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Home My WebLink About09-1718 Our File No.: 193712 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. BRYAN A SHUEY 4116 NANTUCKET DR MECHANICSBURG, PA 17050 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: L1 9, / 7 19, c rv, 1 4 ern- 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 File No.: 193712 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. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: v9` ?7??CN? ?AL BRYAN A SHUEY 4116 NANTUCKET DR MECHANICSBURG, PA 17050 Defendant. 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 BRYAN A SHUEY, an adult individual residing at 4116 NANTUCKET DR MECHANICSBURG, PA 17050. 3. At the special instance and request of Defendant, Plaintiff, CAPITAL ONE BANK (USA),N.A., issued to Defendant(s), Account #4862362509299684. 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 $1,280.10. 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 $1,280.10 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER & ASSOCIATES, P.C. Attorney r laintiff A Law Firm Ene ed ' Debt Collection BY: David J. Akthaker, Esquire Dated: 3/11/2009 Our File No.: 193712 VERIFICATION ?a, 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. BRYAN A SHUEY 4116 NANTUCKET DR MECHANICSBURG, PA 17050 STATEMENT OF ACCOUNT Debtor's Name: BRYAN A SHUEY Account Number: 4862362509299684 Balance Due: $1,280.10 Our File No.: 193712 EXHIBIT "A" v - 193712 Request for Service R. Thomas Kline Sheriff Cumberland County Office of the Sheriff One Courthouse Square Carlisle, PA 17013 Ph: 717.240.6390 Fx: 717-240-6397 Plaintiffs: Court Number: CAPITAL ONE BANK (USA),N.A. Expiration Date: Type of Action: CAction Defendant/s: BRYAN A SHUEY Serve Upon: BRYAN A SHUEY Address for Service: 4116 NANTUCKET DR MECHANICSBURG, PA 17050 Alternate Address for Service: Type of Service: ( ) Personal (X) Adult in Charge () Deputize () Certified Mail () Posting Special Service Instructions: ** If service is to be made by deputized service to another county please specify which county Filing Attorney Information: Name: Apothaker & Associates, P.C. Address: 520 Fellowship Road C306 Mount Laurel, NJ 08054 Telephone: 215-634-8920 C) tT: C) m '? Call Sheriffs Office of Cumberland County R Thomas Kline giubrrla Edward L Schorpp Sheriff' Solicitor Ronny R Anderson Jody S Smith Chief Deputy OFFICE C)F THE S!IERiFF Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 03/27/2009 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: Bryan A. Shuey at 416 Nantucket Drive, Mechanicsburg, Cumberland County, Pennsylvania, 17050 but was unable to locate him in his bailiwick he therefore returr the within Complaint as not found as to the defendant, Bryan A. Shuey. Current resident advises the defendant no longer resides here and the Post Office has no forwarding address. SHERIFF COST: $52.00 March 30, 2009 SO ANSWE R THOMAS KLINE, SHERIFF Docket No. 2009-1718 Capital One Bank v Bryan A. Shuey MApR-1 PH' 27 M*Wgwo