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HomeMy WebLinkAbout09-1631Our F,i1P?No.; 193679 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. WILLIAM L GESSNER 313 VALLEY ST SUMMERDALE, PA 17093 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: (R - I (o31 a-va le 'k 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 Eile No.: 193679 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. WILLIAM L GESSNER 313 VALLEY ST SUMMERDALE, PA 17093 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 0 9 - A 3/ (rte-- 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 WILLIAM L GESSNER, an adult individual residing at 313 VALLEY ST SUMMERDALE, PA 17093. 3. At the special instance and request of Defendant, Plaintiff, CAPITAL ONE BANK (USA),N.A., issued to Defendant(s), Account #4862362390352733. 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 $2,450.25. 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 $2,450.25 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER & SOCIATES, P.C. Attorne r Plaintiff A Law Firm En a d in Debt Collection BY: David I Apodcer, Esquire Dated: 3/10/2009 Our File No.: 193679 VERIFICATION h I 4 , 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: ' e 4 ' Now with FREE Accelerator • • for the that 12 monthsr-a $60 wise 7 - e mnrlth for first 3 months: 14$4 1 59.9&mo. thereafter SIGN UP TODAY! ' 1-888-587-9669 Mention Offer Code: EMERALD Or visit www.peoplepc.oom/go/ameraid PLATINUM VISA ACCOUNT 4862-3623-9035-2733 Acoount Summary Payments, Credits and Adiustments FEB 20 - MAR 19,20% Page 1 of 1 Previous Balance $1,34162 Payments, Credits and Adjustments $.00 Transactions Transactions $29.00 Finance Charges $26.93 1 19 MAR PAST DUE FEE $29,00 New Balance $1,39&55 You were assessed a past due fee of $29.00 on 03/19/2006 because your minimum Payment was not Minimum Amount Due $1,39855 received by the due date of 03/18/2006. To avoid this fee in the fume, we recommend that you Payment Due Date April 19, 2006 allow at least 7 business days for your payment to reach Capital One. Total Credit Line $1,000 Total Available Credit $.00 Credit Line for Cash $1,000 Available Credit for Cash $.00 At your service I. till O stoner Relations or to report a lort -rtolrn ow& I-800-903-3637 For five ordine a arrt aervioe -d spend ovtoom offer, log on to w .apitdone.com Send paymmu to: Send ioguris to Attn: Rantittanot Prop-ing CapitdOneB-k Capiw out P.O. Box 790216 P.O. Bor 30295 St. Lana, MO 63179-0216 SLC, UT 84130-0285 Important Account Information please review the enclosed privacy information and retain it with your aoeoura records Also visa www.capitalone.com/creditcards and click on the Visit the Guide to Benefits link to learn about your latest Visa. or MasterCard. account benefits. The dese ipfiom m this online guide replace any information you received in the Past For a printed copy of the Guide to Benefits, call the Customer Relations number on the back ofyour card. m PLEASE RETURN PORTION BELOW WITH PAYMENT V 0000000 0 4862362390352733 19 1398550200001398552 New Balance $1,39&55 Minimum Amount Due $1,39&55 Payment Drat Date April 19, 2006 Total enclosed $ Amount Number. 4862-3623-9035-2733 Finance Charges Pl "Av reverxrrdafar importaw iinnfirmat ionn BdanrerWe ti A,.,6& 71 gPfuda. wr CHARGE' PURCHASES 51,35556 .07096% 25.90% $26.93 CASH S.00 .07096% 25.90% $.00 ANNUAL PERCENTAGE RATE applied this period 25.90% PI-p,w.arr„agaZi--i, --td-q. klemmergb! orK k:R.k Street Apr, Y Gry Sum ZIP Home Phone Almrnam Phone Em,aAd&- #9007861401092050# MAIL ID NUMBER Capital One Bank WILLIAM L GESSNER r_ P.O. Box 790216 ?1 11111111111111 11 111 1 PO BOX 241 St. Louis, MO 63179-0216 SUMMERDALE PA 17093-0241 Plcarc vriteyouraetount numberm yon djeak o/ moray order madepayable to Capital OwBank mid mail in the endmed envelope. 003 peoplepc- online %-? A Fetter way to Intemet. PeoplePC Online offers the features you would expect from higher-priced Internet Service Providers at half price for the first 3 months! Virus Protection powered by Symantec- ® Pop-Up BlockerTm Spam Controls Smarter Smart Dialer Technology ® ?W More Email Addresses dW % Internet Call Waiting r ?!- ? ? C N f-?i F, 0 ? • ??? ? ? ? ? ? -c `?` ??; ?? Z' 's C' ? ~ N ?? ? . ?? ? ;? N Sheriffs Office of Cumberland County R Thomas Kline ?Y7 0t x.embfr a:u vv aau ., vvuvaYY Sheri 41, r ? Solicitor Ronny R Anderson Jody S Smith Chief Deputy OFFICE OF THE SHERIFF Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 03/17/2009 06:57 PM - Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on March 17, 2009 at 1857 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: William L. Gessner, by making known unto Wisam L Gessner personally, at 313 Valley Street, Summerdale, Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $42.40 (PAID) March 18, 2009 2009-1631 Capital One Bank VS William L. Gessner SO ANSWE R THOMAS KLINE, SHERIFF By Deputy Sheriff ?; %i ?'" ?_ :; = = :.. ; .???r `