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Home My WebLink About09-7356_Odr File No.: 223920 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. JULENE B RICHWINE 347 STUMPSTOWN RD MECHANICSBURG, PA 17055-9602 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: oq - rl35(,, Civ< (Term 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 (Tar File No.: 223920 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. JULENE B RICHWINE 347 STUMPSTOWN RD MECHANICSBURG, PA 17055-9602 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: o q. '73,51, C ,mod 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 JULENE B RICHWINE, an adult individual residing at 347 STUMPSTOWN RD MECHANICSBURG, PA 17055-9602. 3. At the special instance and request of Defendant, Plaintiff, CAPITAL ONE BANK (USA),N.A., issued to Defendant(s), Account #4862362452491429. 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 $1,515.22. 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 I- a. $1,515.22 and requests this-Court award costs to the extent permitted by applicable law. APOTHAKER & AS TES, P.C. Attorney fo PI tebt tiff A Law Firm Enizaae in Collectioi BY: David J. Apot*6eC, Esquire Dated: 10/19/2009 Our File No.: 223920 VERIFICATION David J. Apothaker, Esquire, Esq. hereby states that I am counsel 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. 4'04 rAlating to unsworn falsification to authorities. David J. Apc Attorney DATE: 10/19/2009 CAPITAL ONE BANK (USA),N.A. JULENE B RICHWINE 347 STUMPSTOWN RD MECHANICSBURG, PA 17055-9602 STATEMENT OF ACCOUNT Debtor's Name: JULENE B RICHWINE Account Number: 4862362452491429 Balance Due: $1,515.22 Our File No.: 223920 EXHIBIT "A" 0 OF FILE? NOTARY 2009 OCT 26 PM 2: to CUM t: , .: U ti , Tlr PE?`?s??>YL?; f?,iJAN 08.50 PD -ATr/ CL's !35?a3 e aaa.68a Sheriffs Office of Cumberland County R Thomas Kline FILED-OFFICE Sheriff OF NC FR OTHO"1CTARY Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor OFF ICE <---r:rME : -ERiFF 2009 OCT 29 AN 10: 18 NTY Capital One Bank (U.S.A.) N.A. vs. Case Number Julene B. Richwine 2009-7356 SHERIFF'S RETURN OF SERVICE 10/27/2009 05:50 PM - Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on October 27, 2009 at 1750 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Julene B. Richwine, by making known unto herself personally, at 347 Stumpstown Road Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $37.00 October 28, 2009 SO ANSWERS, R THOMAS KLINE, SHERIFF By /- Deputy Sheriff