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Home My WebLink About08-6079Our File No.: 177334 '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. ROBIN G LIGHTY 3414 WALNUT ST CAMP HILL, PA 17011-2744 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. d$- (vpqq Civil ier m 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 Our File No.: 177334 '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. ROBIN G LIGHTY 3414 WALNUT ST CAMP HILL, PA 17011-2744 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: n 1- 4 0 ?1 Cu ;U -I'Z -- 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 ROBIN G LIGHTY, an adult individual residing at 3414 WALNUT ST CAMP HILL, PA 17011-2744. 3. At the special instance and request of Defendant, Plaintiff, CAPITAL ONE BANK (USA), N.A., issued to Defendant(s), Account #5178052298673175. 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 $1,748.61. 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 $1,748.61 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER & ASSO TES, P.C. Attorney for ' tiff A Law Firm EnRaRed ebt Collection BY: David J. Dated: 10/3/2008 Our File No.: 177334 VERIFICATION -4d, A14 hereby states that I am 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 comd 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: 4ft - j / First 3 months half-price 97 s "'°""' $"WITlo. alerafler =FREEAccekwattooe SIGN UP TODAYI ' 1-877-778-1207 Mention Offer Code: OPAL Or visit www.peoplepc.corNgo/opW peoplepa- online A better way to Internet. PeoplePC Online offers the features you would expect from higher-priced Internet Service Providers at half price for the first 3 months! ® Email Virus Protection ® Pop-Up BlockerTM Spam controls ® Smart Dialer Am IU More Email Addresses ® f# Internet Call Waiting Account previous Balance $1,035.73 Payments, Credits and Adjustments $.00 Transactions $35.00 Finance Charges $23.02 New Balance $1,093.75 Minimum Amount Due $1,093.75 Payment Due Date July 11, 2006 Total Credit Line $600 Total Available Credit $.00 Credit Line for Cash $600 Available Credit for Cash $.00 At your service To aB Owonur RAsfe or to report a loot or stolm cud: 1-800-903-3637 For free ordi sorount seevia amd spend outemer off ra, bog on to: we oq iwoftc O Sind paymevu to: Smd iagairies t« Art.Remins-Proo-ng Capital One Beak Capinl One P.O. Bar 790216 P.O. Bea 30285 St Lou6, MO 63179-0216 SLC, Vf 84190-0285 it Account btformirtion Take control and start paying your bill online for fife. Eliminate the hassle of wrting checks, finding stamps, and sealing envelopes. Evaything you need to access, review, and pay your bill is available online. Our webake offer ywu a convemient, simple, and secure way to manage your account Visit www.capitalow-com and register your account to start simplifying your life to*- PLATINUM MASTERCARD ACCOUNT 5178-0522-9867-3175 MAY 12 - JUN 11, 2006 Page 1 of 1 Payments, Credits and Adjustments Transactions 1 11 JUN PAST DUE FEE $35.00 You were assessed a past due fee of $35.00 on 06/11/2006 because your minimum payment was not received by the due date of 06/10/2006. To avoid this fee in the future, we recommend that you allow at least 7 business days for your payment to reach Capital One. FinanceC62sw Pkarasaermffje &forimp damtiskrmation Balavr,asr Ewa gpprmJss rWr PURCHASES 91,038.96 .07054% 25.9016 $2285 CASH $7.86 .070%% 25.90% L17 ANNUAL PERCENTAGE RATE applied this period PLEASE RETURN PORTION BELOW WITH PAYMENT X2110 0000000 0 5178052298673175 11 1093750035001093751 New Balance $1,093.75 Minimum Amount Due $1.093.75 Payment Due Date July 11, 2006 Total enclosed $ AoeountNumber. 5178-0522-9867-3175 Pfarprfat'_rVrliramY rmaile q.hdon.ms yl_ -,W.*kk 25.90% Stn Apt + Cty s_ ZIP Home Phone Almmat Phone #9016253278418510# MAIL ID NUMBER Capital One Bank ROBIN G LIGHTY P.O. Box 790216 111111111111111111 1111 aa1? 3414 WALNUT STREET St. Louis, MO 63179-0216 °m CAMP HILL PA 17011-2744 0 Is 111111111111III111111111111111111111111111111111111111Is1111 $ PL-e wriuyosr arrmmt rewnberon yom chad or momy order madepayable to Capital Ow Rani mid mail in theendared enmelope. r C1 DO W = ? n c:D F { - 0-1 F tt SHERIFF'S RETURN - REGULAR CASE NO: 2008-06079 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CAPITAL ONE BANK USA N A VS LIGHTY ROBIN G RONALD HOOVER Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE LIGHTY ROBIN G was served upon the DEFENDANT , at 1931:00 HOURS, on the 21st day of October , 2008 at 3414 WALNUT STREET CAMP HILL, PA 17011-2744 ROBIN G LIGHTY by handing to a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 15.00 Affidavit .00 Surcharge 10.00 00 !? J? ??OP gw 4 3 . 0 0 Sworn and Subscibed to before me this day So Answers: R. Thomas Kline 10/21/2008 APOTHAKER & ASSOCIATES By: Deputy Sheriff of A. D. Our File No.: 177334 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker Attorney I.D.# 38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 CAPITAL ONE BANK (USA), N.A. Plaintiff, VS. ROBIN G LIGHTY Defendant. Attorney for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-6079 Civil Action PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment against Defendant, ROBIN G LIGHTY, in the default of an Answer, in the amount of $1,788.70 computed as follows: Amount claimed in complaint: $1,748.61 Amount Paid: - $(0.00) Interest from October 03, 2008 to 05/14/09 at the legal interest rate of 6.000 per annum $40.09 Costs $0.00 Attorney fees $0.00 TOTAL $1,788.70 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, ROBIN G LIGHTY, last know address is 3414 WALNUT ST CAMP HILL, PA 17011- 2744. IATES, P.C. APOTHAKER & SIlaintiff Attorn ey for A Law Firm En ized Debt Collectioi By: David Dated: 5/14/2009 4- A OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS TO: ROBIN G LIGHTY 3414 WALNUT ST CAMP HILL, PA 17011-2744 CAPITAL ONE BANK (USA), N.A. Plaintiff, VS. ROBIN G LIGHTY Defendant. NOTICE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-6079 Civil Action 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 clip 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, Esq. at this telephone number: 215-634-8920 sf261o9 Our File No.: 177334 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. NO.: 08-6079 ROBIN G LIGHTY Defendant. 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 3414 WALNUT ST CAMP HILL, PA 17011-2744. We inquired with the web site of the Deft Boulevard, Suite 400, Arlington, VA 22209-2593, if Mary M. Silavely-Dixon, Director of the indicated that the Defendant(s) is/are not in the i David J. Apothaker Attorney for Plaintiff r Data Center, located at 1600 Wilson s) is/are in any branch of the military. Center has sent back our inquiry 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. It Depa bwm of Ddwse Manpower Data Center Military Stains Report PurSat to dre Savicesnbers Civil Relief Act AICIV -A( :ew. Mary M. Sur: i3mxk Dxect c Dqmftment of Ddense - Maapcwer Data Center 1600 Wilson Wit., Smite 400 Adis, VA 22249-2593 MAY-14-2009 06:48 The D Mmp wer Data Center (DMDC) is an orpmadan of the Departiueat afDela that maintains the Defense Rrasollment and ElO&Y Repmx m System (DEERS) database which is the afficial sow= of data an W for Flory me t care and odber elloiliy system. 'The Deparbsent ofDe£mse *on#y supports the edwcernent ofibe Savic hers Civil ReWAct [50 USCS Apps` ff 501 et seq] {SCRA) Oximeity lire Saidere and Sailore Civil ReWAd of 1940}_ DWDC has issued hundreds of timsmads of "does not possess any m&x abm iadicating that the kwividual is cuwa * an active d W reRmoses. and has eg iienced a swel error rate. In the event the k&idmd r eed abcive, or arty fardty mbar. Mend, or represe ta*e asserts in may mercer drat the iiadiivi&m i is an active duty, at is o +e eared to dre protections of the SCRA, you we st m* encouraged to obtain fnrdmw verification, of'the persona's acme dity status by cor og do perseds Airy Service Va'the "drat nmT URL provided below. Myo have evkknee dw person is an actim-day and you fid to obtain this adMoaat wry Service veri6icatim provisions, of dw SCRA may be invoked against you. If you obtain thrdher nforaratim about the person (e g., an SSN, improved accuracy of DOB, a middle same, you, can shit your request again at dis Web site and we wi l pa de anew cite far diat query. This response rdkcts current active duty staff cnty. For bistoncat ' pie s+e coataot the NMIRFY SCMW SCPA pbiots-Jukrzoation, of-contact. See- IMWIIwavw: mil WARNrDiCr. This certificate was prod based an a manse and Social Security tar gw (SSN) prvvkled by the requeor. ProvAmg an erroneous aacse or SSN will came an woomm certfiate to be provided. Rapo"JD nQ YQRXS Upon watching the ieifar nbm dam beatcs cf the Department of Defense Maapoureer Data Cmta, based an the m&umom you proMed, the above is the current stag of the in&vi&d as to al branches of the Amy. 177334 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY CAPITAL ONE BANK (USA), N.A. ) COURT OF COMMON PLEAS CUMBERLAND COUNTY VS. ) ROBIN G LIGHTY ) NO. 08-6079 } To: ROBIN G LIGHTY 3414 WALNUT ST CAMP HILL, PA 17011-2744 NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT Date of Notice: November 21, 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 DAMN. APOTHAKER, ESQUIRE APOTHAKER & 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 SHERIFF'S RETURN - REGULAR CASE NO: 2008-06079 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CAPITAL ONE BANK USA N A VS LIGHTY ROBIN G OC 1 3 1 1tJU RONALD HOOVER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon LIGHTY ROBIN G the DEFENDANT , at 1931:00 HOURS on the 21st day of October 2008 at 3414 WALNUT STREET CAMP HILL, PA 17011-2744 by handing to ROBIN G LIGHTY a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: So Answers: Docketing Service 18.00 15.00 Affidavit .00 , Surcharge 10.00 R. Thomas Kline .00 43.00 10/21/2008 APOTHAKER & ASSOCIATES Sworn and Subscibed to By: before me this day Deputy Sheriff of A.D. 11 FILED-Di'FI 2 0 0 9 N Y 20 AM Iu: 4 W1 J OIJ4.0,0 ?Ct '494 Q WA /-31/7S-7 R--*L 122 sYC) IU04 le? m-1 i&L Our File No.: 177334 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. ROBIN G LIGHTY Defendant. :x12 MAY 24 AM I I : 09 CUMBERLAND COUNT', PENNSYLVANIA COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 08-6079 PRAECIPE TO MARK JUDGMENT SATISFIED TO THE PROTHONOTARY: Please mark the Judgment Satisfied against the Defendant. Judgment has been paid in full. APOTHAKER & Attorneys A Law Firm EngaA By: David J )CIATES, P.C. laintiff Debt Collection , Esquire y.sa"'2.461'`e191J" ,&M '?) 7 SCoS V