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HomeMy WebLinkAbout10-5620 HAYT, HAYT & LANDAU, LLC By: Arthur Lashin, Esquire Identification No. 23425 400 Market Street Suite 600 Philadelphia, PA 19106-2513 (215) 928-1400 OUR FILE NO. 333451 CAPITAL ONE BANK 4851 COX ROAD GLEN ALLEN, VA 23060 Vs. PAUL G LUTHER 400 W DAUPHIN ST ENOLA PA 17025 Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION No. (0-54-Ao CIVIL ACTION "NOTICE 'You haw bom wed m corm Ifyou wish t defsrxl agamd to obitw eat %M in the bitting papas. you must tabs adios wNNn twfnty C^ days efbr prle oort iW* and notion m serval. in w db wilt tt ? Vow deftn"s or objecdom tow dams gat tam against froze You we vmnwd that if you tail to do so Ote cn may prowad w tmA you wW a jtrdpnwt may be on- tend apsirwt you by to cast vAhat ft~. roliot for arty mon- ey cM*md in to complfbtt or for fry odw dWm or rfief regwd- ed by to p' 11W You m" loft matey or property or oBrsr rights hvoftrt to you. IF YOU CANNOT AFFORD TO FIIRE A LAWYER.TIRS OFFICE MAY BE ABLE TO PROVIDE YOU WITH IINIORMATICK ABOUT AGENCIES THAT MAY CFM LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE ORNO FEE CUMBERLAND COUNTY BAR ASSOCIATION 32 S BEDFORD STREET CARLISLE PA, 17013 800-990-9108 TERM. e;, v i Term ""ISO "Le hen dw wrtdado a used an is oorle. Si used qiwe dtbrrdem do sobs datrsrdae ftWw bs on Met pipings *Vub TMs. usbd tiww vaiM PM dkm do pbto ai palir do Is I , I do r denrwde y r n dleaM . Now felt assr -- taw comparartda aaoria o an pfrwm o con un sbo"& y a 6"= a k curb an form Owls an daierrgs o sun objs r4 f *In dfrrwrt , to contra de w ptraorta. Sag wftwb gun d usbd no w dfbrtde, b torte torrrari medidaf y Pueda oodkrwr Y denwrrda to contra sup sin provio rAw o noliiogd6rt. Adwvi6C M oorrlt puede dadNr a favor dal darnw dw t y requWm *w Tweed cunVb con todes Im prcv'sbrtas do ads dattsrt I . Used puKb Perdu dirwo o an pmpiededat u otros dweehos I ipc to a - Para uabd. -LLEVE ESTA DEMANDA A UN ABOQADO IMMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUMIENT'E DE PAt3AR TAL SERVICIO. VAYA EN PERSONA O LLAME POR TF.LEFONO A LA OFIONA CUYA DIRECCI6N SE ENCUENT'RA ESCRITA ASAJO PARA AVERKAJAR DONDE SE PUEDE C70ll?i?{UIR AsISTENCIA LEtaoiL. S $Qa.oo PA amf Cf IC0776 Q,#a2Y7U-23 CIVIL ACTION 1. Plaintiff CAPITAL ONE BANK is a business entity securing or collecting debts, with offices located at: 4851 COX ROAD, GLEN ALLEN, VA 23060. 2. Defendant(s) PAUL G LUTHER is/are individual(s) residing at: 400 W DAUPHIN ST, ENOLA, PA 17025. 3. Upon application by Defendant(s) a Credit/Revolving Charge Account was established for Defendant(s), which was assigned account number 4003441496072484. 4. Defendant(s) subsequently utilized the aforesaid account to make various purchases and/or receieve cash advances, thereby incurring payment obligations to Plaintiff and/or Plaintiff's predecessor in interest. 5. Defendant(s) defaulted by failing to adhere to repayment terms and in accordance therewith, the entire remaining balance became due and immediately payable. 6. As a consequence of the foregoing there is presently due and owing to Plaintiff by Defendant(s) the following amounts (see Exhibit "A"): Unpaid Balance: Interest: TOTAL DUE: $7,777.23 $379.50 -85? 7. Despite repeated demand by Plaintiff, Defendant(s) has/have failed and refused to pay the aforesaid sum. WHEREFORE, Plaintiff demands that judgment Defendant(s) in favor of Plaintiff in the together with interest and costs. HAYT By: be entered against amount of $8,156.73 Attorney for Plaintiff EXHIBIT A 'A Tlfllff;? It p • Spread too thin? o• Paying bills takes a lot of time: writing checks, addressing envelopes, mailing letters. Get some time back each month with Capital One" balance transfers. Consolidate your bills and higher-interest payments, maybe even save some money, and then spend your time relaxing, shopping or watching the game-instead of writing a lot of checks. C8111-800-955-7070- 00000) L-- 500258 !Ready to transfer? See reverse to learn how. Previous Balance Payments & Credits FINANCE CHARGE Transactions New Balance Minimum Payment Due Date $6,524.54 - $200.00? + $117.30 + $300.00 = $6,741.84 $154.00 Apr. 07, 2009 Feb. 14, 2009 - Mar. 13, 2009 Page 1 of 1 Visa Platinum Account 4=4414Se07.2484 HaI Your Account Information 2 REWARDS' TOTAL CREDIT LINE $7,000.00 TOTAL AVAILABLE CREDIT $258.16 CREDIT LINE FOR CASH $1,400.00 AVAILABLE CREDIT FOR CASH $258,16 RM MY AT UAST THIS AMOUNT Rewards Summary Previous available balance: 1,541 Earned this period: 0 (rellams trenswilw%; posted during this biMg CYCIR) Available Balance: 1,541 Payments Credits & Adiusttnents 1 04 MAR PAYMENT $200.00- Finance Charges (Please see reverse for important information) Transactions Balance rate Periodic Corlesportding FINANCE 2 05 MAR PURCHASE CHECK 1 27(8 04346440 $ applied to rate APR CHARGE Purchases $6,60536 0.06342% 0 23.15% $117.30 Cash $0.00 0.06342% D 23.15% $0.00 ANNUAL PERCENTAGE RATE appliled tltls period: 23.15% At Your Service - Go to 1dJ ? to manses your account, O or Cat 14W-955-7070 to report a lost or stolen card or speak b OrskMar Relations 0 Pay Gnlirte M y_axp?caoitabne.com or Mai W Payment to: Capital One Bank (USA), NA. • P.O. Boot 71093 - Chmb*, NO 28272.1083 Send Inquiries to: Capital One P.O. Box 30285 • Sat Lake City, LT 84130-0285 ® Manage your Rewards online by visiting or Cat 1A00-22&3001 ® Have a question about a charge on your statement? Please refer to the Biting Rights Summary on the back of your statement or visit www caoitalone.comkisoutes PLEASE RETURN PORTION BELOW MTH PAYMENT OR LOG ON TO W WW.CAPITAUONE.COM TO MAKE YOUR PAYMENT ONLINE. 1 4003441496072484 13 6741840200000184006 Account Number. 4003.4414-9607-2484 Lend a hand. Save the land. Due Date New Balance Minimum Payment Amount Enclosed Manage your account online today- 84 741 2009 $6 07 A 00 $184 it's fast, easy and secure. . , pr. , . Pay online anytime-no more checks, stamps or chatter. PAY T PLE SE © Moving? Change your address online or on the back. MOUN A ® Help save the planet---Go paperless. #9007324158759306# ® Sign up at www.capitalone.com. PAUL G LUTHER capital one Bank (USA), N.A. 400 1 DAUPHIN ST p.0. Box 71063 ENOLA, PA 17025-2213 charlotte, NC 28272-1063 rd,ryurllr,lgnlhllhl'nth"hhl'Illl?llllrlhirl"1111 nlllh'Illkknlll?lrhlhn?'IIHh"II'I'Ill'Il?'Ilillhl'hll EXHIBIT A Please make checks payable to Capital One Bank (USA), N.A. and mail with this coupon in the enclosed envelope. p Spread too thin? Paying bills takes a lot of time: writing checks, addressing envelopes, mailing letters. Get some time back each month with Capital One® balance transfers. Consolidate your bills and higher-interest payments, maybe even save some money, and then spend your time relaxing, shopping or watching the game-instead of writing a lot of checks. L Ready to transfer? See reverse to learn how. Call 11-800-955-7070• Visa Platinum Account 40tk4441"@V.244 C? Your Account Information RKWARDS TOTAL CREDIT LINE $7,000.00 TOTAL AVAILABLE CREDIT $206.97 CREDIT LINE FOR CASH $1,400.00 AVAILABLE CREDIT FOR CASH $206.97 FINANCE Previous Balance Payments & Credits CHARGE ......- Transactions New Balance Minimum Payment /--- ---- ----- $6 - ,741.84 - $200.00 + L$51.19 )+ $200.00 _ $6,793.03 $119.00 --- Mar. 14, 2009 -Apr. 13, 2009 Page 1 of 1 PLEASE PAY AT LEAST THIS AMOUNT Finance Charges (Please see reverse for important informal in Balance rate Periodic Corresponding FINANCE applied to rate APR CHARGE Purchases $6,773.02 0.02438% 8.90;6 $51.19 Cash $0.00 0.02712% 9.90% $0.00 ANNUAL PERCENTAGE RATE applied this period: 0.00% _ J ---------- - - - ------- At Your Service • Go to wym oaaitakne.oom to manage your -nt, or Cat 1.8D0-955.7070 to report a bat or stobn cud or speak to customer Pelatiana ® Pay online at ,w,w.caoitebne.com ar rna your payment lo: Capital One B" (USA), N.A. • P.O. Box 71063 • Charlotte, NO 28272.1083 A Send Inquires to: Capital Ow P.O. Bo, 30285 • Sat Lake (Sty, UT 84130-0285 ® Manage your Rewards online by visiting arcs[ t?00.22&3007 ® Have a question about a charge on your statement? Please refer to the Biting Rights Summary on the back of your statement or visit www cadtaIgne com7disoulea 500258 Due hate May. 08, 2009 Rewards Summary Previous available balance: 1,541 Earned this period: 0 (rethcts transactions; posted during this biting orb) Available Balance: 1,541 Payments Credits & Adiustments 1 01 APR PAYMENT $200.OC- Transactions 2 31 MAR PURCHASE CHECK 1 27x6915047310 $2CO.CO Good News: Because of your on-time payment history, some or all of your Annual Percentage Rates (APRs) have been returned to your Non-Introductory Rate. PLEASE RETURN PORTION BELOW WITH PAYMENT OR LOG ON TO WWW.CAPITALONE.COM TO MAKE YOUR PAYMENT ONLINE. 1 4003441496072484 13 6793030200000119001 Gaw Account Number. 4003-4414-9607-2484 Lend a hand. Save the land. Due Date New Balance Minimum Payment Amount Enclosed Manage your account online today- May. 08, 2009 $6,793.03 $119.00 _- it's fast, easy and secure. Pay online anytime-no more checks, stamps or d„uer. PLEASE PAY AT LEAST 0 Moving? change your address online or on the back. THIS AMOUNT ® Help save the planet---Go paperless. #9010424158759309# ® Sign up at www.capitalone.com. PAUL G LUTHER 400 U DAUPHIN ST Capital One Bank (USA), N.A. P.0• Box 71083 ENOLA, PA 17025-2213 Charlotte, IN 28272-1083 r11111'Ir11lInIlII,ILIIIi"Ill'I'Illlll llll111„II'IIII,IIi„li,l Iliii?l,lll„1111'II'iliilll„iillll„il,l'lll,ll„ililllll'illl Please make checks payable to Capital One Bank (USA), NA. and mail with this coupon in the enclosed envelope. EXHIBIT A 500016 Need a home loan? A car loan? A savings account? A personal loan? Financing for braces or glasses? Capital One can handle it all. Hassle free! Visit capitalone.com for a complete list of products and services and to manage your account online. 11I - r MFE-?MyBE?R LEND R-- a? ¦ Vns Visa Platinum Account 4003.44144a07.24M (A!H * Your Account Information REWARDS' TOTAL CREDIT LINE $7,000.00 TOTAL AVAILABLE CREDIT $282.35 CREDIT LINE FOR CASH $1,400.00 AVAILABLE CREDIT FOR CASH $282.35 what's in your wallet? Previous Balance Payments & Credits FINANCE CHARGE Transactions New Balance Minimum Payment $6,793.03 -` $125.00 --- + $49.62 + --------? $0.00 -- $6,717.65 $116.00 `-------- --- ---- 2009 - May. 13, 2009 14 Apr Page 1 of 1 e , . PLEASE PAY AT LEAST THIS AMOUNT Finance Charges (Please see reverse for important information) Balance rate Periodic Corresponding FINANCE applied to rate APR CHARGE Purchases $6,783.72 0.02438% 8.90% $49.62 Cash $0.00 0.02712% 9.90% $0.00 ANNUAL PERCENTAGE RATE applied this period: 8.90% O At Your Service - Go to www caoilstas.com to mange your eaxxint, or Cat 1-000.955-7070 to report a bet or Wlan cad or speak to Customer Rei.b.e AM& Pay ONlne at www ceonalo e.eom or mad your payment to Capital One Bank (USA), NA. - P.O. Boot 71083 - Charlotte, NC 28272-1083 A Send Inquiries to: Capital Ow P.O. Box 30285 - Sal Lace City, UT 84130-0285 ® Manage your Rewards online by visiting a Cat 1-000-228 3001 ® Have a question about a charge on your statement? Please refer to the Biting Rights Summary on the back of your statement or visit www capitalim.tom7dsoules _Due Date_ Jun. 08, 2009 Rewards Summary Previous available balance: 1,541 Earned this period: 0 (reflects transactions posted during this oiling cris) Available Balance! 1,541 Payments Credits 6 Adiustments 1 06 MAY PAYMENT $125.00- PLEASE RETURN PORTION BELOW WITH PAYMENT OR LOG ONTO WWW.CAPITALONE.COM TO MAKE YOUR PAYMENT ONLINE. 1 4003441496072484 13 6717650125000116004 caw Account Number. 4003-4414-9607-2484 Due Date New Balance Minimum Payment Amount Enclosed Jun. O8, 2009 $6,717.65 $116 00 PLEASE PAY AT LEAST THIS AMOUNT #9013424158759306# PAUL 6 LUTHER 400 W DAUPHIN ST ENOLA, PA 17025-2213 ll'111I11111Lrllllr"IIIIrI11111111'11111111Prlllllllll111111' Lend a hand. Save the land. Manage your account online today-- it's fast, easy and secure. to Pay online anytime-no more checks, stamps or clutter. 0 Moving? Change your address online or on the back. ® Help save the planet ---Go paperless. ® Sign up at www.capitalone.com. Capital one Bank (USA), N.A. P•0- Box 71083 Charlotte, NC 28272-10&3 1111111'ill"II1II'll'Illllllrrllllll''ll'l'lll'll"IIIIIIII'llll EXHIBIT A Please make checks payable to Capital One Bank (USA), N.A. and mail with this coupon in the enclosed envelope. Capital One® does credit cards-and then some! 500016 Need a home loan? A car loan? A savings account? A personal loan? Financing for braces or glasses? Capital One can handle it all. Hassle free! Visit capitalone.com for a complete list of products and services and to manage your account online. 11211 MEMBER rurrerwea FM LENDER Visa Platinum Account mo3.4414Aeo7.2484 (44 /!H * ' Your Account Information REWARDS TOTAL CREDIT LINE $7,000.00 TOTAL AVAILABLE CREDIT $351.72 CREDIT LINE FOR CASH $1,400.00 AVAILABLE CREDIT FOR CASH $351.72 ??s?-Tn your wdlot? FINANCE Previous Balance Payments III Credits CHARGE Transactions New Balance Minimum Payment $6,717.65 $120.00 + $50.63 JL + $0.00 $6,648.28 $117.00 May. 14, 2009 - Jun. 13, 2009 Page 1 of 1 PLEASE PAY AT IFAST THIS AMOUNT Finance Charges (Please see reverse for important informatan) Balance rate Periodic Corresponding FINANCE applied to rate APR CHARGE Purchases $6,699.63 0.02438% 8.90% $50.63 Cash $0.00 0.02712% 9.90°% $0.00 ANNUAL PERCENTAGE RATE applied this period: 0.90%- J At Your Service • Go to www cmitahn-M to menage yw account, or Cat IAW955-7070 to repel a bst or slohn card or speel( to LLslow Relatiooc AM& Pay Online at Itww cedlabne.twm a met your Payment b: Capital One Bank (USA), N.A. • P.O. Box 71083 • C7larbtte, NC 28272-1083 A Send Inquiries to: captal One, P.O. Box 30285 - Sat Lake City, LT 84130.0285 ® Manage your Rewards online by visiting or Cat 1.808-228.3001 ® Have a question about a charge on your statement? Please refer to the Bi" Rights Summary on the back of your statement or visit www ca italone com/disrades Due Date Jul. 08, 2009 Rewards Summary Previous available balance: 1,541 Earned this period: 0 (nilbcis transactions pocked during this hiing cycle) Available Balance: 1,541 Po r?rcnts Credits & Adiustments 1 03 JUN PAYMENT $120.0c, PLEASE RETURN PORTION BELOW WITH PAYMENT OR LOG ON TO www.CAPITALONE.COM TO MAKE YOUR PAYMENT ONLINE. 1 4003441496072484 13 6648280120000117008 W"m Account Number: 4003-4414-9607-2484 Due Date New Balance Minimum Payment Amount Enclosed ( Jul. 08, 2009 $8.848.28 $117.00 ( --) PLEASE PAY AT LEAST THIS AMOUNT #9016524158759300# PAUL G LUTHER 400 W DAUPHIN ST ENOLA, PA 17025-2213 lyllnIIIIIIII..I'IIIIIIII11.1r111111111111111111111, 1111.11111r Lend a hand. Save the land. Manage your account online today- it's fast, easy and secure. e Pay online anytime-no more checks, stamps or clutter. 0 Moving? Change your address online or on the back. ® Help save the planet--Go paperless. ® Sign up at www.capitalone.com. Capital One Bank (USA), N.A. P.O. Box 71083 Charlotte, NC 28272-1083 I I I I I' 111"11111' I I' 1 1 1 1 1 1 1 I.l l l l l l"I I' 1' 1 1 l' 1 1"I 1111111' 1 1 1 1 EXHIBIT A Please make checks payable to Capital One Bank (USA), N.A. and mail with this coupon in the enclosed envelope. Capita! One® does credit cards-and then some " 500008 'what's ;nyour wallet? It could happen to anyone. Make sure you pay the amount due on your statement as soon as possible. PAULG LUTHER HOOPSE Keeping your credit in good standing can ou think th l W . an y ot more do a GOOD CREDIT = GOOD CREDIT REFERENCES You"re behind' BETTER INTEREST RATES (good credit could mean lower interest rates) payment IMPROVED CHANCES TO GET APPROVED FOR LOANS (when you want to buy a home or new car) Cd 2009 Capital O ne. Capital One is a federally registered service mark. All rights reserved. Previous Balance Payments III Credits FINANCE CHARGE Transactions New Balance minimum Payment $272.00 $0.00 + $4g,g5 + $39.00 ?_( $6,736.13 CS6:648.28)- - D Jun. 14, 2009 -Jul. 13, 2009 Page 1 of 1 PLEASE PAY AT LEAST THIS AMOUNT Visa Platinum Account 4003.44148807.2481 Your Account Information REWARDS TOTAL CREDIT LINE $7,000.00 TOTAL AVAILABLE CREDIT $263.87 CREDIT LINE FOR CASH $1,400.00 AVAILABLE CREDIT FOR CASH $263.87 Finance Charges (Please see reverse for important information) Balance rate periodic Corresponding FINANCE appiedto rate APR CHARGE Purchases $6,679.62 0.02438% 8.90% $48.85 Cash $0.00 0.02712% 9.90% $0.00 ANNUAL PERCENTAGE RATE applied this period: 8.80% - ! At Your Service • Go to WNI cmitelxna.aom In manage your account, or cat 1.800-955.70701orepot a hsl a slohn card or speak to Customer Relations, ® Pay Odkw at www.gmitalpaii or mail your payment to: Capital One Banc (USA), NA. • P.O. Bas 71083 • Cherift, NC 28272-1083 A Send Inquiries to: Captal Orly P.O. Box 30285 - Set Lake Oly UT 8, 41 00285 ® Manage your Rewards online by visiting or Cat t-800.228-3001 ® Have a question about a charge on your statement? Please refer to the Billing Rights Summary on the back of your statement or visit www.cacitalam.com/di3pule5 Due Date Aug. 07, 2009 You're behind by one payment. Remember that paying the minimum payment by the due date keeps your account current. So make sure you send in the minimum payment to keep your account current. "Important Notice" Your account was past due. Under the terms we previously disclosed to you, if your account is past due again in the next 12 billing cycles, your Annual Percentage Rates (APRs) may increase. Rewards Summary Prevalrs available balance: 1,541 Earned this period: 0 (retacts transactors posted during ft bitig cycle) Available Balance. 1,541 Payments, Credits & Adjustments.----...-- ---------------._.._-__.-- Transactions 1 08 JUL PAST DUE FEE $39.00 You were assessed a past due fee because your minimum payment was not received by the due date. To avoid this fee in the future, we recommend that you allow at least 7 business days for your minimum payment to reach Capital One. PLEASE RETURN PORTION BELOW WITH PAYMENT OR LOG ON TO WWW.CAPtTALONE.COM TO MAKE YOUR PAYMENT ONLINE. GTE"'"' Account Number. 4003-4414-9607-2484 Due Date New Balance Minimum Payment Amount Enclosed (Aug. 07, 2009 --$6,736.13) $272.00 -- _-_j `PLEASE PAY AT LEAST TNIS AMOUNT 1 4003441496072484 13 673613D120000272009 #9019524158759307# PAUL G LUTHER 400 W DAUPHIN ST ENOLA, PA 17025-2233 I I I II I II II11,11111,111111I I I 11111,1111... Lend a hand. Save the land. Manage your account online today- it's fast, easy and secure. Q Pay online anytime-no more checks, stamps or clutter. ® Moving? Change your address online or on the back. ® Help save the planet--Go paperless, 0 Sign up at w .capitalone.com. Capital Ona Bank (USA), N.A. P.O. Box 71083 Charlotta, NC 26272-1083 IIIIIII'lll"lull'll'Illllllrrllllll"II'I'lll'll"IIIIIIII'llll EXHIBIT A Please make checks payable to Capital One Bank (USA), NA. and mail with this coupon in the enclosed envelope. Ca.h.V. J. your wallet? LET'S TALK - WE'RE HERE TO HELP. 500009 Sometimes unexpected expenses keep you from making your credit card payments. We understand, At Capital One,, we're here to help you keep your credit on track. Give us a call. Here are 3 easy ways to make a payment: • Give one of our associates a call at 1.800.955.6600. • Mail us the amount due on your statement. • If you have Internet access, you can make a payment securely online by logging on to www.capitalone.com. 0 202`7 Capital One. Capital One is a federally registered service mark. All rights reserved. FINANCE Previous Balance Payments & Credits CHARGE - Transactions New Balance Minimum Payment Due Date ---- ---- ---- --_.- $6,736.13 -? $0.00 + ( $103.30 +l $39.00 $6,878.43 $483.00 ) Sep. 07, 2009 Jul. 14, 2009 -Aug-13,2009 Page 1 of 1 c PLEASE PAY AT EPAST THIS AMOUNT Visa Platinum Account 4003.4414-M7.204 (rti?Mw* Your Account Information NWARDF TOTAL CREDIT LINE $7,000.00 TOTAL AVAILABLE CREDIT $121.57 CREDIT LINE FOR CASH $1,400.00 AVAILABLE CREDIT FOR CASH $121.57 You're behind by two payments. Let's talc. If you're having financial difficulties and can't make your minimum payment - we want to help. Let's work together to find a solution. "Important Notice" Under the terms we previously disclosed to you, your account is now eligible for an increase in Annual Percentage Rales (APRs) effective immediately. However, Capital One has elected not to raise your APRs at this time. Please be advised that if you fail to keep your account in good slanding, Capital One reserves the right to raise your APRs in the future. Rewards Summary Finance Charges (Please see reverse for important information) Balance rate Periodic Corresponding FINANCE applied to rate APR CHARGE Purchases $6,794.75 0.04904% 0 17.90% $103.30 Cash $0.00 0.06822% 0 24.90% $0.00 ANNUAL PERCENTAGE RATE applied this period: 17.90% A!M O At Your service. Go to wxm oao8abnirown to menage your soccunl. or Cat 1-M-955-7070 to repot abet or stolan card a speak to Customer Relations Previous available balance: 1,541 Earned this period: 0 (raldds Ininsectiorre Posted during this biting cycle) Available Balance 1.541 Payments, Crecilb 8r Adiustments Transactions 1 07 AUG PAST DUE FEE $39.00 ® Pay Online at www cad(ebne.com or mail your payment to: You were assessed a past due fee because your minimum payment was not received by the due data. To Capital 2=0ne Bawc (USA), N.A. • P.O. Box 71083 • Charlotte, NC avoid this fee in the future, we recommend that you allow at least 7 business days for your minimum 28272--1083 e payment to reach Capital One. Send Inquiries to: Cap(el Ora• P.O. Box 30285 • Sat Cake City Jr 8, 4100285 ® Manage your Rewards online by visiting a Cat tA00-218.01 ® Have a question about a charge on your statement? Please refer to the ailing Rights Summary on the back of your statement or visit www.capitelorie.com/dsmtes PLEASE RETURN PORTION BELOW WITH PAYMENT OR LOG ON TO WWW.CAPITALONE.COM TO MAKE YOUR PAYMENT ONLINE. 1 4003441496072484 13 6878430120000483006 Cniia?ft Account Number: 4003-4414-9607-2484 Due Date New Balance Minimum Payment Amount Enclosed Sep. 07, 2009) ' $6,878.43l $483.00 PLFASE PAY AT LEAST THIS AMOUNT 119022624158759300}1 PAUL 6 LUTHER 400 N DAUPHIN ST ENOLA, PA 17025-2213 rllldluhhrlll....0.1111'Ir111n1r1 Lend a hand. Save the land. Manage your account online today- it's fast, easy and secure. e Pay online anytime-no more checks, stamps or clutter. © Moving? Change your address online or on the back. ® Help save the planet-Go paperless. ® Sign up at www.capitalone.com. Capital One Bank (USA), N.A. P.O. Box 71083 Charlotte, NC 28272-1063 ullll''111"obit'h'IIIP""Ilnh"II'1'lll'll"Illllhl'INI EXHIBIT A Please make checks payable to Capital One Bank (USA), NA. and mail with this coupon in the enclosed envelope. PAUL G LUTHER C . In your wallet? MAKE A PAYMENT. AND TAKE CONTROL 500010 OF YOUR CREDIT WITH CAPITAL ONE? Your account is temporarily unusable. The good news is, by paying the amount due on your statement, you can still bring your account into good standing. Let's work together to bring your account back to good standing. You can make a payment with our &g check by phone service or speak to an associate by calling 1.800.955.6600. 0 2009 Capital One. Capital One is a federally registered sm+ice mark. All rights resmred Previous Balance 43- 878 $ Payments & Credits 00 D + $0 FINANCE CHARGE Transactions New Balance 92 + $78.00 = $7,065.35 $108 Minimum Payment 1 $701.00 . ` 6, . 1?.__._ . 2009 - Aug. 14 Sep. 14, 2009 Page 1 of 1 , --_? PLEASE PAY AT LEAST THIS AMOUNT Visa Platinum Account 4003 4411 9B0T•24a4 ?2HW5* Your Account Information RewAROs TOTAL CREDIT LINE $7,000.00 TOTAL AVAILABLE CREDIT $0.00 CREDIT LINE FOR CASH $1,400.00 AVAILABLE CREDIT FOR CASH $0.00 Finance Charges (Please see reverse for important information) Balance rate Periodic Corresponding FINANCE applied to rate APR CNARGE Purchases $6,940.75 0.04904% D 17.90% $108.92 Cash $0.00 0.06822% D 24.90% $0.00 `ANNUAL PERCENTAGE RATE applied tlIB pedod_17.90% At Your Servke • Go to MZ ranitabne.aom to mar age yax amount, or Cat 1410955-7070 to report a bbl or slolan Ord or speak to Cuslomor 11shbons 0 Pay Gnikw at wwwcedialawom mmet Y-Psymwd lo: Capital Ora Baer (USA), N.A. • P.O. am 71063 • Caarbtte, NC 26272-1083 A Sapid Inquiries roe Capital Ow P .O. . Bo. 30285 • Sal Lake City, LT 84130-0285 ® Manage your Rewards online by visiting or Cat 1A00-228-3001 ® Have a question about a charge on your statement? Please refer to the Billing Rights Summary on the back of your statement or visit www.cm?takxw.com/d-smtes Due Date Oct. 09, 2009) You're behind by three payments. But you can bring your account current by paying the minimum payment amount on your statement. If you re having financial difficulties and you re feeling overwhelmed - we want to help. Cite one of our associates a call at 1.800.955.6600. You'd be surprised what we can do together to work this out. Rewards Summary Previous available balance: 1,541 Earned this period: 0 (ralkgs tronsact om posted during this biarg cycle) Available Balance: 1,541 & Adjustments Payments Credits . Transactions ----- 1 07 SEP PAST DUE FEE $39.00 2 14 SEP OVERLIMIT FEE SEP 14, 2009 $39.100 Your account has gone over its credit limit. To avoid adrtitiaral overlimit fees, YOU should parr more than the Minimum Payment. Please pay enough to bring your account balance below your credit limit immedlatety, and make sure your account balance remains below your credit limit. Please be sure the amount you pay accounts for any future purchases, fees, and finance charges. You were assessed a past due fee because your minimum payment was not received by the due date. To avoid this fee in the future, we recommend that you allow at least 7 business days for your minimum payment to reach Capital One. Important change to your Rewards travel redemptions beginning February 2010' A booking fee may apply when you call our Rewards Center to book travel using your rewards. However, you can still book travel online for free at www.ca0talorie.com. PLEASE RETURN PORTION BELOW WITH PAYMENT OR LOG ON TO VAVW.CAPETALONE.COM TO MAKE YOUR PAYMENT ONLINE. 1 4003441496072484 13 7065350120000701003 Account Number. 4003-4414-9607-2484 Due Date New Balance Minimum Payment Amount Enclosed Oct. 09, 20091 $7,065.35 $701.00 PLEASE PAY AT LEAST THIS AMOUNT #9025824158759303# PAUL G LUTHER 400 W DAUPHIN ST ENOLA, PA 17025-2213 r hn 11.11111.111111- - 1-111-1111-I--I-11-111" 1. 11111111111.... II GO GREEN. SAVE GREEN! Pay online and save money on stamps. Cs Sign up at www.capitalone.com Capital One Bank (USA), N.A. P.O. Box 71083 Charlotte, NC 28272-1083 1111111-111--11111-1I-1111111--111111--11'1-III-11--11111111.1111 EXHIBIT A Please make checks payable to Capital One Bank (USA), NA. and mail with this coupon in the enclosed envelope. PAUL G LUTHER --;z capff what's in your wallet? 500011 TAKE CONTROL OF YOUR CAPITAL ONEO ACCOUNT AND KEEP IT FROM BEING PERMANENTLY UNUSABLE. we're here to help. You can regain your charging privileges and bring your account back into good standing by paying the amount due on your statement. Let's work together to bring your account back to good standing. You can make a payment with our free check by phone service or speak to an associate by calling 1.800.955.6600. 0 2009 Capital One. Capiktd One is a fideraI6 regisrrred scmicc mark. AR rigba raemed. FINANCE Previous Balance Payments 9 Credits CHARGE Transactions New Balance Minimum Payment $7,065.35 -( $cl m? + ? -- $101_27 j+? $78.00 J -?M1 $ 62 $913.00 --) Sep. 15, 2009 - Oct. 13, 2009 Page 1 of 1 PlTASF PAY AT IfASr THIS AMOUNT Asa Platinum Account 4003.44144!07.2494 ? Your Account Information 111111WASWIr TOTAL CREDIT LINE $7,000.00 TOTAL AVAILABLE CREDIT $0•00 CREDIT LINE FOR CASH $1.400.01 AVAILABLE CREDIT FOR CASH $0.00 Finance Charges (Please see reverse for important information) Balance rate Periodic Corresponding FINANCE applied to rate APR CHARGE Purchases $7,120.81 0.04904%0 17.90% $101.27 Cash $0.00 0.06871% D 24.90% $0.00 ANNUAL PERCENTAGE RATE applied this "d_17.90% -? Aj_h At Your Service • Go to www ya bbre mm to menega your account, or eat 1-a-955.7070 to report a bst or stolen cad or speak to Orstomer Relations 0 Pay Gtdina at www caoitabne oom m mail your payment to: Capital One Bank (USA), N.A. • P.O. Box 71093 • Chmbtle, NC 28272.1083 A Sand Inquiries m: Coital Ow rin P .O. . Box 30295 - Sal Lake City, UT 84130-0285 ® Manage your Rewards online by visiting orCat 100.228-3001 ® Have a question about a charge on your smtament4 Please refer to the Billing Rights Summary on the back of your statement or visit www caoitalone ccmlddsoutes Due Date Nov. 07, 2009), You're behind by four payments. But you can still bring your account current by paying the minimum payment amount on your statement. Need help? Give us a cal at 1.800.955.6600. Wit work together to find a solution. Rewards Summary Previous available balance: 1,541 Earned this period: 0 (raw. transactions pasted during this billing cycb) Available Balance: 1,541 Payments, Credits dr Adiustments Transactions 1 09 OCT PAST DUE FEE $39.00 2 Q OCT OVERLIMIT FEE OCT 13, 2009 $38.00 Your account has gone over its credit limit. To avoid additional wedimit fees, you shodd pay more than the A9rtimum Payment. Please pay enough to bring your account balance below your credit limit immediately, and make sure your account balance remains below your credit limit. Please be sure the amount you pay accounts for any future purchases, fees, end finance charges. You were assessed a pest due fee because your minimum payment was not received by the due dale. To avoid this fee in the future, we recommend that you allow at least 7 business days for your minimum payment to reach Capital One. PLEASE RETURN PORTION BELOW WITH PAYMENT OR LOG ON TO WWW.CAPITALONE.COM TO MAKE YOUR PAYMENT ONLINE. 1 4003441496072484 13 7244620120000913007 Account Number: 4003-4414-9607-2484 Due Date New Balance Minimum Payment Amount Enclosed (Nov. 07, 2009 $7,244.62 $913.00 - PLEASE PAY AT LEAST THIS AMOUNT #9028724158759302# BE SAFE! Your trash could be an identity thiefs . gold. Manage your account online and end the paper trail. Sign up at www.capitalone.com PAUL G LUTHER Capital One Bank (USA), N.A. 40o U DAUPHIN ST p.0• Box 71083 ENOLA, PA 17025-2213 Charlotte, NC 20272-1063 rrlurrrh"Illllulll?l?rnnrrnnllhr,llnllrrlnlrllrgnnl lrlllh?ln??llhl?hrltllul"Iluh??ll'I'Ill?ll^Ilhlhl?hll EXHIBIT A Please make checks payable to capital One Bank (USA), NA. and mail with this coupon in the enclosed envelope. PAUL G LUTHER Caw xi your wallet? IT'S STILL NOT TOO LATE. Your account is unusable. Please pay the amount due on your statement by the due date. Remember we're here to help! 500012 Let's work together to find a solution that's right for you. You can make a payment with our fry check by phone service or speak to an associate by calling 1.800.955.6600. Ca 2009 Capital One. C: rpital Ow it a frderaRy rexiar rd sereire mark. All rigbti reserved. FINANCE Previous CHARGE Transactions New Balance Minimum Payment l -Due late -.? - ?---.^. Balance' 8 Credits i + = $7,433.70 $1,137.00 } .(Dec. 08, 2009 $7,244. 62 _ Payments 0 $11108 $78.00 _00 C? ---- --%----- ----? ` -----------......--- Oct. 14, 2009 - Nov. 13, 2009 Page 1 of 1 PLEASE PAY AT I AST THIS AMOUNT Visa Platinum Account 4003•44144W-24B4 ' ,Il W Your Account Information REWARDS TOTAL CREDIT LINE $7•x•00 TOTAL AVAILABLE CREDIT $0.00 CREDIT LINE FOR CASH $1,400.00 AVAILABLE CREDIT FOR CASH $0.00 Finance Charges (Please see reverse for important information) Balance rate Periodic Corresponcing FINANCE applied to rate APR CHARGE Purchases $7,307.00 0.04904% 0 17.9D% $111.08 Cash $0.00 0.06822% D 24.90% $0.00 ANNUAL PERCENTAGE RATE applied this period: 17.00% - j1h At Your Service • Go In wwacwils to menage your account, or cat 1-0W955-7070 ID repot a lest or stolen card or speek b Customer RaleaOns ® Pay fhdNe at www ca ilabna win or met your Payment b: C40W One Banc (USA), N.A. • P.O. Box 71083 • Charbtle. NC 25272.1083 A Sand Inquiries to: Captel Orr rr P .O. . Box 30285 • Sal Lake (Sty, UT 84130.0285 ® Manage your Rewards online by visiting or Cat 1.8W228.3001 ® Have a question about a charge on your statement? Please refer to the Billing Rights Summary on the back of your statement or visit www ca6talone com16SQUtes You're behind by five payments. If you continue to miss payments your account is at risk of being charged oB. Please don't let this happen. If you re feeling overwhelmed, call us at 1.800.955.6600. Well work with you to resolve this matter. Rewards Summary PrevtoOs avam* balance 1,541 0 Earned this period' (relbds transactions posted during this hung %rb) Available Balance 1,541 ° nts Credits 3 Adiustments Transactions 1 07 NOV PAST DUE FEE $39.00 2 13 NOV OVERLIMIT FEE NOV 13, 2009 $39.00 Your account has gone over its credit limit. To avoid additional overlimit fees, you should Pay more than the Minimum Payment. Please pay enough to bring your account balance below your credit limit immediately, and make sure your account balance remains below your credit limit. Please be sure the amount you pay accounts for any future purchases, fees, and finance charges. You were assessed a past due fee because your minimum payment was not received by the due dale. To avoid this fee in the future, we recommend that you allow at least 7 business days for your minimum payment to reach Capilal One. PLEASE RETURN PORTION BELOW WITH PAYMENT OR LOG ON TO WWW.CAPrTALONE.COM TO MAKE YOUR PAYMENT ONLINE. c?";""" Account Number: 4003-4414-9607-2484 Due Date New Balance Minimum Payment Amount Enclosed Dec. 08, 2009 C$7,433.7 (` - PLEASE PAY AT LEAST THIS AMOUNT 1 4003441496072484 13 7433700120001137006 #9031824158759305# PAUL 6 LUTHER 400 U DAUPHIN ST ENOLA, PA 17025-2213 urll1'.11.1,111111 111. IIdr11111111111dl''IIIIInrle GO PAPERLESSI The trees will thank you. Sign up at www,capitalone.com Capital One Bank (USA), N.A. P•O. Box 71083 Charlotte, INC 28272-1083 it III ,If I'-II'II-II'1111111rr111111"11'1'111'[1"11111111'1111 EXHIBIT A Please make checks payable to Capital One Bank (USA), N A. and mail with this coupon in the enclosed envelope. PAUL G LUTHER c what's I. your wallet? 500013 IT'S TIME TO TAKE CONTROL OF YOUR DEBT. WE'RE HERE TO HELP. Even if we report your account as charged off, you'll still be responsible for paying your debt. So why not gall us to see what we can do together to keep you from receiving such a serious mark on your credit record? Please contact us to find a solution that's right for you. You can make a payment with our fl, 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 by the due cate to eliminate the risk of being charged off. 0 2009 Capital One. Capital Ora it a frderally regitund rtrvie, mark. All rights remnred FINANCE Previous Balance Payments & Credits -CHARGE _ Transactions New Balance Minimum Payment $7,433.70 ,-?- $0.00 + $110_26*( $39.00 )_ $7,582.96 ) $1,362.00 Nov. 14, 2009 - Dec. 13, 2009 Page 1 of 1 PLEASE PAY AT LEAST THIS AMOUNT Visa Platinum Account 4003.44144807.2484 ' Your Account Information 1IlWARDS TOTAL CREDIT LINE $7,000.00 TOTAL AVAILABLE CREDIT $0.00 CREDIT LINE FOR CASH $1,400.00 AVAILABLE CREDIT FOR CASH $0.00 Finance Charges (Please see reverse for important information) Balance rate Periodic Corresporr4ng FINANCE applied to rate APR CHARGE Purchases $7,494.61 0.04904% D 17.90% $110.26 Cash $0.00 0.061322% 0 24.90% $0.00 ANNUAL PERCENTAGE RATE applied this period: 17.90% AT-h At Your Service - Go to www capdabne oom to manage your account. IQTJ or Col 1-000455-7070 b report a bet or stobn card or speak to Customer Relsions ® Pay Online at www caoitabne.oom or mad your payment lo: Cepdal One Bak (USA), N.A. - P.O. Box 71083 - Charlotte. NC 28272-1083 A Sand Inquiries to; Capital One- P.O. Box 30285 - Sal Lake Cry, UT 84130.0285 Mbk Manage your Rewards online by visiting oCA 1-000.228.3001 is Have a question about a charge on your statement? Please refer to the Billing Rights Summary on the back of your statement or visit www caoitalone com/dismies Due Date Jan. 07, 2010 You're behind by six payments. If we charge off your account due to late or missed payments, finance charges will continue to accrue. Act now to prevent this from happening. Please pay the minimum payment amount on your statement or give us a cal at 1.800.965.6600. We're here to help. Take control of your credit with Capital One. Rewards Summary Previous available balance: 1,541 Earned this period. 0 (reflects transactions posted during ft biting cych) Available Balance: 1,541 Payments Credits dr Adjustments Transactions -------- 1 08 DEC PAST DUE FEE $39.00 Your account has gone over its credit limit. To avoid additional overimit fees, you should pay more than the Minimum Payment. Please pay enough to bring your account balance below your cre(At limit immediately, and make sure your account balance remains below your credit limit. Please be sure the amount you pay accounts for any future purchases, fees, and finance charges. You were assessed a past due fee because your minimum payment was rat received by the due date. To avoid this fee in the future, we recommend that you allow at least 7 business days for your minimum payment to reach Capital One. PLEASE RETURN PORTION BELOW WITH PAYMENT OR LOG ON TO WWW.CAPITALONE.COM TO MAKE YOUR PAYMENT ONLINE. 1 4003441496072484 13 7582960120001362001 G Account Number. 4003-4414-9607-2484 Due Date New Balance Minimum Payment Amount Enclosed Jan. 07, 2010 $7,582.96 $1,362.00 _-- PLEASE PAY AT LEAST THIS AMOUNT #9034724158759304# ORGANIZATION " MADE EASY. Forget the filing. Manage your account online and simplify your life. Sign up at www.capitalone.com PAUL 6 LUTHER Capital One Bank (USA), N.A. 400 U DAUPHIN ST P.O. Box 71083 ENOLA, PA 17025-2213 Charlotte, NC 28272-1083 rrrurllrrqrlif Ill IIIIIIrtill-I'IIIIlhllr11111111to III IIIIIIIII I(11111-111--I11d-II-1111111--llutt--II-I-III-IIrrllllllll-llll Please make checks payable to Capital One Bank (USA), N.A. and mail with this coupon in the enclosed envelope. EXHIBIT A PAUL G LUTHER CAPITAL ONE BANK (USA), N.A., Plaintiff, V. PAUL G LUTHER Defendant(s). VERIFICATION The undersigned does hereby verify subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities, that he/she is an authorized agent of CAPITAL ONE BANK (USA), N.A., Plaintiff herein, and that he/she is duly authorized to make this Verification, and that the facts set forth in the foregoing Complaint in Civil Action are true and correct to the best of his/her knowledge, information and belief. Dated: 1 v Margaret Parton N00000034125054 788708071 A088 HAYT, HAYT & LANDAU SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy - Richard W Stewart Solicitor Capital One Bank (USA) vs. Paul G. Luther Case Number 2010-5620 SHERIFF'S RETURN OF SERVICE 09/14/2010 07:38 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on September 14, 2010 at 1938 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Paul G. Luther, by making known unto himself personally, at 400 W. Dauphin Street, Enola, Cumberland County, Pennsylvania 17025 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $41.94 September 15, 2010 RYAN BURGETT, DEPUTY SO ANSWERS, RON R ANDERSON, SHERIFF 0) ,, FILF~-C; ~IC~ fir T~~~ '~~~T6-3~t.~OT~,~';° BY: Paul G. Luther Pro Se 400 West Dauphin Street 2010 ~~T _(~ ~~ ~~~ Enola, PA 17025 1 IN THE COMMON PLEAS COURT OF THE COMMONWEALTH ~' ~- t ~ •1 ~' ' ` ~ !,~ P. t ~ . ~~r~.. r ~ ~,..t,~;! , OF PENNSYLVANIA IN AND FOR CUMBERLAND COUNTY CAPTI'AL ONE BANK ) Plaintiff ) v ) Case Number: 10-5620 Civil Paul G. Luthely Pro Se Litigant ) Defendant ) ANSWRR OFD .~ ANT The Pro Se Defendant hereby enters his appearance and answers the Complaint of as foIlaws: 1. The Defendant is without knowledge or information sufficient to form a belief as to the truth of this averment 2. Admitted. 3. Denied in Part. Admitted irui Part. Defendant does not recall applying for the credit card and requests a copy of the application. Defendant does admit to receiving a Capital One Bank credit cazd. 4. Admitted. 5. Denied. Defendant does not recall agreeing to any terms with the Plaintiff and requests Plaintiff produce any and all signed Agreements between the two pazties. G. Denied. Defendant requests that Plaintiff produce a complete and dear accounting of all debits, credits, interest fees, late fees and the like (monthly statement aze not sufficient since it commin~es principal with late fees, interest fees, etc and not all payments are applied to the principal) for Defendant to review. The document attached as Exku'bit "A" is self-serving and does not provide a complete accounting of the account nor an Agreement between die parties. Strict proof is demanded at time of trial. Further, Exhibit "fi' cannot replace the agreement, if exists, thus Plaintiff has failed ip overcome its burden of proof. 7. Denied. Defendant has paid monthly statement but refutes the uxterest rates, late fees and dre like and requires a complete accounting as described above before continuing any further payments. WI~'REFORE: The Defendant respectfully requests that Plaintiffs Complaint be dismissed and the relief requested in Plaintiff s Complaint be denied. NEW MATTER 8. Plaintiffs Complaint fads to set foz a cause of action upon which relief maybe granted. 9. Plaintiffs Complaint if barred by the operation of the doctrine of Lathes. 10. Plaintiff s Complaint is booed by the operation of the doctrine of unjust enrichment. 11. Plaintiffs Complaint is barred by the operation of the doctrine of estoppel 12. The relief sou~t by the plaintiff herein if grouted, would be violate public poIi~y. 13. Plaintiff s Complaint is boned because Defendant did not breach any Agreement as a matter of law. 14. Plaintiff s Claims aze barred by the doctrine of promissory estoppel 15. Plaintiff s Claims aze barred by the applicable statute of limitations. 16. Plaintiff is not entitled to relief based upon any alleged contract, which is expressly denied, because plaintiff failed to satisfy all conditions precedent to the enforcement of the provisions if there was such a contract 17. Answering Pro Se Defendant reserve the right to and this New Matter to include additional New Matter that may become available during the course of discovery of this matter. The Defendant verifies that the statements made herein are true and correct based upon his knowledge, infom~atiou and belief. The statements are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unswom falsification to authorities. BY: Paul G. Luthe ro Se 400 West Dauphin Street Enola, PA 17025 CERTIFICATE OF SERVICE -~ d ~./ o~~ The Defendant HEREBY CERTIFIES that on this ~ day of , Z~ copy of the foregoingpleadingwas mailed, first-class, postage pre-paid Tb: Arthur Lashin, Esquire 400 Market Street, Suite 600 Philadelphia, PA 19106 BY: Paul G. Luther, Pro Se 400 West Dauphin S treet Enola, PA 17025 This document mas completed by or with the assistance of an attorney employed at Unbundled Legal Services, LLC Fit,.D'C~FFii.E aF ~'{~~ R~ ! HOOiAR`t 2D10 OCT -8 P~ I : 32 ~~ ~E ~S`f L~ C~U~ 1 ~ CUMBERLAND COUNTY COURT OF COMMON PLEAS •. cl~~ DIVISION TERM, No.: },0-5620-Ci~i 1 PRAECIPE TO DISCONTINUE WITHOUT'PREJUDICE HAYT, HAYT & LANDAU BY: ARTtIUR LASIiIN . IDENTIFlCATION NO. 23425 .ATTORNEY FOR PLAINTIFF ~ . SOCTH FLOOR 400 MARKET STREET PHILADELPHIA, PA 19106-2509 {215) 928-1400 ; . TO. TJ~ PROTHONTARY e . Kindly discontinue the above captioned matter 'w'ithout prejudice. EAYT, ~,YT & I~ANDAII