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Home My WebLink About09-1150 Our File No.: 136607 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. STACI E MARTINEZ 104 ELK DRIVE CARLISLE, PA 17015-7784 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. jA - 1150 NOTICE ?iv ? l l ex'rh 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 1 Our File No.: 136607 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. STACI E MARTINEZ 104 ELK DRIVE CARLISLE, PA 17015-7784 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 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 STACI E MARTINEZ, an adult individual residing at 104 ELK DRIVE CARLISLE, PA 17015-7784. 3. At the special instance and request of Defendant, Plaintiff, CAPITAL ONE BANK (USA), N.A., issued to Defendant(s), Account #5307582077053425. 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 $1,385.72. 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 $1,385.72 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER & Ydin C TES, P.C. Attorney l 'tiff A Law Firm Engag ebt Collecki6r BY: David J. Dated: 2/12/2009 Our File No.: 136607 VERIFICATION k f 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. STACI E MARTINEZ 104 ELK DRIVE CARLISLE, PA 17015-7784 STATEMENT OF ACCOUNT Debtor's Name: STACI E MARTINEZ Account Number: 5307582077053425 Balance Due: $1,385.72 Our File No.: 136607 EXHIBIT "A" -..} hJ =7> 5 - t 00 v O0 A :' v SHERIFF'S RETURN - NOT FOUND M t CASE NO: 2009-01150 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CAPITAL ONE BANK USA N A VS MARTINEZ STACIE 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 MARTINEZ STACI E but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT & NOTICE , the within named DEFENDANT , MARTINEZ STACI E NOT FOUND , as to 104 ELK DRIVE CARLISLE, PA 17015-7784 PER NEIGHBOR, DEFENDANT MOVED OUT A MONTH AND A HALF AGO; PER THE POST OFFICE, MAIL IS STILL DELIVERED THERE. Sheriff's Costs: Docketing 18.00 Service 4.50 Not Found 5.00 Surcharge 10.00 .00 37.50 So answers: R. Thomas line Sheriff of Cumb gland County APOTHAKER & ASSOCIATES 03/09/2009 Sworn and Subscribed to before me this day of A. D. t?5 CIE! ? f t ? Q ? N U Our File No.: 136607 FILED-OFF ICE APOTHAKER & ASSOCIATES, P THE PROTHDNnTAR?? BY: David J. Apothaker, Esquire 2010 DEC -6 PM 2: 53 Attorney I.D.# 38423 520 Fellowship Road C306 CUMBERLAND COUNTY Mount Laurel, NJ 08054 PENNSYLVANIA (800) 672-0215 Attorney for Plaintiff CAPITAL ONE BANK (USA), N.A. Plaintiff, vs. STACI E MARTINEZ Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 09-1150 PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & ASOCIATES, P.C. A Law Firm Engaged ih Debt Collection By: David J. Apothaker, Esquire Dated: 11/24/2010 1*111?16101111111111