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Home My WebLink About08-4831Our File Np.: 169550 APOTHAKER &ASSOCIATES, P.C. BY: David J. Apothaker, Esquire Attorney I.D.#38423 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 (215) 634-8920 Attorneys for Plaintiff ALTANTIC CREDIT & FINANCE INC. ASSIGNEE FROM CAPITAL ONE c/o Apothaker & Associates, P.C. 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 Plaintiff, vs. LAVINIA E MARKEL 815 W TRINDLE RD MECHANICSBURG, PA 17055 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY ?y NO.. 08 - A1831 Lit u 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. 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 r APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire Attorney I.D.# 38423 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 (215) 634-8920 Attorneys for Plaintiff ALTANTIC CREDIT & FINANCE INC. ASSIGNEE FROM CAPITAL ONE c/o Apothaker & Associates, P.C. 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 Plaintiff, vs. LAVINIA E MARKEL 815 W TRINDLE RD MECHANICSBURG, PA 17055 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is ALTANTIC CREDIT & FINANCE INC. ASSIGNEE FROM CAPITAL ONE c/o Apothaker & Associates, P.C., 2417 Welsh Road, Suite 21 #520, Philadelphia, PA 19114. 2. Defendant(s) is/are LAVINIA E MARKEL, an adult individual residing at 815 W TRINDLE RD MECHANICSBURG, PA 17055. 3. Plaintiff, ALTANTIC CREDIT & FINANCE INC. ASSIGNEE FROM CAPITAL ONE, is the Assignee and Successor in Interest of Account #5903592613717616; and said account was issued to Defendant(s) by CAPITAL ONE BANK (USA), N.A., the Original creditor. 4. Defendant received, accepted and used the account to its benefit. 5. This account is in default and Defendant(s) has an unpaid balance of $5,321.45. A true and correct copy of the total due and owing is attached hereto, made a part hereof and marked as Exhibit "A". 6. All credits, if any, to which Defendant(s) is entitled, have been applied to the account and are included in Exhibit "A". 7. Although demand has been made, Defendant(s) 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 $5,321.45 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER & Attorney A Law Firm Engal ,TES, P.C. Collection BY: David J. Apothaker, Esquire Dated: 8/1/2008 Our File No.: 169550 VERIFICATION l (1{?iP 6n1.1 ?t (-?i'nu hereby states that I am Q? (????P }?}gyp _ 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 unworn falsification to authorities. O?LS1ll? P1 ff DATE: ALTANTIC CREDIT & FINANCE INC. ASSIGNEE FROM CAPITAL ONE LAVINIA E MARKEL 815 W TRINDLE RD MECHANICSBURG, PA 17055 STATEMENT OF ACCOUNT Debtor's Name: LAVINIA E MARKEL Account Number: 5903592613717616 Original Creditor: CAPITAL ONE BANK (USA), N.A. Balance Due: $5,321.45 Our File No.: 169550 EXHIBIT "A" 10T, SLi Q ? ?' T V G7 C= c. r c? r.? F-n alfo 7 c SHERIFF'S RETURN - REGULAR CASE NO: 2008-04831 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ATLANTIC CREDIT & FINANCE INC VS MARKEL LAVINIA E ROBERT BITNER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon MARKEL LAVINIA E the DEFENDANT , at 1024:00 HOURS, on the 26th day of August , 2008 at 815 W TRINDLE ROAD MECHANICSBURG, PA 17055 by handing to LAVINIA MARKEL a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing ? 18.00 Service ?'p$ f 9.00 Affidavit 9 Or8 .00 Surcharge 10.00 Sworn and Subscibed to before me this day of , So Answers: R. Thomas Kline 08/27/2008 APOTHAKER & ASSOCIATES By ?Deputy Sheriff A. D. ALTANTIC CREDIT & FINANCE INC. ASSIGNEE FROM CAPITAL ONE VS. LAVINIA E. MARKEL To: LAVINIA E. MARKEL 815 W. TRINDLE RD. MECHANICSBURG, PA 17055 COURT OF COMMON PLEAS CUNBERLAND COUNTY ) NO. 08-4831 TRYING TO PAY MY BILLS We were paying our bills till my husband loss his job because of his doctors making his weight restriction. I work- 6 days a week and we are trying to pay all of our bills. We fell behind and then we went to the Freedom Group and they are working with our credit cards account. They paid one of my accounts for me and they paid off two of my husband. They are working on the capital one account. We are trying to pay our bills with the help of the Freedom Group. My account for capital one is being handling by the Freedom Group from California. Phone number for them is 1-866-302-0422. The person in charge of my account is Lori. The fax number is 1-858-530-0412. We are trying to get everyone paid. I just can't do it my self I need to ask for them to help us. Thank You Lavinia E. Markel October 14, 2008 0416- / yJ '20a ? O ,4 ?.? +?,1 ICJ Our File No.: 169550 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 ALTANTIC CREDIT & FINANCE INC. ASSIGNEE FROM CAPITAL ONE Plaintiff, VS. LAVINIA E MARKEL Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 08-4831 PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & Attorney A Law Firm En al I By: David J. )W( TES, P.C. in Debt Collection , Esquire Dated: February 13, 2009 ewr?rt , 1 'Ff