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Home My WebLink About09-0725q6 Our File No.: 193708 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. AMBER E WAY 323 BRIDGE ST APT B NEW CUMBERLAND, PA 17070 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: N- '1d5 Gvit lem 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 Cur File No.: 193708 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. AMBER E WAY 323 BRIDGE ST APT B NEW CUMBERLAND, PA 17070 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: b q- 7? S .f F-1 NO.: 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 AMBER E WAY, an adult individual residing at 323 BRIDGE ST APT B NEW CUMBERLAND, PA 17070. 3. At the special instance and request of Defendant, Plaintiff, CAPITAL ONE BANK (USA),N.A., issued to Defendant(s), Account #4862362499384843. 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 $1,434.70. 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 $1,434.70 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER & A5-SO TES, P.C. Attorney fair Pt tiff A Law Firm Engaged in, ebt Collection r r BY: David J. Apo er, Esquire Dated: 2/2/2009 Our File No.: 193708 VERIFICATION fit r 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 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: CAPITAL ONE BANK (USA),N.A. AMBER E WAY 323 BRIDGE ST APT B NEW CUMBERLAND, PA 17070 STATEMENT OF ACCOUNT Debtor's Name: AMBER E WAY Account Number: 4862362499384843 Balance Due: $1,434.70 Our File No.: 193708 EXHIBIT "A" # CPO 17 :? ca n SHERIFF'S RETURN - NOT FOUND CASE NO: 2009-00725 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CAPITAL ONE BANK USA N A VS WAY AMBER E 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 WAY AMBER E but was unable to locate Her in his bailiwick. He therefore returns the NOTICE COMPLAINT NOT FOUND , as to the within named DEFENDANT , WAY AMBER E 323 BRIDGE ST, APT B NEW CUMBERLAND, PA 17070 DEFENDANT DOES NOT RESIDE AT ADDRESS STATED, LEFT FORWARDING OF P.O. BOX 194, LAWRENCEVILLE, PA 16929 Sheriff's Costs: So answerJs_- Docketing 18.00 1 - -~ Service 16.20 Not Found Return 5.00 R. Thomas Kline Surcharge 10.00 Sheriff of Cumberland County .00 49.20 APOTHAKER & ASSOCIATES 03/05/2009 Sworn and Subscribed to before me this day of , A. D. JLLJ t5 ra U Our File No.: 193708 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. AMBER E WAY D-OFFICE Dr THELP O THON TAFFY 2010 DEC -6 PM 2: 52 CUMBERLAND COUNTY PENNSYLVANIA COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 09-725 Defendant. PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & AS Attorneys s A Law Firm Ens ed By: David J. Dated: 11/24/2010 kTES, P.C. bt Collection