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Home My WebLink About09-1092x Our File No.: 193978 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. MARGARET L PATRICK 90 FAIRVIEW ST #R CARLISLE, PA 17015 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. 09 logo. NOTICE IYou 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.: 193978 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. MARGARET L PATRICK 90 FAIRVIEW ST #R CARLISLE, PA 17015 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: O 9 - / 6 9 et?j 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 MARGARET L PATRICK, an adult individual residing at 90 FAIRVIEW ST #R CARLISLE, PA 17015. 3. At the special instance and request of Defendant, Plaintiff, CAPITAL ONE BANK (USA),N.A., issued to Defendant(s), Account #5291492196267997. 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 $13,919.18. 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 $13,919.18 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law APOTHA E, & SSOCIATES, P.C. Att rney or Plaintiff A Law Firm nig ed in DebtRllectioi BY: Dated: 2/10/2009 David X_AWfhaker, Esquire Our File No.: 193978 ff • .M CAPITAL ONE BANK (USA),N.A. MARGARET L PATRICK 90 FAIRVIEW ST #R CARLISLE, PA 17015 STATEMENT OF ACCOUNT Debtor's Name: MARGARET L PATRICK Account Number: 5291492196267997 Balance Due: $13,919.18 Our File No.: 193978 EXHIBIT "A" P . it O og r v i SHERIFF'S RETURN - REGULAR CASE NO: 2009-01092 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CAPTIAL ONE BANK USA N A VS PATRICK MARGARET L STEVE BENDER Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE PATRICK MARGART L the DEFENDANT , at 0020:45 HOURS, on the 27th day of February-, 2009 at 90 FAIRVIEW ST #R CARLISLE, PA 17015 MARGARET PATRICK DEFENDANT was served upon by handing to 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: 18.00 4.50 00 r 10.00 R. Thomas Kline .00 32.50 03/02/2009 APOTHAKER & ASSOCIATES By: day Deputy Sheriff of A. D. t a J