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Home My WebLink About09-4185Our File No.: 206358' 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 - t4185 vil (erw 0,1 KENNY R JOHNSON 131 REX DR CARLISLE, PA 17013-8815 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.: 206358' 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. KENNY R JOHNSON 131 REX DR CARLISLE, PA 17013-8815 Defendant. COURT OF COMMON PLEAS CUMBERLAND COU?NyTY_ NO.: d y - q 15 l.ctic l 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 KENNY R JOHNSON, an adult individual residing at 131 REX DR CARLISLE, PA 17013-8815. 3. At the special instance and request of Defendant, Plaintiff, CAPITAL ONE BANK (USA),N.A., issued to Defendant(s), Account #4862362343738764. 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 $3,641.27. 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 $3,641.27 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & ASSOC TES, P.C. Attorney fonDt f A La w Firm Enza?ed Collection BY: David J. Ap+aker, Esquire Dated: 6/15/2009 Our File No.: 206358 VERIFICATION t, V , 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: ¦ C ¦ ¦ ¦ a 5 1 i a • c?a o? C 3•?4• C LLA p ` y f I V ? m N 4 ?' .AlL a c? •? e p 0 4 M o H p M R CD r d Ln 0 cD cc Q `-l c C X N (1) nn`` 0) LU (f) • Ct LU a a) ca i ? ac ? t) o 4a y ai P m ? m c m o C +=•• cfa ?• o cae?j coo ? +.? -0 C"t m bg a v ° Y .??? Q C E V Q ,C p O Q.?rr¦? r+. cx,,, E 4- Lo +c m Q f ,?,, o u ?'r'w'r CU ' •? U ? n'C., C ? IMf?/1 ? 1,.. 43 W OL = J= ?+J I w ° r?wr?wr Q u m u Ile, e? ?` mum • '° - ? ?? '? ? ' 1 ? ter.. a? a7 0? i4 t y 'T' .....?.... QJ '-- CL G3 ?•G3 f/? d Or ! r Gy o (r a? U .92 woo 14 a 0 -6 o env d 5 r.4- co Q-P1talowl . I what's in your wallet?a KENNY R JOHNSON NOT PAYING YOUR DEBT 058 DOESN'T MAKE IT GO AWAY. In fact, 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 free 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 registered service mark. All rights reserved. 058-07754 Account Summary Previous Balance $2,020.87 Payments, Credits and Adjustments $29.00 Transactions $35.00 Finance Charges $50.19 New Balance $2,077.06 Nlinimum Amount Due $2,077.06 Payment Due Date October 19, 2006 Total Credit Line $1,550 Total Available Credit $.00 Credit Line for Cash $1,240 Available Credit for Cash $.00 At vour service To call Customer Relations or to report a lost or stolen card: 1-800-903-3637 For free online account service and speaal -omer offers, log on to: wwm.cepitalone.com send payments to: Send inquiries to: Attn: Remittanm Processing Capiul One Bank Capital One P.O. Box 70884 P.O. B. 30285 Charlotte, NC 28272-0884 SLC, UT 84130-0285 Important Account Information Beginning October 1st, 2006, based on your account activity you may be assessed more than two late, overlimit, or returned check fees that occur during any billing period. PLATINUM VISA ACCOUNT AUG 20 - SEP 19, 2006 4862-3623-4373-8764 Page 1 of 1 Payments, Credits and Adjustments 1 13 SEP CR PAST DUE FEE $29.00- Transactions 2 19 SEP PAST DUE FEE $35.00 Your ace-unt is six payments behind. if we charge off your account due to late payments, we wilt report this to several national credit bureaus x h:ch may have a seriotr. impact en Your credit record. Act now tc prevent this from happening. Please pay the amountdue em your statemcnt or give us a call at 1.800.955.660C. Well work with you s , you can take control of your Capital One account and start rebulding your credit. NOTICE: Look for a new statement design for your Capital One credit card beginning nest month. A summary of the key changes will be provided with your new statement. You were assessed a past due fee of $35.00 on 09/1912006 because your minimum payment was not received by the due date of 09/19/2006. 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 Pleam ire reveae idef i> giant i f ation v' m Bal >arr P Wdr Ca.respa„dssg A pplirdto >a:e APPR A 1:t1 ).C l tO PURCHASES $2038.56 .07942%P 28.99% 150.19 CASH $.00 .07942%P 28.99% S.00 ANNUAL PERCENTAGE RATE appl ied this period 28.99% PLEASE RETURN PORTION BELOW WITH PAYMENT V C-P" le 0000000 0 4862362343738764 19 2077060025002077067 New Balance $2,077.06 Minimum Amount Due $2,077.06 Payment Due Date October 19, 2006 Total enclosed $ - 1 Account Number: 4862-3623-4373-8764 Capital One Bank P.O. Box 70884 1.1111 tLlltl11tdtll Charlotte, NC 28272-0864 1111tlLtlrt1111111[1111111111] 1111111 IInI1111116t111 11111 11 Plraseprint mailing adi-t and or e-rna;lriungrs hd swing bl -bl kirsE Stre<t Apt_ 4 Cry Sm zip Home Phone Alternate Phone #9026340843105009# MAIL ID NUMBER KENNY R JOHNSON 131 REX DR CARLISLE PA 17013-8815 m ? I,..IILt?lllta...ll..IlrLtlrlt,It?t?IlJJtrtllrtttllttltll r Pl are rarite your accoant number on your check or money o a made payable to Capital One Bank and mail in the enclosed envel?5r. Sheriff s Office of Cumberland County R Thomas Kline ~~~~,tp ~~ ~zr'nfier/;t~r~ Sheriff ', Ronny R Anderson Chief Deputy oFf;~E.,;: -,;~ f,..~~i~r Edward L Schorpp Solicitor Jody S Smith Civil Process Sergeant Capital One Bank (U.S.A.) N.A. vs. Kenny R. Johnson Number 9-4185 SHERIFF'S RETURN OF SERVICE 06/23/2009 07:35 PM -Michael Garrick, Deputy Sheriff, who being duly sworn according to law, states hat on June 23, 2009 at 1935 hours, he served a true copy of the within Complaint and Notice, upon th within named defendant, to wit: Kenny R. Johnson, by making known unto himself personally, defendant t 701 E. Locust Street Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and a the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $37.00 June 24, 2009 SO ANSWERS, R THOMAS KLINE, ; y Sher N ~ "p r:~ -t'3 .,aa .J 4.. ~` L~ ,. 4F1 ~]'w f (T' ~'-: ) ~ r y :,7 {--, --<