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Home My WebLink About08-5153Our File No.: 150987 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire, 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. ARTHUR F JONES 1291 SUMMITVIEW CT NEW CUMBERLAND, PA 17070-2233 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. 68 - .rl.Z3 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 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire, 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. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. ARTHUR F JONES 1291 SUMMITVIEW CT NEW CUMBERLAND, PA 17070-2233 Defendant. CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is CAPITAL ONE BANK(USA), N.A. c/o Apothaker & Associates, P.C., 2417 Welsh Road, Suite 21 #520, Philadelphia, PA 19114. 2. Defendant(s) is/are ARTHUR F JONES, an adult individual residing at 1291 SUMMITVIEW CT NEW CUMBERLAND, PA 17070-2233. 3. At the special instance and request of Defendant, Plaintiff, CAPITAL ONE BANK(USA), N.A., issued to Defendant(s), Account #5178052220737684. 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 $2,014.29. 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 $2,014.29 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER & AS$OCAATES, P.C. BY: Attorney fo P A Law Firm Engage in Dated: 8/13/2008 David J. Esquire Our File No.: 150987 r VERIFICATION 1,111161114 , hereby states that I am for plaintiff in this .l_ _ 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: • . . • 1-800 flowers401n. Call 1-800-FLOWERS- (1-800-356-9377) or Click www.1800flowers.com today! Your florist of choice- L--------------------------------------------------------------------------------------------------J ?o lei- PLATINUM MASTERCARD ACCOUNT MAR 04 - APR 03, 2005 5178-0522-2073-7684 Page 1 of 1 r-------------------------------------------------------------------------------------------------- I Show Mom your love! Special savings for Capital One, Cardholders! 0 * on your next purchase when i /Q you use Promotion Code CAP66 ; Savel 5 (See reverse for details) Save this code! Offer good all year long! ; Remember: Mother's Day is Sunday, May At' Account Summary Payments, Credits mad Adjustments Previous Balance $1,052.41 =n Credits and Adjustments $.00 Ttaneacdons $35.00 Finance Charges $24.17 1 03 APR PAST DUE FEE $35.00 New Balance $1,111.58 Your request to close your account has been received. Your account will be closed when it readies a $0 balance. Minimum Amount Doe $1,111.58 Until then, you will continue to receive statements and must continue to make payments. All terms and Payment Due Date May 03, 2005 conditions of the account will apply while a balance remains. Please remember to cut your cards and cancel all chuges which automatically bill to your account Total Credit Line $500 Total Available Credit $.00 "Important Notice" Under the terms of your account, Capital One has the right to increase your Credit Line for Cash $500 Annual Percentage Rates (A.P.Rs) effective immediatdy. However, Capital One has dated not to Available Credit for Cash $.00 raise your A.P.Rs at this time. Please be advised that ifyou fail to abide by the terms ofyour agreement, Capital One reserves the right to raise your A.P.Rs in the fimre. At your sexvioe You were assessed a past due fee of $35.00 on 04/03/2005 because your minimum payment was not To call Customer Relations or to report a lost or storm card: received by the due date of 04/0212005. To avoid this fee in the future, we recommend that you 1-800-903-3637 allow at least 7 business days for your payment to reach Capital One. For free onlln aceamt service aced .pedal oatomer offer, log onto: - waw.oxpitalotse.com . Smd pa7samts to, Send inquiries to: Attn: Remitnam Promsiag - Cspital One Bank Capital One Ser im P.O. Bea 790216 P.O. Box $5015 St Louis, MO 63179-0216 Richmond, VA 23285-5015 Finance Chaiges Pkxe5ff remnende, for is patsat ix 6rmstiim Bdarerair ' P.riodsr Corrrr#arl M `R' ' dte N ?ppb sale APP liI , PURCHASES $1,06,05 .07326%P 26.74% $24.17 CASH $.00 .07326%P 26.74% A00 ANNUAL PERCENTAGE RATE applied this period 26.74% PLEASE RETURN PORTION BELOW WITH PAYMENT :aPftW()W* 0000000 0 5178052220737684 03 1111580030001111584 New Balance $1,111.58 Minvntun Amount Due $1,111.58 Payment Due Date May 03, 2005 Total enclosed S Account Number. 5179-0522-2073-7684 Pl. pridmad.Z ,Ii, -horn-mritd-Z. Moro rr 141. or K.4 ink Snsn Apt # City S- ZIP Home Fb- Alwam PAme #9009340438111207# MAIL ID NUMBER Capital One Bank ARTHUR F JONES P.O. Box 790216 IsIn1u11lu1tlulltl m 1291 SUMMITVIEW CT NEW CUMBERLAND PA 17070-2233 St. Louis, MO 63179-0216 ! Islluul1 11111111111111111111IsI11n1111I1u1111111111 11111I Its!IIus1IInlIusllluuslslu111nIIusllslsluulllslslsl Please va ite ymr errormt narraber on your check or money order made payable to Capital One Bank and mail in the endwed envelope r 0 4% W ? O V i ,oba SHERIFF'S RETURN - NOT FOUND CASE NO: 2008-05153 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CAPITAL ONE BANK (USA) N A VS JONES ARTHUR F 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 JONES ARTHUR F but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT & NOTICE , the within named DEFENDANT , JONES ARTHUR F , NOT FOUND , as to 1291 SUMMITVIEW CT NEW CUMBERLAND, PA 17070-2233 DEFENDANT DOES NOT LIVE AT GIVEN ADDRESS. Sheriff's Costs: Docketing 18.00 Service 34.00 Not Found 5.00 Surcharge 10.00 .00 Jo/DZ%o? L V 67.00 So answers- ---- - R. Thomas Kli Sheriff of Cumber nd County APOTHAKER & ASSOCIATES 09/15/2008 Sworn and Subscribed to before me this day of A. D. Our File No.: 150987 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(USA), N.A. Plaintiff, VS. ARTHUR F JONES Defendant. OF :rt-;E PRO7? r? TAW "'OFE6 -9 AM 9.53 cum FLU" ?s,'? COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 08-5153 PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & A Law Firm TES, P.C. for laintiff ed ' Debt Collecti By: David J Esquire Dated: 1/30/2010