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Home My WebLink About09-7425Our File•No.: 224136 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. PATRICIA M MARTIN 2331 CHESTNUT ST CAMP HILL, PA 17011-4616 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: Oa- 7ga5 L)V; t -Ferro 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 i 16 Our File-No.: 224136 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. PATRICIA M MARTIN 2331 CHESTNUT ST CAMP HILL, PA 17011-4616 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: Of- CIVIL T1 c,.?-, 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 PATRICIA M MARTIN, an adult individual residing at 2331 CHESTNUT ST CAMP HILL, PA 17011-4616. 3. At the special instance and request of Defendant, Plaintiff, CAPITAL ONE BANK (USA),N.A., issued to Defendant(s), Account #4862362667840162. 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 $1,485.75. 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 $1,485.75 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & ASS TES, P.C. Attorney for tiff A Law Firm En2aae in ebt Coll ioi BY: Dated: 10/21/2009 David J. Apo4iXer, Esquire Our File No.: 224136 . 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 ie . The undersigned understands that the statements therein are made subject to the penalties of 18 Pa.C.S.A'?4904 elating to unsworn falsification to authorities. Davi J. Apothaker, Esquire Atto or Plaintiff DATE: 10/21/2009 CAPITAL ONE BANK (USA),N.A. PATRICIA M MARTIN 2331 CHESTNUT ST CAMP HILL, PA 17011-4616 STATEMENT OF ACCOUNT Debtor's Name: PATRICIA M MARTIN Account Number: 4862362667840162 Balance Due: $1,485.75 Our File No.: 224136 EXHIBIT "A" 0 RLFD-O =FtCE OF THE PROTHONOTARY 2009 OCT 28 PM 1: 04 CUM ..: - i 1r PElm%YLVA,N- A 4178.5o Po ATM CY.`?' t S(o r'7(o a3a??r9 R Thomas Kline Sheriff Ronny R Anderson Chief Deputy SHERIFF'S OFFICE OF CUMBERLAND COUNTY ,_ Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor Capital One Bank (U.S.A.) N.A. vs. Patricia M. Martin h# ~~_.~ ~ .~~t~ ,,, c ~ ,.~, i _ i~~; _ ~. Case Number 2009-7425 SHERIFF'S RETURN OF SERVICE 11/16/2009 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: Patrica M. Martin, but was unable to locate her in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant Patricia M. Martin. Eric Sheaffer, current resident of 2331 Chestnut Street Camp Hill, PA 17011 has resided at this location for a year and does not know the defendant. The Camp Hill Postmaster has advised the defendant is not known at address given. An exact address is not available. SHERIFF COST: $46.50 SO ANSWERS, _. .-~ -.: -~ _...~.~ -- -- ..... , v%~-'' November 16, 2009 R THOMAS KLINE, SHERIFF !cj Cou^*,«uite 5h.^.r..ff, irie:so`i inc. c~ •r r ~ . 1 r ` Our File No.: 224136 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. Plaintiff, vs. PATRICIA M MARTIN Defendant. 20l0 F~~ 22 i'e~i i~~ 52 `w~ 1 ~~L} I j! COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 09-7425 PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & Attorneys A Law Firm En~a~ )CIATES, P.C. laintiff Debt Collection By: ~~ David J. Apothaker, Esquire ~~~_~~J--t.a'r.i~~~ Dated: 1 /4/2010