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Home My WebLink About09-4294U/ Our File No.: 206375 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. HEATHER CLINE 1136 LAUREL AVE CAMP HILL, PA 17011 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. 09- p,// q n/ if, -/ 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 Qur File'No.: 206375 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothakex, 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. HEATHER CLINE 1136 LAUREL AVE CAMP HILL, PA 17011 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. d 7? x,07 C?-/I 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 HEATHER CLINE, an adult individual residing at 1136 LAUREL AVE CAMP HILL, PA 17011. 3. At the special instance and request of Defendant, Plaintiff, CAPITAL ONE BANK (USA),N.A., issued to Defendant(s), Account #4862362437528832. 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 $1,356.60. 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 $1,356.60 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & ASSOCIATES, P.C. Attorney for tiff A Law Firm Enaaized/m ebt Collection BY: Dated: 6/18/2009 David J. Our File No.: 206375 VERIFICATION 1,114,111 4.14 , 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: 053 what's in your wallet?' HEATHER CLINE It could happen to anyone. Make sure you pay the amount due on your statement as soon as possible. Keeping your credit in good standing can WHOOPS, do a lot more than you think. GOOD CREDIT= GOOD CREDIT REFERENCES BETTER INTEREST RATES (good credit could mean lower interest rates) IMPROVED CHANCES TO GET APPROVED FOR LOANS (when you want to buy a home or new car) ® 2006 Capital One Services, Inc. Capital One is a federally registered service ?nark. All rights reserved 053-08106 Account Summary Previous Balance $504.33 Payments, Credits and Adjustments S.00 Transactions ;58.00 Finance Charges $5.56 New Balance $567.89 Minimum Amount Due $67.89 Payment Due Date October 27, 2006 Total Credit Line ;500 Total Available Credit ;.00 Credit Line for Cash $500 Available Credit for Cash $.00 At your service To can Customer Relations or to report a lost or stolen card: 1-500-903-3637 Send Payments to: Send inquiries to: An.: Resnittanee Processing Capital 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 baling period. PLATINUM VISA ACCOUNT AUG 28 - SEP 27, 2006 4862-3624-3752-8832 Page 1 of 1 Payments, Credits and Adjustments Your scheduled payment has not been received. Please remit the amount due appearing on this statement. If you have already made your payment, please accept our thanks. Transactions 1 27 SEP OVERLIMIT FEE ;29.00 2 27 SEP PAST DUE FEE 29.00 Your account is one payment behind. Remember that making your minimum payments by the due date, keeps your account in good standing. 'When you miss a payment, late fees start adding up. And nobody wants that. So make sue you send in the minimum amount due on your statement to keep your account in good standing and to keep horn paying extras fees. NOTICE: Look for a new statement design for your Capital One credit card beginning next month. A summary of the key changes will be provided with your new statement. You were assessed a past due fee of $29.00 on 09/27/2006 because your minimum payment was not received by the due date of 09/27/2006. 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 Please see reverse side for important information a Bal rate Pnodir C ?pond gIANCE ` &I dto rote APR C`:t1?AjRj(i E PURCHASES $507.94 .03534% 1190% $5.56 CASH 5.00 .05425% 19.80% 6.00 ANNUAL PERCENTAGE RATE applied this period 12.90% PLEASE RETURN PORTION BELOW WITH PAYMENT G? 0000000 0 4862362437528832 27 0567890040000067895 New Balance ;567.89 - Minimum Amount Due ;67.89 Payment Due Date October 27, 2006 Total enclosed ; 1 :1 Account Number. 4862-3624-3752-8832 Capital One Bank P.O. Box 70884 It lulull?llmlltnl Charlotte, NC 28272-0884 lultllul?nl?ll?ulultlll?ulultlululnllululullmll Pleareprint mailing adbrrs and/ e-mailihanges bel acing blwablack ink Sneed C"y Snte Home Phone Alten,- Phone #9027157299126167# MAIL ID NUMBER HEATHER CLINE 1136 LAUREL AVE O CAMP HILL PA 17011-6920 ItnlllntllLtt?t?Il??tlhlLd?Ltt?Lllltttnllttll?ttLtll Apt # ZIP r Please rariteyonr acmant number on your check or money order neadepayable to Capital One Bank and mail in the enclatedenvelope. O F!LT_.r,:,---Il, OF THE 21P;1, J 'A' 2 5 Pi"; 2: 5 8 ? pp 'f 1111?:? _. ? y' ? ?# ?a7aa a Sheriffs Office of Cumberland County R Thomas Kline Sheriff Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor c..cFIFF OFF CG -"E F i OF THE ° ^rt,^Y 2009 jut?._ i, r 4 I Y Capital One Bank (U.S.A.) N.A. vs. Heather Cline Case Number 2009-4294 SHERIFF'S RETURN OF SERVICE 06/29/2009 11:52 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: Heather Cline, but was unable to locate her in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant Heather Cline. The current resident of 1136 Laurel Avenue Camp Hill, PA 17011 states the defendant has moved out. The Camp Hill Postmaster has advised Heather Cline's mail is being forwarded to 1913 N. 2nd Street Harrisburg, PA 17102. SHERIFF COST: $41.50 July 10, 2009 SO ANSWERS, R THOMAS KLINE, SHERIFF