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Home My WebLink About09-0726'Our File No.: 193969 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. JESSICA A RICHARD 1107 YVERDON DR APT B4 CAMP HILL, PA 17011-1250 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. Oq - '1d (P NOTICE 0'iv; (-r arm 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, Fife No.: 193 969 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. JESSICA A RICHARD 1107 YVERDON DR APT B4 CAMP HILL, PA 17011-1250 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 09- 72 L &. -a -77u- ^- 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 JESSICA A RICHARD, an adult individual residing at 1107 YVERDON DR APT B4 CAMP HILL, PA 17011-1250. 3. At the special instance and request of Defendant, Plaintiff, CAPITAL ONE BANK (USA),N.A., issued to Defendant(s), Account #5291491934422245. 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 $6,681.60. 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 $6,681.60 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER &P.C. Attorney rAO?IATES, l ' tiff A Law Firm Engaged in ebt Collection BY: Dated: 2/2/2009 David J. A0Qthk'er, Esquire Our File No.: 193969 V VERIFICATION ice! 41; hereby states that I am AW 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: go I I ? L I R N 4 R3.i N C W E C%i -.If td rr r r LE 16 It r r r 1-6 R Qa? o S -? l v z C4 Cam' Ab'? ?I i m --, Big= O 4 0310N OS t- (V Cb 0 ri 0 0 a %0 MP r+ S } i ' ? R I -g, mn alUoo3 L ? ? o0 rn a aLI U ?f7 a cz _ ? ? V 4 Da 146 ir a N N C 17 ?i f+ M M NOW Wftb FREE Accelerator • for the first 12 monthat-a 060 value i i - a month for A_ I first 3 mon ts; 40 $9.95/mo. thereafter 97 SIGN UP TODAY: ' 1-888-587-9669 Mention Offer Code: PEARL Or visit www.peoplepc..ni/go/pearl Account Summary Previous Balance $6,578.11 Payments, Credits and Adjustments $.00 Transactions $35.00 Finance Charges $.00 New Balance $6,613.11 Minimum Amount Due $6,613.11 Payment Due Date March 23, 2006 Total Credit Line $6,300 Total Available Credit $.00 Credit Line for Cash $3,150 Available Credit for Cash $.00 At your service To can Customer Relations or to report a lost or stolen nrd 1-800-955-7070 For free online amount service and special outomer offers, log on to: --pitdone.eom Send Pgo eau to: Send inquiries to: Attn: Remittance Proonsing Capital One Bank Capitsl One P.O. Box 790216 P.O. Box 302115 St Louis, MO 63179-0216 SLC, Ur 64130-0285 003 peoplepc- online 11? A better way to Intemet. PeoplePC Online offers all the features you would expect from higher-priced Internet Service Providers, including: ® Virus Protection Powered by Symaruec- ® Pop-Up BlockerTM' Spam controls a p,% Smarter Smart Dialer Technology 4gr LW More Email Addresses ® 0 Internet Call Wafting PLATINUM MASTERCARD ACCOUNT 5291-4919-3442-2245 JAN 24 - FEB 23, 2006 Page 1 of 1 Payments, Credits and Adjustvtents Transactions 1 23 FEB PAST DUE FEE $35.00 Your amount has recently been past due, overlimit, or has had a returned payment While Capital One reserves the right to increase your A.P.R. ifyou fail to maintain the terms of your account, we have chosen not to do so at this time as we value you as our customer and appreciate your business. Please keep your account in good standing in the furore to enable us w provide you with the best possible rates and level of service. Thank you for choosing Capital One. As a valued Capital One customer, you are eligible to receive a free Year-End Summary for this specific account that recaps your 2005 charges, provuw your account is in good standing and you have made transactions during the calendar year. Please call 1-877-794-4467 before March 31, 2006, to reserve your copy for this arccutnr Orders will be mailed out by the end of April 2006. You were assessed a past due fee of 335.00 on 02/23/2006 because your minimum payment was not received by the due date of 02/23/2006. To avoid this fee in the fitarq we recommend that you allow at least 7 business days for your payment to reach Capital One. )!'inane Charges Plemesee revmetidefir Iwtortant inforw4tion BeJ nrde Pesindsr C mxdwg ?TI,?1? ? gep&edte str R lt]AK PURCHASES 13,47456 . 00000% .00% A00 rn CASH 13,10355 . 00000% .00% 1.00 ANNUAL PERCENTAGE RATE applied dus period 0.00% PLEASE RETURN PORTION BELOW WITH PAYMENT 0000000 0 5291491934422245 23 6613110124996613119 New Balance $6,613.11 Minimum Amount Due $6,613.11 Payment Doe Date Match 23, 2006 Total enclosed i Account Number. 5291-4919-3442-2245 #9005534995559113# MAIL ID NUMBER JESSICA A RICHARD Capital One Bank - 1101 YVERDON P.O. Box 790216 111 II'I'111I11I11rIrll APT B4 St. Louis, MO 63179-0216 N CAMP HILL PA 17011 Pleme -teyo aaoraat nvm&r m yore c&rk or moray order madetayable to Capital One Bank and mail in the enclaed envelope. Pleareprn --d-g-1,&- ate --Ie anz Aek- inghi.orR" ,& Apt City S_ ZIP Home Phone Alnt Phone 40 Fms¢Ad& - r YC.? ti? F za ? fi? CD =0 SHERIFF'S RETURN - REGULAR CASE NO: 2009-00726 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CAPITAL ONE BANK USA N A VS RICHARD JESSICA A NOAH CLINE Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon RICHARD JESSICA A the DEFENDANT , at 0020:06 HOURS, on the 17th day of February-, 2009 at 1107 YVERDON DR, APT B4 CAMP HILL, PA 17011 by handing to JESSICA A RICHARD 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 Service Affidavit Surcharge Sworn and Subscibed to before me this So Answers: 18.0 12.660 00 • 10.00 R. Thomas Kline .00 40.60 02/18/2009 APOTHAKER & ASSOCIATES By: day Deputy Sheriff of A. D. ti 77