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Home My WebLink About09-2491Our File No.: 197354 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. JOAN E BARILAR A/K/A JOAN CAMPBELL 235 HUMMEL AVE APT B LEMOYNE, PA 17043-1949 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 09 - 01441 NOTICE You have been sued in court. If you wish to defend against the claims set forth in the follow you must take action within twenty (20) days after this complaint and notice are served, by enterin appearance personally or by attorney and filing in writing with the court your defenses or object claims set forth against you. You are warned that if you fail to do so the case may proceed without judgment may be entered against you by the court without further notice for any money clan complaint or for any other claim or relief requested by the plaintiff. You may lose money or propel rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NO'. LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH B FIND OUT WHERE YOU CAN GET LEGAL HELP. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 mg pages, a written ins to the you and a ed in the v or other HAVE A LOW TO VIDE IBLE 4 Our File No.: 197354 AP?OTHAKER & 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. JOAN E BARILAR A/K/A JOAN CAMPBELL 235 HUMMEL AVE APT B LEMOYNE, PA 17043-1949 COURT OF COMMON PLEAS CUMBERLAND COUNTY -2q"' &iw( NO.: 09- Defendant. ) ill 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 JOAN E BARILAR A/K/A JOAN CAMPBELL, an adult individual residing at 235 HUMMEL AVE APT B LEMOYNE, PA 17043-1949. 3. At the special instance and request of Defendant, Plaintiff, CAPITAL ONE BANK (i SA),N.A., issued to Defendant(s), Account #4862362437166609. 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 $1,733.22. A true ? d 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 $1,733.22 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER & A CIATES, P.C. l ' tiff r P Attorney (ecd A Law Firm Ena in ebt Collection BY: Dated: 4/14/2009 David J. Our File No.: 197354 VERIFICATION 1II; , 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: 110W what's in your wallet? JOAN E BARILAR NOT PAYING YOUR DEBT 058 DOESN'T MAKE IT GO AWAY. In fad, even if we report your account as charged off, you'll still be responsible for paying your debt. So why not call us to see what we can do together to keep you from receiving such a serious mark on your credit record? We're here to help. Please contact us to find a solution that's right for you. You can make a payment with our fm check by phone service or speak to an associate by calling 1.800.955.6600. Make sure you call or pay the amount due on your statement within 30 days to keep your account from being charged off. ® 2006 Capital One Services, Inc. Capital One is a federally rrgirtered service mark. All righu reserved 058-07754 ANNUAL PERCENTAGE RATE applied this period 25.90% PLEASE RETURN PORTION BELOW WITH PAYMENT Account Previous Balance $981.89 Payments, Credits and Adjustments $.00 Transactions $35.00 Finance Charges $21.83 New Balance $1,038.72 Minimum Amount Due $1,039.72 Payment Due Date October 23,20% Total Credit Line $550 Total Available Credit $.00 Credit Line for Cash $550 Available Credit for Cash $.00 At your service To. 11 Cwtomer RA t- or to report a lost or t l. card: 1-800-903-3637 Smdpaymaioto: Sodinguku to Attn: Randtanee Procenin8 Capital One Bank Capital One P.O. Box 70884 P.O. Box 30285 Charlotte, NC 28272-OM SLC, UT 84130-OM Impoztantt Account Information Beginning October lsy 2006, based on your amount activity you may be assessed more than two late, ovaRraiy or returned check fees that occur during any billing period. PLATINUM VISA ACCOUNT 4862-3624-3716-6609 AUG 24 - SEP 23, 2006 Page 1 of 1 Payments, Credits and Adjustments Transactions 1 23 SEP PAST DUE FEE $35.00 Your account is six payments behind. If we charge off your account due to late payments, we will report this to several national credit bureaus which may have a serious impact on your credit record. Act now to prevent this from happening. Please pay the amount due on your statement or give us a call at 1.900.955.6600. Vve71 work with you so y mu take control of yvta Capital One account and scant rebuilding your credit NOTICE: Look for a new statement design for your Capital One credit cud beginning nert month A summary of the key changes will be provided with your new statement. You were 29sessed a past due fee of $35.00 on 09123/2006 because your minimum payment was not received by the due date of 09/23/2006. To avoid this fee in the future, we recommend that you allow at least 7 business days for your payment to reach Capital One. Finance Charges Pkare see reverseakfor important information N Bdamrndi Pnodu Cm+rs/mulaeg ?1.?1 `?' m q?l tits rain ?.ffPP l;tlAKlil; PURCHASES $992.41 .0709616 25.90% $2183 CASH S.00 .0709616 25.90% 5100 0000000 0 4862362437166609 23 1038720019751038723 New Balance $1,039.72 Minimum Amount Due $1,039.72 Payment Due Date October 23, 2006 Total enclosed $ Account Number: 4%2-3624-3716-6609 Pf..fir,efa-rz.4bruand/srrnm+1 m5,-W-u.WW -,W"44- Stteet Apt 3 City Shm ZIP Home Phone Alt-tc Pboae Fm.UAdd- #9026722210493649# MAIL ID NUMBER JOAN E BARILAR Capital One Bank 235 HUMMEL AVE P.O. Box 70684 APT B N hlulultlltlntllnl Charlotte, NC 28272-0884 e 1111111 LEMOYNE PA 17043-1949 Iuhllnlutltllutluhllln?Inhlnlulullulnlullutll ? Iu?lllu?llluululnlluulll?l?ululltluullultlulnll Phase writeyour auamnt nurmberon your dxci or money order madepayable to Capital OwBanf and mail in the emtkuedemxlofe. r FIL ED- 0, .-Rtr OF THE P, 2009 APR 20 PH 1: 4.4 'y i' S;`'i'?1?? E' -fls. so Po ATT1 ec* j3o408 R* aaya6 Sheriffs Office of Cumberland County R Thomas Kline r at cumbrr?ap? Edward L Schorpp Sheriff' Solicitor Ronny R Anderson Jody S Smith Chief Deputy OMCE of THE $-ERIFF y Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 04/25/2009 11:45 AM - Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on April 25, 2009 at 1145 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Joan E. Barilar, by making known unto herself personally, defendant at 235 Hummel Avenue, Apt. B. Lemoyne, Cumberland County, Pennsylvania 17043 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $42.40 April 27, 2009 SO ANSWERS, R THOMAS KLINE, SHERIFF 2009-2491 Capital One Bank VS Joan E. Barilar By'r?•--- Depu Sheriff FILED-),, il: E q DF THr 2099 APR 28 AN , 18 g ,t i?f. If ??? cf Ii rs t? 1 ? :'.-5S? Our File No.: 197354 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. Plaintiff, VS. JOAN E BARILAR A/K/A JOAN CAMPBELL COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 09-2491 Defendant. PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & ASSOCIATES, P.C. Attorneys for Plainti A Law Firm Engaged in Collectioi By: David J. Apothaker, Esquire Dated: May 22, 2009 OF THt" 2 fUt -2 AH GuImi' Crt ? J