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Home My WebLink About08-6061 Our File No.: 177401 APOTHAKER & ASSOCIATES, P.C. $Y: David J. Apothaker, Esquire, Esq. Attorney I.D.#38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff CAPITAL ONE BANK (USA), N.A. c/o Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 Plaintiff, VS. JILL D MALIS 200 PENNSYLVANIA AVE CAMP HILL, PA 17011-5436 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: b8-&o(oI aivit 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. 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 A Our ]file No.: 177401 APOTHAKER & ASSOCIATES, P.C. bY: David J. Apothaker, Esquire, Esq. Attorney I.D.#38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff CAPITAL ONE BANK (USA), N.A. c/o Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 Plaintiff, VS. JILL D MALIS 200 PENNSYLVANIA AVE CAMP HILL, PA 17011-5436 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 4F- 6041 0 ? A d- lu.??. CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is CAPITAL ONE BANK (USA), N.A. c/o Apothaker & Associates, P.C., 520 Fellowship Road C306, Mount Laurel, NJ 08054. 2. Defendant(s) is/are JILL D MALIS, an adult individual residing at 200 PENNSYLVANIA AVE CAMP HILL, PA 17011-5436. 3. At the special instance and request of Defendant, Plaintiff, CAPITAL ONE BANK (USA), N.A., issued to Defendant(s), Account #5178052391330491. 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 $1,843.92. 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. a WHEREFORE, Plaintiff demands judgment in favor of Plaintiff and against Defendant(s) for the sum of $1,843.92 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER & AS Attorney for A Law Firm EnLyaQed/ BY: Dated: 10/2/2008 RTES, P.C. Collection. David J. Apoth?ker Esquire Our File No.: 177401 I VERIFICATION hereby states that I am Lim 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: CAPITAL ONE BANK (USA), N.A. JILL D MALIS 200 PENNSYLVANIA AVE CAMP HILL, PA 17011-5436 STATEMENT OF ACCOUNT Debtor's Name: JILL D MALIS Account Number: 5178052391330491 Balance Due: $1,843.92 Our File No.: 177401 EXHIBIT "A" ? c:n ` 0 0 i 9b Of ? ? Cj ` •? rig ?.?-_' ? ? v`a LIJ r SHERIFF'S RETURN - REGULAR CASE NO: 2008-06061 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CAPITAL ONE BANK USA N A VS MALIS JILL D VALERIE WEARY Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon MALIS JILL D the DEFENDANT , at 0013:54 HOURS, on the 16th day of October , 2008 at 200 PENNSYLVANIA AVE CAMP HILL, PA 17011-5436 JILL D MALIS by handing to DEFENDANT 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 14.00 Affidavit .00 Surcharge 10.00 .00 /o?x3Jb? 42.00 Sworn and Subscibed to before me this day So Answers: R. Thomas Kline 10/17/2008 APOTHAKER & ASSOCIATES By //,.Xz- S e iff of A. D. w Our File No.: 177401 APOTHAKER & ASSOCIATES, P.C. Attorney for Plaintiff BY: David J. Apothakerr Attorney I.D.# 38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 CAPITAL ONE BANK (USA), N.A. ) COURT OF COMMON PLEAS OF Plaintiff, ) CUMBERLAND COUNTY VS. ) NO.: 08-6061 JILL D MALIS ) Defendant. ) Civil Action PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment against Defendant, JILL D MALIS, in the default of an Answer, in the amount of $1,881.02 computed as follows: Amount claimed in complaint: $1,843.92 Amount Paid: - $(0.00) Interest from October 02, 2008 to 05/14/09 at the legal interest rate of 6.000 per annum $37.10 Costs $0.00 Attorney fees $0.00 TOTAL $1,881.02 I hereby certify that the appropriate Notices of Default, as attached have been mailed in accordance with Pa.R.Civ.P. 237.1 on the dates indicated on the Notices. I certify Defendant, JILL D MALIS, last know address is 200 PENNSYLVANIA AVE CAMP HILL, PA 17011-5436. APOTHAKER AS OCIATES, P.C. Attorn s f Plaintiff A Law Firm En ag in t Collection By: David . Apothaker Dated: 5/14/2009 I as OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS TO: JILL D MALIS 200 PENNSYLVANIA AVE CAMP HILL, PA 17011-5436 CAPITAL ONE BANK (USA), N.A. Plaintiff, vs. JILL D MALIS Defendant. COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-6061 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. 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 IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: ATTORNEY David J. Apothaker, Esc. at this telephone number: 215-634-8920 s/2o%y C Our File No.: 177401 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. Plaintiff, vs. JILL D MALIS Defendant. COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-6061 Civil Action AFFIDAVIT OF NON-NULITARY 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 200 PENNSYLVANIA AVE CAMP HILL, PA 17011-5436. We inquired with the web site of the Defense ower Data Center, located at 1600 Wilson Boulevard, Suite 400, Arlington, VA 22209-2593, if Kanpower dant(s) is/are in any branch of the military. Mary M. Snavely-Dixon, Director of the Def se Da enter has sent back our inquiry indicated that the Defendant(s) is/are not in the mili David J. othaker Attorney for Plaintiff The above signed understands that the statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DepartmedofDefense Manpower Data Cefter MAY-14.20091 7.09 Upon searching the aafxmaban data banks of the De met of Ike Manpower Din Cam, based on the xfortuatim that you provided, the above is the cauatt statas cf'the iudreid ad as to all branches of The fir. Mary X Saav* Mon. Director Dqxfftmem of Demise - Manpower Data Curter 1600 Wilsaa Blv%L. Suite 400 Ate, VA 22209-2593 Mw Defeaxe Manpower Data Caster OWQ is an aganzadw of the Deparknadf dDefsnse drat xamintains the Defime Ea vbuaat and RqmrtogSystem (DDS) ddebase w%&is tht somm of data of Ry for iry rare and other doility system. Ilse Dqmrkmeut of Defense strongly sWpods the erfixcement of die S be rs Carve ROWAct 150 USCS Appx_ +§ 381 et segl (SCRA) (f mumlS? the Sys' and Sailors' Chi R Act of 1944)_ IBC bas issued hundreds oftliowands of *does not possess aaryaailio n indicating that the individnal is cone* on active dray" responses, and has end a small ;error rate. In the evert the iklividad refisenced above, or arty family smenim, friend, or repro ve asserts in say entente diet the indevi&d is on acts duty, or is owe eddied to the protections of the SCRA, you we stron* encouraged to obtain gather vefficebon o f the perscds active duty stem by contacting that perseds Military Service vk the * mi URL provided bebwv. Nyou have evidence the person is on actin-daty and you tsrl to obtain this Militia" glary Service s provisions cf the SCRA way be invoked against you. Myou obtain fix r kfinnation abut the person ( e.g., an, SSN, improved accuracy of DOB, a middle namme), you can sa I your request again at this Web site and we will pwvide a new certificate for that query. 'This response re1ks current active duty stop only For ' butwical afirmation, please contact the teary Service SCRA pows- of-coutact. Se% bttcdh ww. ' WAR 4R4G- Ttis cue was provided based on a name and Sock Security r r (SSN) provided by the requeder, Providing an =oneoos meant at SSN will casxse an arroneous comae to be provided. RVar M-n"7- wjxK Mary Status Report Pumamat to the Services Civil ReWArt 177401 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY CAPITAL ONE BANK (USA), N.A. ) COURT OF COMMON PLEAS CUMBERLAND COUNTY VS. ) JILL D MALIS ) NO. 08-6061 To: JILL D MALIS 200 PENNSYLVANIA AVE CAMP HILL, PA 17011-5436 NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT Date of Notice: December 03, 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 ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 BAR DA J. APOTHAKER, ESQUIRE APOT R & ASSOCIATES, PC A Law Firm Engaged in Debt Collection 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff Attorney ID #38423 TI L Q SHERIFF'S RETURN - REGULAR CASE NO: 2008-06051 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND j ? 31? I.S j . ! , , J i l l CAPITAL ONE BANK USA N A? (( iI NOY VS J MALIS JILL D VALERIE WEARY , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon MALIS JILL D the DEFENDANT at 0013:54 HOURS, on the 16th day of October , 2008 at 200 PENNSYLVANIA AVE CAMP HILL PA 17011-5436 by handing to JILL D MALIS -DEFENDANT a true and attested copy of COMPLAINT & NOTICE together with and at the same time directng.Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 14.00 Affidavit .00 Surcharge 10.00 .00 42.00 Sworn and Subscibed to before me this day of , So Answers: / }f R. Thomas Kline f 10/17/2008 APOTHAKER & ASSOCIATES By: A;:?- eputy S iff A.D. FILE !r'C f E .. #- ti_ 71 AR 2q? 0 9 ) f' 2Q firs 10.40 e? i3y?s? ?-?E .2.2 s yrf AI-4