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Home My WebLink About09-3203Our File No.: 193662 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.: Oq - 3x243 0,1 vi l -[m VALICITY CORDLE 6 W MAIN ST NEWBURG, PA 17240 Defendant. 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.: 193662 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. VALICITY CORDLE 6 W MAIN ST NEWBURG, PA 17240 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: o 4. 3 2 0 3 Ct;,( `r.?,w' 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 VALICITY CORDLE, an adult individual residing at 6 W MAIN ST NEWBURG, PA 17240. 3. At the special instance and request of Defendant, Plaintiff, CAPITAL ONE BANK (USA),N.A., issued to Defendant(s), Account #4862362352239555. 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 $6,455.68. 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 $6,455.68 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER & ASSO S, P.C. ainti Attorney for jo F" A Law Firm Enizaaed n Dettt Collection BY: Dated: 5/13/2009 David J Our File No.: 193662 VERIFICATION 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: m d w 4? cr ? C x ? E 3 ._ . o ca as ? ? C V) z ? Q ? rrl 40 H d Eg cn E W z c H m O ? c a y c r4. m a a ? m w M N ? N ? ? - a ? ` I-W 1 C-i r .? c C O - C- ' n C N N a ? O T ?? ? H 32 3 N dl g g o 3 ac . B E L E R g m ? ? ? d c O m r= Q 0 i w ? 9 N cm ? O ' OQ o L. qc ? i ? II J 1 d g - i ? I o L L+ ae o' E { i , ii Z O o O d d ? 8 Z C% i I ? T- h 2 a y t, b I?d d ? i ro Q oc 7Ei C) C Ca. to C . V c _o O V co = N a? v?- tOl1 N ?Fa a-.2 N M malow N O ? w o N V 0 O ? ro c E . 4 m J ? u ? ? a V o ? CJ Ca 2 1? N n z A a O? so 027 With Capital One" online account servicing, getting account information and Access your making payments is easy. Check out just a few of the things you can do- -4 Pay your bill online accountontine... -? Check your balance and available credit -} View your statement Register today at www.capitalone.com. Account S Previous Balance $3,594.65 Payments, Credits and Adjustments S.00 Transactions $35.00 Finance Charges $77.32 New Balance $3,706.97 Minimum Amount Due $3,706.97 Payment Due Date August 01, 2006 Total Credit Line $3,000 Total Available Credit $.00 Credit Lim for Cash $3,000 Available Credit for Cash $.00 At your service To all Customer Rel tiom or to report a Ion or stolen card: 1-800-955-7070 For free online account service and special customer offer, log on to: www.apaalonceom Send Payments to: Send inquiries to: Arta Remittance Processing Capital One Bank Capital One P.O. B. 790216 P.O. R. 30285 St Louis, MO 63179-0216 SLC, UT 84130-0285 b rnortant Account Information Take control and start paying your bill online for free. Eliminate the hassle of writing checks, finding stamps, and sealing envelopes. Everything you need to access, review, and pay your bill is available online. Our website offers you a convenient, simple, and secure way to manage your account. Visit www.capitalone.com and register your account to start s rnpllfyang your life today. 0 Plus, take advantage of other special offers developed especially for you! ow sufaft In yaw WS1187- see reverse for details )P- 027-0402 PLATINUM VISA ACCOUNT JUN 02 - JUL 01, 2006 4862-3623-5223-9555 Page 1 of 1 Payments, Credits and Adjustments Transactions 1 01 JUL PAST DUE FEE $35.00 You were assessed a past due fee of $35.00 on 07/01/2006 because your minimum payment was not received by the due date of 07/01/2006. 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 PLeasr ire reamfe r n idAe * important informati Bduaratr o Pniadu Cw + r ? "hed n, dP .is R PURCHASES $3,631.88 .070%% 25.90% $77.32 CASH $.00 .07096% 25.90% $.00 ANNUAL PERCENTAGE RATE applied this period 25.90% PLEASE RETURN PORTION BELOW WITH PAYMENT 0000000 0 4862362352239555 01 3706970090003706971 Pleareprmtmadmg&16,--& e-maJrhaageskl,aavab6u-Uschml. New Balance $3,706.97 Minimum Amount Due $3,706.97 Payment Due Date August 01, 2006 Total enclosed $? Account Number: 4862-3623-5223-9555 Capital One Bank P.O. Box 790216 hhlhllllll llllllhl St. Louis, MO 63179-0216 i 1111111111111111111111111ii lllllllil ll iililllllllll llllllllll Street APL / Ci,y S- ZIP Home Phone Alumsse Phom _ #9018340554300518# MAIL ID NUMBER VALICITY CORDLE o Z PO BOX 454 1DO NEWBURG PA 17240-0454 senseless aa? o ? o ? r Pleare wife your account number on your check or money order made payable to Capital One Bank and mail in the enclwed envelope. 0 r? , ?r ?AIRY 2CC9," 20 Ai'i i3,: 46 $18.so PO ATH av,l' lB(343 P-T* aais387 Sheriffs Office of Cumberland County R Thomas Kline air ?+ ?uarerr ??^•?4 •- ??••?•rr Sheri' c Solicitor Ronny R Anderson ' Jody S Smith Chief Deputy 0Ff4GE OF THE SHERIFF Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 05/22/2009 04:50 P - Steve Bender, Deputy Sheriff, who being duly sworn according to law, states that on May 22, 2009 at 650 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Valicity Cordle, by making known unto Terry Martin, adult in charge at 6 W. Main Street Newbur , Cumberland County, Pennsylvania 17240 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: May 26, 2009 SO ANSWERS, R THOMAS KLINE, SHERIFF puty Sheri 7f 2009-3203 Capital 0 v Valicity Oordle c> ?v Cho - -