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Home My WebLink About09-4293a Our File No.: 206263 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire, Esq. Attorney I.D.438423 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. JAY W KLAUBER 6302 CARLISLE PK MECHANICSBURG, PA 17050 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 4i, 4/v i3 ?lV? J?Vh'l 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.: 206263 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire, Esq. Attorney I.13.08423 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. JAY W KLAUBER 6302 CARLISLE PK MECHANICSBURG, PA 17050 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: o g q ?4 3 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 JAY W KLAUBER, an adult individual residing at 6302 CARLISLE PK MECHANICSBURG, PA 17050. 3. At the special instance and request of Defendant, Plaintiff, CAPITAL ONE BANK (USA),N.A., issued to Defendant(s), Account #4388641947051616. 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 $3,538.52. 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 $3,538.52 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & ASSOCIATES, P.C. A Law Firm Engiged i4 Debt Collection BY: David J. Apn??, Esquire Dated: 6/18/2009 Our File No.: 206263 VERIFICATION XIAJI/ 16-1114, 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: w O or ?z J dg, ?d ?s QA Ilk N ?s12 w 0 w. ? p > b ? > a ? .r ?v ^ L rrT?T ? a? r L y L L N v 0 rn v 0 n M r co r.{ a d? rf r a 7 Cl. d First 3 months half-price .; dolp 97 4 a monm; $9.95/rno. thereafter WFREEAcc eleratate Wws7eeetpspMftawtle SIGN UP TODAYI ' 1-877-778-1207 Mention Offer Code: OPAL Or visit www.peoplepc.corn/go/opal peoplepa- online N__'1 A better way to In temet. 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 BlockerT- ?j Spam Controls ® Smart Dialer ® [W More Email Addresses ® CO Internet Call Waiting Account S Previous Balance $1,883.65 Payments, Credits and Adjustments $.00 Transactions $35.00 Finance Charges $46.11 New Balance $1,964.76 Minimum Amount Due $1,964.76 Payment Due Date July 07, 2006 Total Credit Line $1,500 Total Available Credit $.00 Credit Line for Cash $1,500 Available Credit for Cash $.00 At your service To all Customer Relations or to report a lost or stolen _l, 1-800-903-3637 For free online account service and special customer off=, log on to: -cipitelonccom Send payments to: Send inq iris to: Attic Reesitun e Processing Capital One Bank Capital One P.O. Box 60024 P.O. B. 30285 City Indust CA 91716-0024 SLC, UT 84130-0285 Important 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.rapitalone.com and register your account to start simplifying your life today! ce C PLATINUM VISA ACCOUNT 4388-6419-4705-1616 MAY 08 -JUN 07, 2006 Page 1 of 1 Payments, Credits and Adjustments Transactions 1 07 JUN PAST DUE FEE $35.00 You were assessed a past due fee of $35.00 on 06/07/2006 because your minimum payment was not received by the due date of 06/07/2006. 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 Plemesm reverse tide for important informarioe B.( -.,,d, lm Periodic Coen g ROSE PURCHASES CASH $1,450.31 car .07805%P 29.4996 .09 $455.55 .07805%P 28.4996 $11 u.oz ANNUAL PERCENTAGE RATE applied this period 28.49% PLEASE RETURN PORTION BELOW WITH PAYMENT 0000000 0 4388641947051616 07 1964760042001964762 New Balance Sl 964.76 Minimum Amount Due $1964.76 Payment Due Date July 07, 2006 Total enclosed $ Account Number: 4388-6419-4705-1616 Capital One Bank P.O. Box 60024 I1111 I1[1 I1111 111.1 Ill City Indust CA 91716-0024 11111111111111111111111111111.111111,1111111111111 Plrasep.int mailing addru anb r-mailclongrs brl suing b! or bl kirsl•. Sneer Apt R Ci7 Su[e ZIP Home Phone Alamaoe Phone -.1 Addcen #9015928759060086# MAIL ID NUMBER JAY W KLAUBER PO BOX 2341 CAPO BEACH CA 92624-0341 v Me- t riteyow orcorent number m yow check or money order made payable to Capital One Bank and mail in the end-,- envelope. 206263 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: CAPITAL ONE BANK (USA),N.A. Defendant/s: JAY W KLAUBER Court Number: Expiration Date: Type of Action: Civil Action Serve Upon: JAY W KLAUBER Address for Service: 6302 CARLISLE PK MECHANICSBURG, PA 17050 Alternate Address for Service: Type of Service: ( ) Personal (X) Adult in Charge O Deputize O Certified Mail O 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 O ,)'F THEE- F ;CRY 2019 J25) F 2 5 fy, #It, ?6- A? 60 73Y -76* Sheriffs Office of Cumberland County R Thomas Kline V0 tr of lunbrEdward L Schorpp Sheriff Solicitor Ronny R Anderson Jody S Smith Chief Deputy OFFICE OF hE SHERIFF Civil Process Sergeant Capital One Bank (U.S.A.) N.A. Case Number vs. Jay W. Klauber 20094293 SHERIFF'S RETURN OF SERVICE 06/30/2009 10:25 AM - 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: Jay W. Klauber, but was unable to locate him in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant Jay W. Klauber. The request for service is at business location of McCafferty Ford Kia. Deputy spoke to Assistant Manager and no one by the name of Jay W. Klauber has worked at this location. An exact address is not available. SHERIFF COST: $42.00 July 01, 2009 ° O rte-. . ? t C_ Co c.n `ci Our File No.: 206263 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. COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff, vs. JAY W KLAUBER NO. 09-4293 Defendant. PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & ASSOCIATES, P.C. Attorney Plaintiff A Law Firm E aged in Debt Collection By: David J~ Apothaker, Esquire Dated: August 6, 2009 ~ Ali I ~ IRM 3~ i 5 ~s~v ~