HomeMy WebLinkAbout09-1082..,
Our File No.: 193 873
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.
JASON R WHITEHEAD
4008 GOLFVIEW DR
MECHANICSBURG, PA 17050-2250
Defendant.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO.: d9 - ( 0$a OiV?L e-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.: 193873
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.
JASON R WHITEHEAD
4008 GOLFVIEW DR
MECHANICSBURG, PA 17050-2250
Defendant.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO.: 6,9 - /b? z ct?'j T
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 JASON R WHITEHEAD, an adult individual residing at 4008 GOLFVIEW
DR MECHANICSBURG, PA 17050-2250.
3. At the special instance and request of Defendant, Plaintiff, CAPITAL ONE BANK (USA),N.A.,
issued to Defendant(s), Account #5178052504417508.
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 $2,539.42. 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
$2,539.42 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law.
APOTHAKER AS OCIATES, P.C.
. .. ,.,.
A Law Firm Erkage4 in Debt Collection
BY:
Dated: 2/6/2009
David J.'Akfiaker, Esquire
Our File No.: 193873
VERIFICATION
ra( - , 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.
JASON R WHITEHEAD
4008 GOLFVIEW DR
MECHANICSBURG, PA 17050-2250
STATEMENT OF ACCOUNT
Debtor's Name: JASON R WHITEHEAD
Account Number: 5178052504417508
Balance Due: $2,539.42
Our File No.: 193873
EXHIBIT "A"
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SHERIFF'S RETURN - REGULAR
CASE NO: 2009-01082 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
CAPITAL ONE BANK USA N A
VS
WHITEHEAD JASON R
STEVE BENDER
Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE
WHITEHEAD JASON R
was served upon
DEFENDANT
the
at 0017:15 HOURS, on the 24th day of February-, 2009
at 4008 GOLFVIEW DR
MECHANICSBURG, PA 17050-2250
MELISSA WHITEHEAD
by handing to
WIFE OF DEFENDANT
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
Service
Affidavit
Surcharge
Sworn and Subscibed to
before me this
So Answers:
18.00
11.70
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10.00 R. Thomas Kline
.00
39.70 02/25/2009
APOTHAKER & ASSOCIATES
By:
day Deputy Sheriff
of A. D.
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