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HomeMy WebLinkAbout09-1645A Our File No.: 197757 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. MATTHEW L MURVINE 4 PARK ST MOUNT HOLLY SPRINGS, PA 17065- 1433 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: (7q- R AS l errM 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 s 46 Our File No.: 197757 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. MATTHEW L MURVINE 4 PARK ST MOUNT HOLLY SPRINGS, PA 17065- 1433 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY ) NO.. 0q 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 MATTHEW L MURVINE, an adult individual residing at 4 PARK ST MOUNT HOLLY SPRINGS, PA 17065-1433. 3. At the special instance and request of Defendant, Plaintiff, CAPITAL ONE BANK (USA),N.A., issued to Defendant(s), Account #5178052340427778. 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 $1,534.23. 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 $1,534.23 and requests this Court award Plaintiff attorneys fees and costs to the extent permitted by applicable law. APOTHAKXngag?Td SOCIATES, P.C. AttPlaintiff A Law Finn in Debt Collection BY: Dated: 3/9/2009 DavidV. Aplo l er, Esquire Our File No.: 197757 • 1 , VERIFICATION ?ti? f , 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 unswom falsification to authorities. DATE: . a First 3 months half-price s mateX 4 7 $9.951M. ttorealtec' SIGN UP TODAYI ' 1-877-778-1207 Mention Offer Code: ONYX Or visit www.peoplepc.com/go/onyx Account Summary previous Balance $870.47 payments, Credits and Adjustments $.00 Transactions $29.00 Finance Charges $21.69 New Balance $921.16 Minim. Amount Due $921.16 Payment Due Date October 23, 2006 Total Credit Line $500 Total Available Credit $.00 Credit Line for Cash $500 Available Credit for Cash $.00 Atyourservice To aR Customer Rds iom or to report a lost or stolen ark 1-800-903-3637 For free online aaaa nt accrue and gooal euftomer offer., lot on to: aom italone www n . . p Send mm" to: . Send in paw to: Atm: R-*b m Pmoeui T Capital One Back C.Piw One P.O. Box 70884 P.O. Box 30M Charlotw, NC 28272-0884 SLC, Ur 8413"M irnportartt Account Information &grmmng October lit, 2006, based on your account activity you maybe assessed more than two late, ovetlimit, or returned cheep fees that occur during any billing period. 003 peoplew online u A better way to Internet. PeoplePC Online offers the features you would expect from higher-priced Internet Service Providers at half price for the first 3 months! ® Email Virus Protection ® Pop-Up BlockerT14 IF?j Spam Controls Smart Dialer Phisher Security Q* Internet Call Waiting PLATINUM MASTERCARD ACCOUNT 5178-0523-4042-7778 AUG 24 - SEP 23, n% Page 1 of 1 Payments, Credits and Adjustments Transactions 1 23 SEp PAST DUE FEE $29.00 NOTICE: Look for a new statement design for your Capital One credit card beginning next month. A summary of the key changes will be provided with your new statement You were assessed a past due fee of $29.00 on 09/23/2006 because your minimum payment was not received by the due due of 09/23/2006. To avid this fee in the future, we recommend that you allow at least 7 business days for your payment to reach Capital One. Finance Charges N Bdannde ?i 1m °n PURCHASES $880.92 CASH 8.00 ANNUAL PERCENTAGE RATE applied this perk V PLEASE RETURN PORTION BELOW WITH PAYMENT Pkemra rewrrxndefor sraportsat rafornta - .07"XP 2&99K f2L69 .07942%P 2&99% f.00 d 28.99% 0000000 0 5178052340427778 23 0921160219940921160 New -Balance $921.16 Minimum Amount Due $921.16 Payment Due Due October 23, 2006 Total enclosed $ 71 Acoourt Number. 5178-0523-4042-7778 #9026747366632732# MAIL ID NUMBER P7-p-1-,7.ga1lrcn-il- rnr lrrl mge.brkmmurW eruekmk Street Apt ! taro Stare ZIP Home Phone Alteman Pb.. e EmulAddcee MATTHEW L MURVINE I Capital One Bank 4 PARK ST P.O. Box 70884 't'trltl'IIIIIIIIIIIII N MOUNT HOLLY SPRINGS PA 17065-1433 Charlotte, NC 28272-0884 Plewe ws teyaur acrocmt number on ymr dwl or money order makfixuhk to capital One Bank and mail in the endued en%AdoAr. r TI CK i' Q -?C Sheriffs Office of Cumberland County R Thomas Kline Cuoty It cumber4t4l,?0 Edward L Schorpp Sheriff Solicitor Ronny R Anderson Jody S Smith Chief Deputy OFFICE OF THE SHERIFF Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 03/30/2009 R. Thomas Kline, Sheriff who being duly sworn according to law states that he made a diligent search and inquiry for the within named defendant to wit: Matthew L. Murvine at 4 Park Street, Mt. Holly Springs, Cumberland County, Pennsylvania, 17065, but was unable to locate him in his bailiwick he therefore retun the within Complaint as not found as to the defendant, Matthew L. Murvine. Current resident advises the defendant no longer resides here. SHERIFF COST: $45.60 SO ANSWERS, March 31, 2009 THOMAS KLINE, ERIFF Deputy Sheriff Docket No. 2009-1645 Capital One v Matthew L. Murvine ? ?°' ?, ?? ?, ?: ?? ?? ????????