR POSSESSION ? JUDGMENT ON AWARD OF ARBITRATORS IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: ATTORNEY David J. Apothaker. Esq. at this telephone number: 215-634-8920 D-A) N/ Our File No.: 157804 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker Attorney I.D.# 55140 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff CAPITAL ONE BANK (USA), N.A. Plaintiff, VS. ELAINE A MEREDITH Defendant. FILED-OFFICE OF TNE.PROTNONOTARY 2010 NOV 18 PM 1: 15 CUMBERLAND COUNTY PENNSYLVANIA COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 08-3076 PRAECIPE TO VACATE JUDGMENT TO THE PROTHONOTARY: Please vacate the Judgment against the Defendant. APOTHAKER & ASSOCIATES, P.C. Attorneys for Plaintiff A Law Firm Engaged ' ebt Collection By: David J. Apothaker Our File No.: 157804 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 CAPI1 AL ONE BANK (USA), N.A. Plaintiff, vs. ELAINE A MEREDITH OF TH??PRaTHO UTARY 1012 JAN 13 AM 11: 36 CUMBERLAND COUNTY PENNSYLVANIA COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 08-3076 Defendant. PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER ramelin OCIATES, P.C. Attorne Plaintiff A Law Firm En Debt Callectioi By: V David J. A thaker, Esquire Dated: 12/29/2011 ?IIIIN?NN??IMIII?