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Home My WebLink About09-1644`bur Ffle No.: 197742 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. FRANK D ARMSTRONG 1231 HIGHLANDER WAY MECHANICSBURG, PA 17050-8302 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: Chi - 1(pqy alv i L-[.;rvK 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 -bur File No.: 197742 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. FRANK D ARMSTRONG 1231 HIGHLANDER WAY MECHANICSBURG, PA 17050-8302 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY q q Cam( ??.,. NO.: 0 ct _ /I 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 FRANK D ARMSTRONG, an adult individual residing at 1231 HIGHLANDER WAY MECHANICSBURG, PA 17050-8302. 3. At the special instance and request of Defendant, Plaintiff, CAPITAL ONE BANK (USA),N.A., issued to Defendant(s), Account #5178052299186029. 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 $1,353.53. 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 $1,353.53 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKE7Mayl SSOCUTES, P.C. Atto r Plaintiff A Law Firm E in Debt Lyollectini BY: David J. Aaker, Esquire Dated: 3/9/2009 Our File No.: 197742 VERIFICATION ?y 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: Cap WOW what's in your wallet?* FRANK D ARMSTRONG ® 2006 Capital One Services, Inc. Capital Ora is a frdenx/[y rcgirured service mark. AU sightr raer,, 060-07754 R PLATINUM MASTERCARD ACCOUNT AUG 12 - SEP 11, 2006 5178-0522-9918-6029 Page 1 of 1 Account Summary Payments, Credits and Adjustments Previous Balance Payments Credits and Adjustments Tnnsaclions $73112 $.00 Transactions Finance Charges $29.00 $16.28 1 11 SEP PAST DUE FEE $29.00 New Balance Minimum Amount Due P D $777,40 $27-7.40 You're behind by five payments - so we've permanently, suspended yrour charging privikgm If you don't make a sufficient payment in the neat 60 days, well charge offyour account Ifyour account is re ort d t ayment ue Date October 12, 2006 p e o national credit bureaus as charged off, itll have a serious impact on your credit record. Please don't let this Total Credit Line $500 happen. You can prevent any further damage to your credit by paying the amount due on yrour statement. If you're feeling overwhelmed, give us a call at 1 800 955 6600 W ll Total Available Credit $.00 . . . , e work with you to resolve il»s matter. Credit Line for Cash Available Credit for Cash $500 $,00 NOTICE: Look for a new statement design for your Capital One credit card beginning neat month. A summary of the key changes will be rovided with p your new statement Atymlrservice You were assessed a past due fee of $29.00 on 0911112006 because your minimum payment was not received b the due d t f 09/1 / T ll C y a e o 1 2006. To avoid this fee in the future, we recommend that ou o a ustomer Rdatiom or to report • tort or stolen nrd y allow at least 7 business days for your Payment to reach Capital One 1-800-903-3637 . For free online seooumt service and spedd wtomer o$et-, log on to: -..npatiloneuom Send pgmmu t« Send inqu tier to: Attn: Renattanoe Proosaing Capital One Bank C*W One P.O. Bor 70884 P.O. Boa 302&5 Charlotte, NC 28272-0884 SLC, UT 84130-0285 Important Account Infortnation Beginning October 1st, 2006, based on your account activity you may be assessed more than two late, overhutd% or returned check fees that occur during any billing period. MAKE A PAYMENT. AND TAKE CONTROL ow OF YOUR CREDIT WITH CAPITAL ONE? Your account is temporarily unusable. The good news is, by paying the amount due on your statement, you can still bring your account into good standing. Let's work together to bring your account back to good standing. You can make a payment with our free check by phone service or speak to an associate by calling 1.800.955.6600. Finance Chug" Plwe wretwrerideforsmpwant iajoraration Bd-s, gpcsa, Perot rmE L+E PURCHASES f739.% CASH .07096% 25.90% $16 28 8.00 .070%% 25.90% . $.00 ANNUAL PERCENTAGE RATE a lied this i d pp per o 25.90% PLEASE RETURN PORTION BELOW WITH PAYMENT 0000000 0 5178052299186029 11 0777400065270277402 New Balance 5777 Minimum Amount Due $27740 Payment Due Date October 12, 2006 Total enclosed $ Aceomtt Nmnber. 5178-0522-9919-6029 Pf-prafara77V Zan a?rl/ore-nuiteser?r,drkv-.rW -H-Fact Jtreet - Apt t uty S- ZIP Home Phone Alt=c Phone ?- #9025572100088640# MAIL ID NUMBER Capital One Bank FRANK D ARMSTRONG P.O. Box 70884 Irlululrllnluldtl 1231 HIGHLANDER WAY Charlotte, NC 28272-0884 N s? MECHANICSBURG PA 17050-8302 ItrLlltdrttldlrnLJrlllrtdrrlJtrLtlnllrrLdrrllrttll ? IrrrlllrrdllrrtddrlltttLdrrrllJlrrrrrltlttlLrttlllLrtl Plwe -eyarv acmant numbef on ymv clank ar money. ordn madepayablc to 0a0dt lone Bank and mail in bye endured enveb r 00 R4 . rs v i ` t co ? rt. ?rz '5m Sheriffs Office of Cumberland County R Thomas Kline ovP 01 cnmhrr Edward L Schorpp Sheri Solicitor Ronny R Anderson Jody S Smith Chief Deputy OFFICE Or 74E SHERIFF Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 03/20/2009 12:34 AM - Timothy Reitz, Deputy Sheriff, who being duly sworn according to law, states that on March 20, 2009 at 1234 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Frank Armstrong, by making known unto Frank Armstrong personally, at One Courthouse Square, Room 303, Carlisle, 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: $32.50 March 23, 2009 Docket No. 2009-1644 Capital One v Frank Armstrong - 4e~ SO ANSWERS, R THOMAS KLINE, SHERIFF De y Seri Fri Our File No.: 197742 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire Attorney I.D.# 38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff CAPITAL ONE BANK (USA),N.A. COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff, vs. FRANK D ARMSTRONG NO. 09-1644 Defendant. PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & ASSOCIATES, P.C. Attorneys for tiff A Law Firm En2apze rn D/ebt Collection By: David J. Apot'kaker, Esquire Dated: April 24, 2009 RLED- i'ICE OF THE F np?,:1AFY 2009 MAY -- I AM I I * 26 PEN i,,,