HomeMy WebLinkAbout07-0997IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK
VS. Plaintiff No: 07 ., q97 COMPLAINT IN CIVIL ACTION
CAROLINE M DARHOWER
Defendant FILED ON BEHALF OF
Plaintiff
COUNSEL OF RECORD OF
THIS PARTY:
James C. Warmbrodt,42524
WELTMAN, WEINBERG & REIS CO., L.P.A.
436 Seventh Avenue, Suite 2718
Pittsburgh, PA 15219
(412) 434-7955
FAX: 412-338-7130
05701486 C A Pit CXC
T
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK
Plaintiff
vs. Civil Action No
CAROLINE M DARHOWER
Defendant
COMPLAINT AND NOTICE TO DEFEND
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 an 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.
LAWYER REFERRAL SERVICE
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
(717) 249-3166
COMPLAINT
1. Plaintiff, CAPITAL ONE BANK is a corporation with offices at 6851
JERICHO TURNPIKE #190 SYOSSET , NY 11791 .
2. Defendant is adult individual(s) residing at the address listed
below:
CAROLINE M DARHOWER
371 ARMY HERITAGE DR APT
CARLISLE, PA 17013
3. Defendant applied for and received a credit card bearing the
account number 4121741586221272 .
4. Defendant made use of said credit card and has a current balance
due of $2446.32 , as of January 26, 2007 .
5. Defendant is in default by failing to make monthly payments when
due. As such, the entire balance is immediately due and payable to
Plaintiff.
6. Plaintiff is entitled to the addition of interest at the rate of
11.900a per annum on the unpaid balance from January 26, 2007 . A copy
of Plaintiff's STATEMENT is attached hereto, marked as Exhibit "1" and
made a part hereof.
7. Although repeatedly requested to do so by Plaintiff, Defendant has
willfully failed and/or refused to pay the balance due to Plaintiff.
Wherefore, the Plaintiff prays for judgment in its favor and
against Defendant , CAROLINE M DARHOWER , INDIVIDUALLY , in the amount
of $2446.32 with continuing interest thereon at the rate of 11.9000
per annum from January 26, 2007 plus costs.
James Warmbrodt,42524
WELT WEINBERG & REIS CO., L.P.A.
436 eve th Avenue, Suite 2718
Pit sbu gh, PA 15219
(4 2) 4 4-7955
F 4 2-338-7130
0 701 86 C A Pit CXC
This law firm is a debt collector atzte ting to collect this debt for
our client and any information obt i d will be used for that purpose.
NOW wrfth
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capifalcw
Account S
Previous Balance 11
790.70
Payments Credits and Adjustments ,
1.00
Transactions 135
00
Finance Charges .
11728
New Balance 11,832.98
Minimum Amount Due 11
93298
Payment Due Date ,
April 15, 2004
Total Credit Line 12
500
Total Available Credit ,
$.00
Credit Line for Cash s1
250
Available Credit for Cash ,
100
At your sevice
To call Costume Rd.&-
or :o report a Iwt or rtolah acrd:
1-800-903-3637
Sad paymems to, Send inquiries to.
Attn: R- imnoe Procaeing
Capital One services Capital One Sa.;ea
P.O. Box S5147 P.O. Boa 85015
Richmond, VA 23276 Richmond, VA 23285-5ol5
I?portant Account Information
This month you will receive your 2004 Guide To Rene*
which sets forth all the additional benefits and services you
may be eligible to receive this year. These benefits and services
supersede any benefits and services provided in your 2003
Guide To Benefits or other additional benefits and services
previously communicated to you. Please read and retain for
your records.
VISA ACCOUNT
4121-7415-8622-1272
Pa vtents, Credits and Adjustments
Tnamactions
FEB 16 - MAR 15, 2004
Page 1 of 1
1 15 MAR PAST DUE FEE 135.00
Your request to dose your account has been received. Yar account will be dosed when it reaches a 10 balance,
Una then, you will continue to receive amemetm and must continue to make payments. All terms and
conditions of the account win apply while a balance remains. Please remember to cut your cards and cancel all
charges which amomatiually bill to your a.vmunt
You were assessed a past due fee of 135.00 on 03/15/2004 becwse yen><.nninimum payment was not
received by the due date of 03/15/2004. To avoid this fee in the our; we recommend that you
allow at least 7 business days for yaw payment to reach Capital One.
003
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EXHIBIT
F-. Charges
P/eareter npeltertartjor tsvpartanr lAlgAl
?
t
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A
e ({??
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/
{
PURCHASES 31,67451 .
CASH 032609{ 1L90%
f15
Ss
311452 . 04356% 15.90% .
s1.45
ANNUAL PERCENTAGE RATEap h d this
e W
p 12.16%
?1- ^ ? PLEASE RETURN PORTION BELOW WITH PAYMENT. v
Ca?107e' 0000000 0 4121741586221272 15 1832980045001832987
New Balann c 11932.98 R-prw-dnIddd`°*,'aas' filch-jsbrk--CR- or 41.4 nk
Minimum Amount Due 11832 98
Paymert Due Date Apt,
April 35, 2004
Gry Scan ZIP
Total enclosed $
AecotmtNumber Ho'es` pose Apeman Photo
4121-7415-8622-1272
Fmd Addrm
#9007642282587966# MAIL ID NUMBER
CAROLINE M DARHOWER
Capital One Bank 371 ARMY HERITAGE DR
P_0. Box 85147 111 IfIIall111111111111 APT 19
Richmond, VA 23276 0 ?- CARLISLE PA 17013-7307
uunsfn II.I., off 111.1h. 111.11...
Pleae -teyow a count nttsaber onyuty rl e.4 or rn,Aty wder Amde payable to Capital 0, Bank aad oval/ in then d od en .4&
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n v. nave "amp, You we Aare a I-"- Brace period of
26 days without fins. airrpo an row Dtmdheaes, new,
balance t-.%,, row +P"ru"n purduses and nnevv othw
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and In term for It to be bted?ce for wa honor
rdoakap dote. Thom 1- ro by your Tasd stem nest
end +PedN tmmbm. b area Period can cash advscaa
an any trwactionif addition, on, them s ro Race "mod
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transaction is Pmwe d to your Account or 31 from tls
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it You aid not pay the -New Beano' term the previos
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previously disclosed to
ft* u, At me and of aclh e.y dhd ni;
a q penpd use +PPIVyo1W dry Pedodic ram for c as I
++ilrnerm oT ytMw accasa 10 da dNhrekdenae m sack
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mules from ea.h? ad1 segnsd. We add cep the
to u ?ssgment m arrive g thIe meal perto6c
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PBOpI?I; 'stay tle forth. Omer and 6 not a ifeled dM Capital One. ('.Bp1210ne does mat pmuide, and.
?ds? andafA"icd -tf4 cry paekmct a carte thq"n here Aay ksdet0tkt nietiomied lieeie ee snidy
abed wIsan to ft .icompany wide, tae pmod 6r odur2 lrip m mm al ;you may a cctrmncifi g btlIsmstion
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support avtitede f., a St.ss pin minute, tAceder mr is five to 12 months. over good for kNed fim. Ate ft raw 12 monde, the Aanele,tbed stance wr
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mein in blephowtol rkages. Access may be knifed, esped* dung tines of peak tape Vial-up maters may be
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cataporarho AMIIML PLIICENTAOE RATES
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6. Anaanamord r Loa, Gverfiat snrl Il.rmat Prymsr Fess.
Your s::se
w be aaeaaad more tan two ai ih fees
listed tat amt Bring cryrobebg pMOd. Under the
terms d your osrorunat "resonant, vse rasarvs the
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Intl whet wsiving or sageo the same or similar
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6. Yam A"aarat. If a metWdtp in
appaa qua The Inant of pan e"mwwm, qua = tm 30
day. from the don sib stasmrm qua to you to
avoid paying the fee or to Irsa ouch Ise credited to you
iff you Cstr:N you account. E skhg this period, you may
= fro tZwu? vddao s roving or Pay sib
notify u by camp ear Cushourvftter Ndwki
m e Department
and PaY Maw Bahama' in L (exdudrq de
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tadl You pay an sonars tqu owe lie kdudng wry
a ?sialeotisesauaso?na?d, titsTCe dengea, P"w
advance fees and any otlrr Ines apaiuiad tVo?
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or cad w accost cannot be
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BIWNG RIGHTS SUMMARY
IM Cain Of Eumm Or Quostiors Abort Your Bic)
T Yoar tticc Your be h wrorhg, or B you had mom
kdonn"afim on s Vnuaeniora or M, rhe to m ten a
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tot bo m wklch the erhx s P'b., appsmed. Yost un
1p'Jmaaorlr cu miner RNatlelle ralnaer. but daft so wt not
bin tmaatltirw its. M your knm, give u de idbwing
amour of Meter name and "twain raatuer, tW dots des
and an ezpenadon iit?podMe, of wwAayy on o1 .d error
an error, or If you eyed more inbeswibn breve dam h
Its, itch too am Issues about. Yqu do not how to of V
amore in Rcesdm vWS Z-8
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m ste obpamd to pay in of yoIs tM , "°ro
min uaial `am min modgate You question. we corn,
amour you Qrsathn, or Take cry sNm to cream the
t,'t Special Ruln for Cmdt Cod Purchases
B You how a Problem wth 1W guilty of progen. V V w
ti Riled win Ituchaad soda a Civet cad yqu
gad failA m &vW.1h the p.M_ with ire anow
amore duedes an the hv" the right ram to pay ft moronism
PropanV w services. You hove this
profession conyy who MPurduaaqke was rnaone than
wdtiWn
and t parches vres madd err Your cum atom or
100 mia at yqm thaft a
? the If vft Vo t vve 0 o or
advsnt ourefor ?dhe Apntpan or If "YmaWted sou the
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saMces, M Durdasaes
s
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t tiles nu -AP/Y b cousins nor-u.W cord xcdwrs
t Does mat apply to &%hoa non meft' cam, accounts
Capital 0- -VP- information vrebrtn 1rnN -pialre.mn. privacy protection: sons nor
CapitN Om h a bdwry ;;;weed service mark of Capital
Capons ( CorporaWn. Al 140 --d. -2003
OILOLBAK
remina
bray 0 nt en
00 pp men ?°PP arced w-r P+Ynerm h cmc1rej to n Dort fete by 3 p. recei Pa acs =t=- porgan of this sutamem and umyour eMek I. rW eMoaW
Yrnashn adaressad to atx WasNrpton mcWM^vb m atldrasad or (ieorgh psocesdng Isms m W receivetl an a bmdress day
vary detdo Ir Peyunera received by as n arty otlyr bcariwn u in anther foahh ayy not W cm6ley 1W ?Y bV 3:00 p.m. PT. Pkae snow o son five f61 haMryu de ern
I delays. Plesae do n. ail wpla tlla, cams d"y we ecdve them. Our b-d yas days am MandeY Ya Powal
Wnk accoam (or Uhe amout of tae .aleck Tlie °m' w? Pr°P-iq Y°an P°VUO-nt. W W- nerd w a dyck(p, you eutlndzo u to meka a are-tbm daatmmdcota?hy{erudd0epryy'r
eWOrize ca to make a .ha °?-azor°^ aPPg-a to NI dwrJa mcN
ape against your bank accauast uirnp Um dhsck, a paper diver w ? rtaa. ?p ?e ever if sant by wmeom Na. If qua earryt Pmcesa dy varhabr, you
Now wf h
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?r0
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Gaol LG• VISA ACCOUNT
4121-7415-8622-1272
Account Stwtn iq
Previous Balance $1
727
45
Payment; Credits and Adjustments ,
.
00
S
Transactions .
f35
D0
Finance Charges .
$18.25
New Balance
Minimum Amount Due $1,780.70
Payment Due Date $1,780.70
March 15, 2004
Total Credit Line
Total Available Credit
Credit Line for cash $ 00
Available Credit for C
h $1,250
as $ 00
At your service
T. aB Ceanomer R46tiom or to reports 1o 1 or nolen card
1-800-903-3637
Sew P.7mems t' Sved inquiries to:
Ann: Ranitunce p,_ --g
CPtd Oeee Services Capital One Scvion
P.O. Box 85147 P.O. Boa $5015
Richmond, VA 23276 Ridunond, VA 23255-5015
rtantAccount Infonnstion
This February Capital One is in the movies! Watch Ebert &
Boeper to see their top movie picks and visit
EbertandRoeper.rv to are how you ran get imolacd and learn
more about Roger Ebert's 6th Annual Overlooked Film
Festival.
Payments, Credits and Adiustments
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JAN 16 - FEB 15, 2o04
Page 1 of 1
Terns
1 15 FEB PAST DUE FEE
$35.00
Your Until then, to dose your amount has been received. Your account will be dosed when it reaches a $0 balance.
41st still continue to receive statements and must continue to make payments. All terms and
conditions of the account will apply while a balance remains Please remember to art your cards and cancel all
charges which automatically bill to your account.
You were awed a pant due fee of $35.00 on 02/15/2004 because your minimum payment was not
received by the dux date of 02/14/2004. 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
f P/mtera rruerrrridrror in fpmrranr in•Jirnw
tia
a
tlirla, Peies&
C
g
rdr
* dart a
?GE
CASH 53,623.24
5113.02 .03321%F
u'12 816.71
.043B99bF 16
02%
.
$1.54
ANNUAL PERCENTAGE RATE applied this period
12.38%
/1, ? PLEASE RETURN PORTION BELOW WITH PAYMENT.
Capitaloa 0000000 0 4121741586221272 15 1780700045001780705
New Bal- $1780.70 P^e1p a r ""l a•+ tvAeab&rwNaFai
Minimum Amount Due $179070 Payment Due Date March 15, 2004 S Apr e
Total eadosed $ aq scar ZIP
Account Number. 4121-7415-8622-1272 Home Rnnr N eara P
&ud Aeldme
#9004642282587969# MAIL ID NUMBER
?- CAROLINE M DARHOWER
Capital One Bank
P.O. Box 85147 r- 371 ARMY HERITAGE DR
?e?nn???rtt?ten?t?t?s?
Richmond, VA A 23276 -?? APT 19
CARLISLE PA 17013-7307
Pleare writryrotr armunf nsmeber on yroty rJ?} or mo a? n,a?
u}' poyab/r ro Gpitd pnr Ban.f and m¢il in t!x rnrlorrd rnvdapc
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CAROLINE M DARHOWER
371 ARMY HERBAGE DR
I ITED
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ptcpkPC c ada)y rtdponabla fart* OfFK &M IS nd a8iaed wkh Capdal Dr C p M One does not prllli andoee
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abed YOMW b gar Y rife prtwidet ft •^OK N dada leseryad. 6y duci - lar r Sts o8et »u may bar MMMMIC96V idonrm8a,
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O 20M Cepilel Ore Senicn, ilia. CVW One is a kW* registered tevice mark N 4, mm ma
I •. saw roar. To! ter hew a miniature grate pedod of
25 da» widaot firratnce tartge m raw Prrdrases, raw
Dram varrlarc, rrvlr r4edai purchaass and rsw other
charges it accordance, mi r? um 'NEW aanrce', in
in time for it to be c?radeeed by by VC for raymaaa prpyy.
and d•rep tint. Them b ro ? rod
momeim period on cob ad-lices
end •Pedr trarulen Ina ddon arm grace period
m •nY lrawmion if you do not pay the tope 'New
balance.'
b Finance Oren Trarenfae w ddb arc not
subjea to
am the date mgram podod am esssseed finance cleage 1)
here the date the transaction m 2) from the data the
Brat eaivrar processed to V•ra Account or 3) from the
day of the orrranmt Dillyvg ps1p? AddlipWl
if you did not pay the 'N•w ffr•rmce' hoot me Y•
Ming Palled in fee, lnranmce Charges coskse to a?txru, to
belance re unpaid This ma s you my " owe arch. Wild e A. tug.
ths!
You pay the afew Now B-Le ce Indicated On the from of if
Your statement by the row statement dosing date, br ad
rot do es for the PrMar month. Lkww finance durgm
}
eceuq.
C. eakm:ra.m arc stilledFkuwe ro grtluss•. Far old. Nam _- . ••PnarnT ill Yam A
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iuel Arrnq'dr.rye?issrjtlng jm= e yr application ?fydwrr
amuse kGre the 80.50 nniamun Intl tAe dflemr,ce rail be
alas to de prartlass of
ccorca.
t d. °1 0 ? nee =I! = We mmne he
epee for any given
m aI-
err balance
rte of e•dr
a far each
total
u du
vary me Y sodomy itrcmm m dsetaaae bad de
anted hrdrm, =-d. err TAS Wag Sbaet ?.nta( pks
tle m,npln pne12doaed to you, chess drarges
rlih. amt 4Y of Your burp pedod
eacteah a monM.
d. A-momma d Lase, Ovarbm end Reamed Psym rd Pam.
Your account vnY be aenssed no eons thin Two . tls fesa
listed Ifm dot Collar dueling any burp period herder the
?ns m root ta r -, we move the dghi to am= any feel .4shou pd- rotiac•tien to
?yywioun at I.:
oa our dlihl to .es.. the same or Ainnlar
5. a7RmawlnYv Aeorsti, If • mwruerrap in
ppeam on to front of pea statoneem, You hires 3o
d.» from the time this surnames was anrkd to you ta
avoid peykp do fee . to haw such Ise t mdW ol You
If YOU Cereal yOlr avemart. DAIng 11112 padmd. you mYO
cm*m 10 mar embsrahip L& T your account uhhpur I m, year m psix me
m
notify u by calling oar Qmamoow Re *m Department,
and paynslYmipw New Balance- in sal (excluding the
prMmss_ ?M-0sY Plod
8. N Yam Class Y?Cme
»ur arises by ,L am (==Z=
mrem. You must dsatroy You waft canK.) and
aoc.amt access decks. carnal ON pneadndead billing.
ad ease Imp Yotr account. N you tb not armtd
Pmeulydzedd Ebitmp sneeeaments, em wW consider
receipt of a charge Year audtodzetlem ro capem yvu
ta a You Pay.0 area tss you owes us including, na be aoaed
transactio s You hew: rdtodzed, irrce ys
are fees, oweesit rtes, rekrod peYr we krss, ter
ad-nCs fees and any oiler few aaeemed to Y•,e
account. You am msporoibie for thass amount. wfetlmer
== m your axcous at the riveyom+ mtaest to
TeUS Of May am incurred srwspmcec'•
». mil m n ro does the a:cwt Th12 may merit it
durgss t1Ppeedcmg or Year account ahal rou tort
3857M
01L0LBAK
?. S. RM O•lY railer. lat•ararg thaw f4r•lssssl.
S. Mce Charge Is
of each team mletlplykp de dry
balance of e aaerrscm .1 Call »ur eraccount, a and and b.4. tern
by adwn, theprspecial transfer, •POdd pr• been
corresponding dry periodic and o each fns bean
pnwdoWy, delddiadasatl to you A At t the and of f semhm d
,he baling pedod, me apply the dry pedoac rem for sad
ssenam o YS. scan m the rimes Mlerce of each
'-ft. Of Tear a de anal oe rite duitp period, we add Lip
oldie #-- ?tiry ukdaiow ro arrive atypK
rcahn imrn each r9• satin a°e1 s to M d" at the we total add to der
finance, charge for your ball ac
•c ccou t, l the ddy b balance for each balance forte awn segment VC, eras. m Cake de bail=ing
ea and add d e > charge cWtudesed on
Ind. any pedo
days balance for tea aeglrws. we than subtract
a° QnywO'
P•Nnenu to mean posted as of the day thin arc aBOted
to tM apP .. This ghee u ife, aspeate dairy balance
for eadm saenmem . you +rzvus. ,how s-1, It You paid dtp
New Brace a on you PwAoma statement in kill for
if your new balance ce rrss Is. Of • treat •,nomeml, few
tranucterm vW*h Pea ta Your purchase Ce •P•dr
purchase -OW-ents 0. not added to he daily bala.. age dry belanmoe by adding r the dailye
=
the topstlrer rd avianp the sure by to ember of
the da» in the mrmm bilrmg cycn. To alNme you loud
daily a pedoac r delve. nwatiply yo. avsrcps drof %"b
alance de
deny .a .rd Dy the nanwr 12 drbus p
rounding Y them period. NO to m a dr bare,
rnaance charge acwm meeeralnlattmn and Memeam.m of
b. If the cede Z . N sppamw the from . d s
a•tenem
text to 'Brartce Rae gppked To.' w,e moldpY the
V --W- Fh. t N h hio already been cIt-d. For eta
If YOU oudedred a Pullss few • merchant and wed'
eraUr-Count has d a been Clos hem do nem taw be steer your raopara,
err +rnaaa of ??' r eCCO r, ? to
and you tea be = Wa he added to you account.
fe pe»n.m. n there 12,
tar m arshrypW, a, ou . 1M tee Ma continue - ' by I.. until the
account bears. 00as beer pfd in-bU as defined above.
7. Using Your Aemue.Yaa Card or aceoud Cannot be
used in bn Mm any iaemet pampyrrg
BIWNO RIOIfTSrcSUMMARY IM Cass Oil Fim Or ?e Abet You Big)
m >
VOW bar 12 anvil, . N you need mom
rasa lion Or bill, write to a on a
agmmte ar= as Soon as Pusab12 at ft address b
Ira fri shover on the leas of this at t;= mt. We mum
you no lame darn 80 tyy afTer we aaM you de
Am bar m rratdr the en. err ptoD)sm appmred. Yalu can
.are our Cnssom. Rse,ders m•eb•r, INA doing p Ma not
m- you rights. In you Ism., ghm us the ,meow ng
kbm Of ulna and atxavm number, the dollar
amount
rho suspected .ror. ¦ dmcdpdm of the .rote
and an exploration, if possible, avntry you below Mess )a
0o error . if You nand mare krfonrration, a description of
d
onlouint in harem You am usurc about. You tb rem hart to y any
an qumajon vWft we a
=111 i m
ge pay Tfe pram of yvr tM am mt
in grres6 Wale m imwillete I- oestlon, m carrot
aimYdelingmsss take my action to celem the
t,t SPedr fide ror Cn dt r-d Red..
If you lute • Preblae wt he quality of property.
he Tye d 0s you purdu•ad rddr a crest tam and yo
ed In u
good fNM m acnem tlr pcob12m whh tle
martens. You may low the rips rot to Pay the r.mek;eg
Me" du an the p1q y . asnvfas. You lure this
pmtembn orby when dr PudYy v{pe rep mom thin
"I, t0oand tfiamesa -t ot v. p y-ea Buda la your hone sue .
wdrm 1sWp .seem. g, ter owes ere
a ss for w if vve marled you the
Pf•p.,, C, ssnvices, all purchases
'Pla.m ,emamber to`.Igmai of purchase.)
t tkus not •AO/y m c.naamer noo-omo?t card accounts
t Don ror apply m bcrMn nor votes` card acrovns
vebaito vvvvw. infonnalian privacy protection: see our
Caphel One fara .coma
Oro Ponsnrtl11 Y mOaTared service mark of Capital
Call. Ore rporatiaw Ali crass moved. • 2003
emimarce m
°? , a? Nnant tea be .rested to your account as of the day mal- n, pmvi0ed you sad Me pomperilOn of this Inamo ent and 7=k kr 1M endwed
by 3 Yoe
P.m
P.
authoriz peYmrs 12 roahwd in our pnocessi,p colt. D 3
. ET. Paymerro atlaeassd to or Washinapn +ddce•aed to our vcigmhda . Goagia Pcocssairp tamer muread m a Drsrrees day
drive ymerma rxrved are
u . •rrY
ye mar hocatim . mpr r emery vet be cratitetl tlr arse yy?vw ryeedw Mme. Our bdnnesa pre at lees five 151 brraNmess der for
Iafde». Aram do rot use wp1m m?e' » em Mwda » Portal
beak etxxu,n for the em.nt of the dvxk. 7"Fis a c. d1pA P?Oi?r P°Ynre^t. When YoU aeM u a decklN. you eutledze u 1o make setae-time demryorie ierdehhy(mmp
e u to make a tits uhedzadm spplss to ea drecla chaired dudrq ile Wlig eyrie ewes if errs y Someone rte. If tea cervmot Process the tnneter, your
? •garrt you Mntc aeeomat rarvg the dick, • paper dmh . odor 71rm.
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VERIFICATION
The undersigned does hereby verify subject to the penr
of 18 P C.S 4904 relating
to unworn falsifications to authorities, that he/she is (NAME)
of plaintiff herein, that
4
--' E) ?- (COMPANY)
he/she is duly authorized to make this verification, and that the facts set forth in the foregoing Complaint
are true and correct to the best of his/her knowledge, information and belief.
tWUNATURE)
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Jeff Lawrence
Certified Legal Intern
Nichole M. Walters, Esq.
ID#84478
The Elder Law and Consumer Protection Clinic
The Dickinson School of Law
The Pennsylvania State University
45 North Pitt Street
Carlisle, PA 17013
717-240-5152
IN THE COURT OF COMMON PLEAS,
CUMBERLAND COUNTY
Capitol One Bank
Plaintiff
NO. 07-997
V.
Caroline Darhower
Defendant
CIVIL ACTION - LAW
DEFENDANTS CAROLINE DARHOWER'S PRELIMINARY OBJECTION TO
PLAINTIFF'S COMPLAINT PURSUANT TO PA R.C.P. 41028(a)(3).
Defendant, Caroline Darhower, by and through the counsel of the Elder Law and
Consumer Protection Clinic of the Pennsylvania State University, Dickinson School of
Law, files the following preliminary objection to Plaintiff's Complaint. In support
thereof, Defendants avers as follows:
1. On February 22, 2007, Plaintiff initiated this instant action by filing a
Complaint alleging that Defendant failed to pay the balance of a Capitol
One Bank credit card account.
2. Pa. R.C.P. §1028(a)(3) states that preliminary objections maybe filed by
any party to any pleading and may include the objection of insufficient
specificity in a pleading.
3. Pursuant to Pennsylvania Rules of Civil Procedure §1019(f), averments of
time, place and special damage shall be specifically stated.
4. Plaintiff's complaint failed to allege the specific date of the Defendant's
last purchase using the Capitol One Bank credit card with the account
number 4121741586221272.
5. Plaintiff's complaint did not allege the specific date on which the
Defendant made the last payment to Capitol One Bank credit card with the
account number 4121741586221272.
6. Without the specific dates of the Defendant's last purchase using the
Capitol One Bank credit card or the Defendant's last payment to the
Capitol One bank credit card with the account number
4121741586221272, Defendant does not have sufficient information to
answer the complaint, as Defendant may have a statute of limitations
claim.
WHEREFORE, Defendants request that this Court dismiss Plaintiff's complaint for
failure to plead with specificity pursuant to Pa. R.C.P. § 1028(a)(3) or, in the alternative,
require Plaintiff to amend its complaint to comply with Pa.R.C.P. 1028(a)(3).
Jeff L
,OATMY
Certified Legal Intern
/Yl vr1?.?.e, Wcc?tc?.
Mchole M. Walters, Esq.
Supervising Attorney
ID# 84478
Elder Law Clinic
The Dickinson School of Law
The Pennsylvania State University
150 South College St.
Carlisle, PA 17013-2899
(717) 240-5152
VERIFICATION
I verify that the statements made in Defendant Caroline Darhower's Preliminary
Objection to Plaintiff's Complaint are true and correct to the best of my personal
knowledge, information and belief. I understand that false statements herein are made
subject to the penalties of 18 Pa. C.S.A. §4904, relating to unsworn falsification to
authorities.
C 00 Jx) G?,?r?,.,
Date: April 2, 2007
Caroline Darhower
IN THE COURT OF COMMON PLEAS,
CUMBERLAND COUNTY
Caroline Darhower
Plaintiff
V.
Capitol One Bank
Defendants
NO. 07-997
CIVIL ACTION - LAW
CERTIFICATE OF SERVICE
I hereby certify that on April 2, 2007, I served the foregoing Preliminary Objection, by
placing true and correct copies of the same via First Class Mail, postage prepaid,
addressed as follows:
James C. Warmbrodt, 42524
Weltman, Weinberg & Reis Co., L.P.A.
436 Seventh Avenue, Suite 2718
Pittsburg, Pennsylvania 15219
WCA a,ate.
Nichole M. Walters
Supervising Attorney
Elder Law Clinic
The Dickinson School of Law
The Pennsylvania State University
150 South College St.
Carlisle, PA 17013-2899
(717) 240-5152
Dated: q /,a
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK
Plaintiff
VS.
CAROLINE M DARHOWER
Defendant
No. 07-997 CIVIL TERM
AMENDED COMPLAINT IN CIVIL ACTION
FILED ON BEHALF OF
Plaintiff
COUNSEL OF RECORD OF
THIS PARTY:
James C. Warmbrodt
PA I.D #42524
WELTMAN, WEINBERG & REIS CO., L.P.A.
2718 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR#05701486
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK
Plaintiff
VS. Civil Action No. 07-997 CIVIL TERM
CAROLINE M DARHOWER
Defendant
AMENDED COMPLAINT IN CIVIL ACTION AND NOTICE TO DEFEND
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 an 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.
LAWYER REFERRAL SERVICE
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
(717) 249-3166
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CUSTOMER AGREEMENT
JelcDme to Capital One.® We are pleased to open your credit card account. This
,greement contains information about your account Please read it and keep it for your
:cords. In this Agreement the words 'you: 'your and yours' refer to each person who
igned the application and to anyone else who uses the account in any way. Each of you
; individually and join* obligated under this Agreement. The words 'we," 'us" and 'our
mean Capital One Bank and its successors or assigns. We can delay enforcing our rights
rider this Agreement without losing them.
Ising Your Account You can make purchases and obtain cash advances (it we have
)Id you that cash advances are an option for your accanQ by using your card. account
umber, and any account access decks (ihduding Purchase Checks, Cormierim
:hecks, Special Transfer Checks and other sunder decks) that we may send b you.
Men we provide you with account access dhecim, we will tell you whether they will be
vated as purchases, cash advances, or special transfers. Unless we tell you otherwise,
:onvanience Checks will always be treated as cash advances.
'our card or account cannot be used in connection with any Internet or illegal gambling
ansactions. Your card and account may only be used for valid and lawful purposes. If
ou use, or allow someone else to use, the card or account for any impermissible
, urpose, you will be responsible for such use and may be required to reimburse us and
AasterCard International Incorporated or Visa USA, Inc., as applicable, for all amounts or
xpenses we or they pay as ti result of such imhpemiissnble use-
, Du agree that we are not responsible lt anyone refuses to honor you account If you do
,ot use your account, you may cancel it by caring our Customer Relations department
nd destroying your card(s) and account access checks within 30 days after you receive
oem
:ash Equivalent Transactions. If cash advances are an option for your account, you
an use your account to purchase items that are directly convertible to cash. These cash
:quivalent transactions will be treated as cash advances and will be billed to the rash
idvance segment of your account Cash equivalent tamsaclions include the purchase of
vice transfer money orders, bets, lottery fidkefs, casino gaming chips, and other similar
uoducis or services.
,our Credit Limit You were told your credit limit when you opened your account You
ilso may have different credit fibs that apply to dilferert segments of your account
such as purchases, cash advances, and special transfers). These kilt fimils will be
ientified on your periodic statement You agree b make purchases or obtain cash
advances only up to the relevant credit limit We may increase or decrease your credit
Imits at any time, may limit the amount that is available for cash advances, or may
xdude cash advances entirely from your account We may honor transactions in excess
of your credit firnk even 't those transactions result in an over" fee, and those
ransactions and fees will be covered by this Agreement.
Aaking Payments. You promise to pay us all amounts due resulting from the use of your
ic=nt, including any finance changes and other charges due under the terms of this
ugreernent Payments must be made in U.S. dollars. Payments made by a negotiable
nstrument such as a check or a money order must be in a form acceptable to us and be
Irawn on a U.S. financial institution. We may allocate payments among the various
:egments of your account in any way we detemtne.
'ou must pay at least the minimum amount due by the date requested on your statement
o avoid a late payment fee. However, you may pay more than the minimum payment or
ey the balance in full. In any case, finance charges will continue to be assessed during
41fing periods that you carry a balance regardless of whether or not your statement
bows a minimum payment due.
Ye can accept late payments or partial payments or decks and money orders marked
payment in full' or other similar language without losing any of our rights under this
kgreement, including our right to receive payment in full.
)eriodic Statement Each month you have a balance in your account we will send you
i statement showing all transactions billed to your account during the 1Wng period. The
,ilfing period is the time from one statement dosing date through and Including the next
;tatement closing date. The statement dosing date determines the month of a specific
riling period. For example, your January billing period is the billing period with the
,tatement closing date in January.
'finance Charge Information.
1. Grace Period. You will have a minimum grace period of 25 days without finance
Charge on new purchases, new balance transfers, new special purdases and new other
:harges If you pay your total New Balance as shown on your periods statement in full
ind in fire for it to be credited by your next statement closing date. There is no grace
period on cash advances and special transfers. In addition, if you did not pay the total
Jew Balance from the previous billing statement in full and in dime for it to be credited by
,our next statement dosing date, there is no grace period on any transaction.
3. Accruing Finance Charge. Transactions which are not subject to a grace period are
isessed finance charge as follows:
-Transactions made during the current billing period: from the transaction date.
-Undated transactions and transactions made with account access checks: from the date
he transaction is processed to your account
Transactions made prior to the current billing period: from the first calendar day of the
:urrent billing period.
lddiionaiy, If you did not pay the New Balance from the previous billing period in full,
trance charges continue to accrue to your unpaid balance until the unpaid balance is
raid in full. This means that you may still owe finance charges, even K you pay the entire
VM11 Z-11
To get the daily balance for each segment of your account, we take the
beginig balance for each segment and add any new transactions and any
periods finance charge calculated on the previous day's balance for that
segawt We then subtract any payments or weds posted as of that day that
are allocated to that segment This gives us the separate daily balance for each
segment of your account. However. V you paid the New Balance shown on your
previaa statement in full (or If your New Balance was zero or a credit amount),
new trarwaclions which post to your purchase or special purchase segments are
not added to the daffy balances.
To cakatate your total finance charge, multiply your average daily balance by
the daffy periodic rate and by the number of days in the tiffng period. Due to
mundng an a defy bass. there may be a slight variance between this
raigrfafion and the amount of finance charge actually assessed.
F. Cash Adymm Fee. If a cash advance fee applies to your account you were
pfd the fee when you opened you account. The fee will be charged each time
you obtain a cash advance and wit be added to Be cash advance segment of
your amant and will reduce your available credit. The amount of the cash
advance fee will be added to other finance charges on your periodic statement
for the pwpose of calculating the annual percentage rate disclosed there. This
may cause the annual percentage rate disclosed on your statement to be
greater bran the annual percentage rate that was disclosed to you when you
opened your account
G. Temporary Reduction in Finance Charge. We reserve the right to not assess
any or all fiance charges for arty given bang period.
Other Fees and Charges. The totowixJ fees may be billed to the purchase
segmerd of your accent, unless otherwise specified, in every billing period in
which they apply. late payment fee if we do not receive your payment in time for
it to be crecked by the following statement dosing date; overlimit fee 't your
accord (or any segment of your accounQ goes or stays above any temporarily
or pmnmehty assigned credit limit, even t we approved the oved" amount,
at any fine during the being cycle (regardless of whether you went overlimit as
a result d a transaction, finance charge. or any other fee or charge); returned
died fee, imposed every time a died is retuned to us for any reason, or if we
cannot tenor your account access decks for any reason; and copying charges
for dupicaie copies of transactions or statements unless required for billing
dispute resolution. These fees and charges will not be assessed H your billing
address was in Puerto Rico when your account was opened. The fee and
charge amounts were disclosed to you when you opened your account If any of
these fees or charges are changed subsequent to your account opening, you
w7 be advised of the new amount We reserve the right to waive these fees
without prior notification to you.
Merhbemblp Fee. If your account has a membership fee, it was disclosed to
you when you opened your account The fee will be billed to tfie purchase
segment of you account
Credit Baeau Inlomation. You agree that we may obtain your credit
Information from credit reporting agencies at any lime for the purposes of
monitoring your credit performance. managing your account and considering
you for new otters and programs.
Future Offers. The temps of any future offer win be disclosed to you at the time
the oft is made. If you accept an offer, the berms will become effective
imnedafely unless otherwise specified in the offer.
Default. We may consider you to be in default under this Agreement if (a) you
fail to pay the minimum payment on time, (b) you exceed your credit timl, or (c)
you pay us wilh funds that are returned for any reason. To the extent permitted
by haw, you may also be in default under this Agreement if (1) you violate any of
the other terns of this Agreement or any of the terms of any other agreement
with us or any of our affiliates, or (2) you made any false or misleading
statements on your application, or (3) bankruptcy or other insolvency
proceedW are instituted by you or against you. After you are in default (or
after we give you any nrotice of or right to cure the default N required by law), we
may restrict your account from new transactions, or dose your account and
demand irmiediate payment of the entire olstatding balance. In addition, as a
result of the default, your mnkmum payment may increase without advance
notice.
To the extent permitted by law, you agree to pay all court costs and ccllecffion
expenses incurred by us in the collection of any amount you owe us under this
Agreement. N you default and we refer your account for collection to an attorney
who is not our salaried employee, to the extent permitted by law, you agree to
pay reasonable attorneys' fees. You also agree b pay any costs we may incur
in refrfievfing your cards, including any costs we may incur by having your
account placed on a restricted fist
If You Close Your Account You can request to dose your account by calling
our Cuskimer Relations department You must destroy all cards and account
access checks, cancel all preauthorized billing arrangements, and cease using
your account If you do not cancel preauthorized billing arrangements, we will
consider receipt of a charge your authorization to reopen your account
Additionally, your account will not be dosed until you pay an amounts you owe
us Including: any transactions you have authorized, finance charges, late
Davment fees. overimit fees. returned check fees, cash advance fees and any
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13. Accruing Finance Charge. Transactions which are not subject to a grace period are
es"s-ssed finance charge as follows:
.Transactions made during the current billing period: from the transaction date.
.Undated transactions and transactions made with account access checks: from the data
the transaction is processed to your account
.Transactions made prior to the current billing period: from the first calendar day of the
current billing period.
Additionally, if you did not pay the New Balance from the previous billing. period in full,
finance charges continue to accrue to your unpaid balance until the unpaid balance is
paid in full. This means that you may still owe finance charges, even ti you pay the entire
New Balance indicated on the front of your statement by ft next statement closing date,
but did not do so for the previous month. Unpaid finance charges are added to the
applicable segment of your account
C. Minimum France Charge. For each biting period that your account is subject to a
finance charge, a minimum total finance charge of $0.50 will be Imposed. N the total
finance charge resulting from the application of your periodic rate(s) is less than $050,
we will subtract that amount from the $0.50 minimum and the di ferenee will be billed to
the purchase segment of your account
D. Periodic Rates. We determine the daily periodic rate by dividing the annual percentage
rate by 365 and rounding K to the nearest 1/100,0D01 h of 10'. The rate may be different
for each segment of your account (e.g., cash advance, purchase, special purchase, and
special transfer 9 applicable for your account). You were fold the daily periodic rate(s)
when you opened your account and it appears on your statement
E. Cakwlatng Finance Charge. Finance charge is calculated by multiplying the daily
balance of each segment of your account (e.g., cash advance, purchase, special transfer,
and special purchase) by the corresponding daily periodic rate(s) that has been
previously disclosed to you. At the end of each day dung the bffM period, we apply the
daily periodic rate for each segment of your account to the dally balance of each
segment Then at the end of the billing period, we add up the results of these daily
calculations to arrive at your periodic finance charge for each segment We add up the
results from each segment to arrive at the total periodic finance charge for your account
kgreernent and/or temporarily or permanently suspend your credit privileges. This
icudes, but is not limited tD, situations where you have violated fn's Agreement or where
re have reason to doubt your creditworthiness. Your obligations rider this Agreement
ontinue after your rights to obtain credit have been terminated or suspended. We may
relay in enforcing our rights under this
who is not our salaried employee, to the extent permitted by law, you agree to
pay reasonable atfomeys' fees. You also agree to pay any costs we may incur
in retrieving your cards, including any costs we may incur by having your
account placed on a restricted list
9 You Close Your Account You can request to dose your account by calling
our Customer Relations department You must destroy all cards and account
aceess checks, cancel at preauthDnzed billing arrangements, hind cease USM
your account fl you do rot cancel preauthorized b0lirrg arrangements, we will
consider receipt of a charge your authorization to reopen your account
Additionally, your account will not be dosed unfil you pay all amounts you owe
us ihchrdng: any transactions you have authorized, finance charges. late
paymerd fees, over(umit fees, retumed check fees, cash advance fees and any
other fees assessed to your account You are responsible for these amounts
whelm they appear on your account at the fine you request to dose the
account or they are incurred subsequent to your request to dose the account
This may result in charges appearing on your account after you have requested
the account to be dosed or the reopening of your account ff it has already been
dosed. For example, 'd you authorized a purchase from a merchant and we
receive the transaction from the merchant after your account has been closed,
your amount will be reopened, the amount of the charge will be added to your
account and you will be responsible for payment If there is a membersho fee
for your account the be will continue to be charged, to ft extent permitted by
law, until the account balance has been paid in full as defined above.
If you ward to stop an authorized user's access to your account you must cat
our Customer Relations department and destroy the user's card (If any) and any
account access checks he or she may have. H you are unable to destroy that
person's card and account access checks, and you cat our Customer Relations
department to dose your account your account will be dosed and both you and
the joint cardholder. I any, may apply for a new account If we dose the
accent you and the )Dint cardholder, t any, will still be table, individually and
together, for at amounts charged to your account
If We Cancel Your Account or Suspend Credit Privileges. We may at any
time, wh h or witout cause and with or without advance notice, terminate this
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Capital oW
VISA ACCOUNT
4121-7415-8622-1272
Account Summary
Previous Balance $1,780.70
Payments, Credits and Adjustments $.00
Transactions (35.00
Finance Charges $17.28
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FEB 16 - MAR 15, 2004
Page 1 of 1
Payments, Credits and Adjustments
Transactions
15 MAR PAST DUE FEE
$35.00
New Balance 832.98
$1 Your request to dose your account has been received. Your account will be dosed when it reaches a $0 balance.
Minimum Amount Due ,
832.98
$1 Until then, you will continue to receive statements and must continue to make payments. All terms and
Payment Due Date ,
April 15, 2004 conditions of the account will apply while a balance remains. Please remember to cut your cards and cancel all
charges which automatically bill to your account
Total Credit Line
Total Available Credit $2,500
sA0
You were assessed a past due fee of $35.00 on 03/1512004 because yout.>ninimum payment was not
Credit Line for Cash $1,250 received by the due date of 03/15/2004. To avoid this fee in the fimre, we recommend that you
Available Credit for Cash $.00 allow at least 7 business days for your payment to reach Capital One.
At your service
To caR Customer Rdafmns or to "port a lost or stolen aril:
1-800-903-3637
Said p.7mma to, surd ingtikia ter:
Attn: Remimaa Processing
Capita] One Servirn C Phil One Services
P.O. B- 85147 P.O. Ben 95015
R:c6mond, VA23276 Richmond, VA 23285-5015
Imoortant Account Information
This month you will receive your 2004 Guide To Benefits,
which sets forth all the additional benefits and services you
may be eligible to receive this year. These benefits and servers
supersede any benefits and services provided in your 2003
Guide To Benefits or other additional benefits and services
previously communicated to you. Please read and retain for
your record&
jvl i
F-mance Charges Pkaresa res-si& for important iaforsnatunt
BalmurraG lhr &
f
d ma
P
1
yrli,lte res
PURCHASES 53,67451 .03260% 1L90% $15.83
CASH $11452 .04356% 15.90% 51.45
ANNUAL PERCENTAGE RATE applied this period 12.16%
PLEASE RETURN PORTION BELOW WITH PAYMENT.
czPftwo a 0000000 0 4121741586221272 15 1832980045001832987
Plrm/rint a ml6rt add-and/or r-au lrbmde+ bdoorausd bba w black ki
New Balance $1,832.98
Minimann Amount Diu $1,832.98 S_ Apt- e
Payment Due Date April 15, 2004
Cry Sna ZIP
Total enclosed $ Hom, pnoos Al-W Phma
Account Number. 4121-7415-8622-1272 e
Enna Addsev
#9007642282587966# MAIL ID NUMBER
CAROLINE M DARHOWER
371 ARMY HERITAGE DR
Capital One Bank
P.O. Box 85147 APT 19
Richmond, VA 23276 0 CARLISLE PA 17013-7307 EXHIBIT
1rt1ris d1ttr1t11ttr1t11rr[isrr11tas11rrr11is 111rrr111of 11rIs I Eaam_ uun[roll.111.Its [1.I'Itll.11.14111$1.111111
tt Ctl
Pkare wife your aetoemt number m you db k ar -say order ma&",,hk to Capital One Bank tad mail in the eaclared ea Ape.
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or g-aaee, and is not aAieded affil, any product or service dawn here . Any rrademerial m intoned he art am Solely
owned by the respective malty. Al *ft Reserved. By msporldrg to ft often, you may be mrmeraceeng inici neion
about yourself to the company, that provides this product - for example, that you ear a Capital One cusexter.
TOOPWPC Online: Fret 3 rtantt a are billed at $497 per Mirth; $9.95 per nonli thereateL Offer avaleble to new
did-up subscribers at least 18 yeas at ape and mey not be redeemed with ary oaar offer Oro Subject to change at
any tiros Phone tedadcel support available for $195 per mute.
tAaalealer is free fa 12 0-9,s. Oflar good bir krdted time. After iha fist 12 narltlta, the AcceleaW service vR
mammddy, revert 10 the standard PW*K crane service. Offer subject bi d=W at NOM. Wdh I'mo PC W.
Accelerated, certain Web papa rent and graptda v ill bad faster when corrnpared to sfartdurd dal-up haerret service.
Acted Rastas may vary. PebpleP(0 Oriea Accelerated is a* compat6le with PecospC Wm Ir has 10 Service and
s KWW WffWmA brO mall, PNPWIC Otgne Accelerated is not Cot PW* wth Windom 95 wth E 5.5 SP2
Service rd available in al areas. Access tees, taws, end Other fees ad nstricticcw may appy. Telephone ION darges
may ap* am dm9 tdel Pablo. You we responsible for determining whether a al tone of out wcea numbers will
msu4 in tTtltpltore bill charges. Accese may be roiled, especially dung tines of paele usepe. Ow-up mambas may be
changed at PeoplePCIS dwrdim. CO(Ithu us use subject bi tirrda procetllaes.Al use IS Subject bi PwpWC online's
Wvices Agvisatt and Acceptable the Policy. 56K a the maximum speed of sevice; actual speed may vary.
0 2666 I'm9 C Inc AN WRIT Reserved. PeepleK Once and Its Noll are lmdanarks N PeopiePC in the Us.
and eater aachies.
02066 Capital One Services, Inc. Capital One is a federally registered service mark AN rights reserved.
8
O t
V ?
e ,
r
period" bite. To Obtain der average dauy balance 1. the
bill period rnvered by cilia etatmtart. we take tfa
beY?ng balance of each sepnaa adr elev. add snY new
traraedferr a each 0119-M, antl aubt"ct any paymmes
or oed". fit to code N appease on she hoer of this
umamere nee To"a ce Rate Applied To," w aim
abaraur any unpaid f-- "urge irK*.Md In the bal-
t .it aW - ) This ghea u the IV balance of each
sepnae. Then, we add rq all the rWyy Dalanon for each
ruprhww for the HiOg priori and divide by the total
amber of days in the bikq period. This gives uO
the
3. Anna 60, deity balance of reach segmem.
eats- Rita IAPRI.
a. The term 'the (roAr Percarttage fine" may appear ere
APR' m t Bas stnemat.
b. the esds P Prim), ), L (3+no. LIBM,
paper C IC ft to
D a
D . star S Iii Minn.) apnea" on he he ft. or
f
teas nafaat me4 n To to the period" R , he period"
Team ry rn edInllres ANNUAL PERCENTAGE RATIndices, a found in d TIM Wag Sraet or decaliter based
on to aimed
JoatW, Plot The Margin preAmety disclosed u you
Thhem frail bar flecitw en der first day 11 vat
HIND perod tmvMOd by yaw pedodc natelneM ending
the momhs Jewry, April. July ahd October.
c. If the -ode D IPlk- F Rota LIBORI a G (3-mo.
LIBOR ROPricad Y) mpesthe irora of your
stater t nett to tha paeode r tercel, the Pahl ern
and tomespa ittif Af-tAL PERCENfAOE RATES may
wry mainly and may Incra e, W dmrns based on tha
stead irhdces, as band N he Was Stmer Jpaad, pka
the reargin Pr0vi00alY dsclosed to yen. These durhgs
be eft-Mm on the first day of your b=q; period
will each "Fe"
4. Ae-easam t f We, rr Sandt and 1lararned Pai mat Fen.
your atsoua rte be Trimmed ne mom than rw of the ten
ist
led here itart owe d-it* any biNng period. Ureter
the
toms f yam serener apmatem, vhe reaerw tie right to
wind d not to aces ants' fees widen prior notlficatm ro
wdaut vnivinp Ou tl/tt ro assess the same or a miler
at a ear time.
5. Yar A round. N a membership fee
aquas m the item f nit sutamaa, you haw 30
days tram the data this a"temert Sus mailed ta you to
avmtd peVnV dr fee er m low etch tea cradrw to ya
If you -abed Wet act-K. Dubq this period, loo May
antkne to t- yaw ascent esthete having to pry the
mmdere ip be. To each Vert miceum. ya Rest
notify u by calling Our Cuearer Relatiae thpannnss
and pry New Belerce" N lea (excluding the
nhembe 600 prior 10 tr end of the W nyday per
8. R Ym Case Yeor AMMOL You can mliumn ro Comm
vyaasr acous by "slip err CM-W Reietlon
Daperrmem. Vm moat destroy Yam credit card(.) all
-e--!m deco. rrW all pmaulorized billing.
aa Yoh adxmhat. R you w rho nrnW
a, w WII erider
proeuhorizedhp amexa=.:==
recelp of a dufga year uon -a :c. Addtlaa o yaw offs mdaa P-' Y all snoats you ow w Including: charns,
vawYOU haw authorized, America a charges, Sam
due eras, -*"h inn, -'= pymera ears, cash
advartca foss and ay slur en aaeeaad to Your
accaat. you am reapmalde for char arrests whether
they ageer on you aocant at the tim you request to
dos Iha accou t OF they am Norved subsequent to
your request to dos The account. This may renal in
your mean if h has already been closed for -.Pp
e,
N you aWadzed a puniase from a Merchant and w
mWw to taraction hoer the mercnam after your
account hall been closed, your acce, vrN be Leopard,
the engaa f Vr clrrp wi be added to your accaaa,
and you rte be net for peymaM. If te2 is a
membership tea for you aawt, tln ere WY artirens
to be charged, to the ease permitted by law, until the
weed balahes has been paid in full n defined above.
7, Write Year Aoemet.ycrr od or a-uham carnet be
Used I. contraction wish any incerrer gambling
traimacIl.-
BILLING RIONTS SUMMARY
Inn Cam Of Enos Or GUseierr ALa0. Your Bich
If You ft* your bill 'e wrong, or N you rued Moro
mfor n tti- - a lrareactim or bar, -1m to us on
a
separate Nun as woo n poseEle at the address tar
NOWda shown m the from of this atnanem. we mum
hear from You m Inn Than BO days after w m7 you the
firm teal m With the error a pmhiem appeared. Ym urn
ug our Cu5Xmmer Raistiore mmhar, but doing m WIT not
preserve Vote rigitt. In Vour letter. give a the following
infsrroatNrc y?ff name eel arxoua amber, the dollar
of On sUspected error, a demdptim of the error
and en mplaradm, it nos .. 0, of why you befhew them is
ertor, er If you need more informs on, a description of
the hem you am hates about. You do not taw to pay ay
amain in qu::cn While w am inwnigatinP It, but you
are eel oblgned to easy the pane of you bb at that am e
in quedm. White em Nvempte your quesom, rte cannot
report you s dNNpart or take any anion to collect the
amour you question.
t.t Spatial Rte For Cmdt Card Pucates
N you haw a problem with"Wanly of property er
SOrViCas
haw that you purchased Wgt a credit card and you
tried in good high so erav tha problem Wm the
nemlrm, you may haw the dgit not to pay tha remaining
amain doe m ft pmpeny or services. You haw die
protection Ord en the Putcuw pin Sus more than
$50.00 and t9:W
purchase we Resells in your here nave or
widen 100 male of Vmr malitg adtlmm. (if w own or
mperne the Meraet, er If we mailed you the
sdwrtiaanam for to property o -Aces. NI p rdtaas
;===W f amain of Purchase.)
d arreeparhdernce.
t Dons of eA* h -omaahar - - malif Bard acautts
t Does rot sppy m bitshess ton-osC/r cad acoanrs
Capful One stpporm Information privacy protection: sm err
rMmite at wwrr.uphNtne.cwn.
Capita One is a federally registered service mad of Capital
One Fall Corporation. All dghs neserwd. 0 2003
Capital one
OILGLBAK
T a. riraee Permed. You wfii he" a mktimun grace Period of
25 days m new prcatn, row
haisrtea '=== pur"fasas erd new otlhe
cnarps N yen pry yaw tatal 'New Balarnce', N
and i for it to be mid ed?? # wows below,
by Yom rata staenaa
doairq Them fa m gran Period m cash eMcn
end spxJal lmareem. N addition, them is a grace Period
on any traruacdon if you doe Pay the total 'New
DNace."
b. AsauNp Fb- Charge. Tra recd- which as not
abjmt to • pmca period ere waned finance carpe 1)
iron the date of the tawederh or 2) tram the data the
transaction is pmesaed to vor Account or 3) from the
fire Warder day of the erunart billing period AddtiouNy,
it PW0v1oWd Payy;* N: Bslehca' Imm the p-mua, in full,
changes continue to accnae to
your unpaid belatce ual the unpaid balancer is paid in fuel.
The means 11x1 you mry ale owe irate chnpea, auto if
yen pay the palm eew ealarhu Ndcned m tlu hoN of
your statement by the nerd statement dowtp data, but rid
===. do m for the previos anse. Unpaid fi- ch.,
t c. -;= o6Nfiq pre .
your sCCOma ie able-t to a fntarnoe charge a Minimum
teal A$IANCE f71ARGE of $0.50 We be "I;. d If The
rural t- dhagp rewhing boa the application of
pariodk =,) is lea tan lfl 50, we wW a6lract that
anent e SO So minNeen and rite ditletahce Wu be
billed b On purchase aepna? f you account.
t d. TenhVaay RedroM In Fihatee Orge. We reserve The
rift to rhea ashes dry or all finance dheryn air any given
2. A-lip. ? Dally Bad- (khokrd?4 New P rdeaal.
a. Fuverhoe charge Is calculated by multiplying the dally
bdace of each millnert of votr ao:mun te.a. can
advecs. purchase, spatial treater, and Special pnadusl
by the com-pohdrtp daily padodic rata[.) dart Indybeen
pm4ously declosed to Vm At #0 end of each 1T a bl&V period, w apply to daily periodic me aad?i
tepaat of you a"ataa to The daily balance of each
eapnant. Then at the end of The bOV pat m add rip
the real" of tlhes diy Wterstior riw n yea
pedodc fitters! ch de for neri ahprh to 0 u "'We adtl op the
results from each aeglMra to ardor n to Tota periods
flrhrce .,ge for yaw arenas. To gat the daily balance
for each be met of your arcane, w take ft beginning
pate each -game and add any new marmidione
and a y, tN Charge Mutated a the peviae
d.)(. I. aeonant. We than sinless ay
peyhthas a oaths posed a of that day to tiro aNoeatetl
to thn SM ace. This III- Us the aeprau dally balance
thaaweaBalahe talawo m ease. Ibwe- N yen pad The
yaw pmvias sutanst N kll (or
if your tow balsrhu Sun zero a e credit amout), tow
trarwetlora which puts m your purchase er sPeeial
padre spites am rot added to Th. daily babunces. We
the a-mge bell arceas Wgellmr and daily dnbalance p the m air adding an " the daily
naaa of
iha days in the awhamybeitl cycle. To calculate you met
periafic eras AiN by the a= ?er df N ? tg the
efrhg
day V. N the
period. Due fo rmnatdirq m a dWy bow, the" my be a
digit -Amm bem - Ws W Waion and tha amainn f
finance charrge actually assesed.
b. If:ato "R code Z or NRats Applied apes" on tTheo, f em
nets elat"e " prepw ord"this m Vtheenan
Irhptrtart Nfier. You pymsur vre ha credited ro your accohnt s of tha Mte w rmalw h, providM yen std pre Dorton prom of tits a"tames and r cluck in tlu erwiosd
iturce envekpe, erd Your pyehent is reWVed Nour phocesktp tamer by 3 p.m. Psprharnf eddreasetl ro err Virginia a a ntcesai urea hm? De roWwd m a ddres Bey
bV 300pm. ET. Pa OaorP p n0
Yrrharhta adnneM ro mum Waseanpm proosalrhp timer must ce reWwd m a buaireq tlsy Dy 3:00 p.m. PT. Pleaea eitow a least flw (51 beteltes days br portal
W__'. Paymera revived by Us n dry stem louder er N reeler tom may not be credited Ute erne daY w recaive clam. Our busmen days am wfad.y thmgih Saturday, eroiudnp
hdidaya. peas do oat ex n paper dpa, ate. when pmpnNp you peymem. When yam send a • deckl.), you aedrrize Us to make a oro-?inm electronic treater de611 from your
Wok arxoup br the ammut of to tack. T'iie autgdzatm applis to ell drelu mWwd ddastmnpp tr Hip cyder awn ii seer by comeore Ns. 11 w uhsot props to trauter, you
alerts Us to make a darya eWku1 your berhk accoesn narhp tr tleck, a paper tl"h a pharham.
•
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Capitalow
Account S
Previous Balance $1,727.45
Payments, Credits and Adjustments $.00
Transactions $35.00
Finance Charges $18.25
New Balance $1,780.70
Minimum Amount Due $1,780.70
Payment Due Date March 15, 2004
Total Credit Line $2,500
Total Available Credit $.00
Credit Line for Cash $1,250
Available Credit for Cash $.00
At your service
To call Cwtomer Relations or to report a lost of stolen aril
1-800-903-3637
Send payments to: Send inquitia to:
Arm: Remittance Prooening
Capital One Servi- Gpital Oee Services
P.O. Boa 85147 P.O. Box 85015
Richmond, VA 21276 Rkhroond, VA 23285-5015
Inmortant Account Information
This February Capital One is in the movies! Watch Ebert &
Roeper to see their top movie picks and visit
EbertandRoeper.rv to see how you can get involved and learn
more about Roger Ebert's 6th Annual Overlooked Film
Fes6v21.
009
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VISA ACCOUNT
4121-7415-8622-1272
JAN 16 - FEB 15, 2004
Page 1 of 1
Payments, Credits and Adjustments
Transactions
1 15 FEB PAST DUE FEE $35.00
Your request to dose your account has been received. Your account will be dosed when it reaches a $0 balance.
Until then, you will continue to receive statements and must continue to make payments. AD terms and
conditions of the account will apply while a balance remains Please remember to can your cards and cancel all
charges which automatically bill to your account.
You were assessed a past due fee of $35.00 on 02/1S12004 because your minimum payment was not
received by the due date of 02114/2004. To avoid this fee in the future, we recommend that you
allow at least 7 business days for your payment to reach Capital One.
Finartce Charges Pfemr.rareewnsidrfor important information
13a1aasre, A,;.& WEE
yy7 l to .fie R
m PURCHASES 51,62324 .03321%F 1112% 516.71
CASH $113.02 .04389%F 16.02% $1.54
ANNUAL PERCENTAGE RATE applied this period 12.3S%
V PLEASE RETURN PORTION BELOW WITH PAYMENT.
C--V ° OW 0000000 0 4121741586221272 15 1780700045001780705
New Balance $1,780.70
Minimum Amount Due $1,780.70
Payment Due Date March 15, 2004
Total endosed $
Account Number: 4121-7415-8622-1272
Capital One Bank
P.O. Box 85147
Richmond, VA 23276
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P4areprinr somi.,ad*-and* e-mail doers Art--Z Al. car Hark lack.
Sneer Ap.4
Cry Snu Zip
Home Phone Aieernate Phone
E.Q Addm
#9004642262587969# MAIL ID NUMBER
CAROLINE M DARHOWER
a_ 371 ARMY HERITAGE DR F
,n APT 19
m CARLISLE PA 17013-7307
t? ItttllLttll6avtul111111111th.11111ntlt,t6ulll11111j ll
Pleare tariteymr account number on your rhack or money order madepayable to Capital One Bank and mail in the endl ed -Ippe.
peoplepcm online
?? A better way to Internet.
CAROLINE M DARHOWER
371 ARMY HERITAGE DR
UMITED
INTERNET ACCESS
SIGN UP TODAY!
1-888-587-9669
Mention Offer Code: PEARL
Or visit www,peoplepc.corn/go/pearl
8
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0
b [V
Pa piepC is eddy respasb a drft oiler, and a rtd alriiated wit Ctpdal One. Capita Ore don not pntiride, endorse
or guaromse, and in no adNateO with, arty pmdid or service shown here. Any tndemarls mon ianed beret) am solely
Card by the respedire atity. M i"feared. Ely rapor "to 9is d or, you may be armnri alilg idordo"m
aboul yourself to ale vidipany ft provides flu product - for example, Mat you we a Capital One antdrFaC
'PeoplaPC Ornfta: Fuld 3 nwnft are hied at 54.97 per month; $925 per nrodlr Maoafta. OBer avi iehle to now
daHq subscribes at leant 16 years of age ad may not be redeemed with any elder der Of err sullied to dti per el
a y time. Phone ted veal appoR waieble for$1.95 per trireme.
tAcw1eraW is tree la 12 rnonfils. D6er good for knifed time. Atior ft first f 2 rFadls, the Aaxiaa<td ervice all
AWate6Caiy Mnn to dw elmt I POWWl C OaW service. Oga AOSd b Change at WybrW Whh pwmoPC Otdew
Axdaelai tartan Web page tad orfd graW= wi load Bata' wflm cailpa6d b A dad daFup Ilterta seivm
Actual mwis may ary. PeepiePC 0" Aeodoratad is ody wrtgatble wi h PeopkPC Or6e Math service and
Wedfwd WmbwaA browsers Peo*K "Far Awalaated a std eortlpafrble vah Wnlrr A 95 A E 53 SP2.
Service not avahble In a arses. Acura fee, faces, and d w fees and FoRricaiors may apply. Wepinne tell door"
may apply, arm doing trial paiodk taw are mspatwUe for detemoralg whetlera call to are of oar arse menbers wig
m tt in W*uova Wk dopes. Amis may be baited, ePowly d r" times of PW uew D011-tip marbles may be
draped at Peoplel dsadM Cordirstas M SMO d to tiawott WOcedue. N 113B IS aabo m PeoplePc 0dre'a
Servkm Apreanat sad Acoopr alie Use Potty. 5W twit marimn Weed d service; edaal fpad may vary.
O 2806 PeO&K krC AJ Ridde Reserved PeopW Unite and its logos am fmderrWds Of Pe PW c IF the U&
and clew countries.
0 2086 Cepdel One Srrrice, bm Caphd One is a Federally mgbtered service mak All Nile rasaved.
periods; rate. To obtain the average daily bds for fie
6ilirp peeled covered by this stalemart we take date
b.*"np balance of each -9-01 as day, add any row
tranaaceaa to each aapnara, asl sW[raa arry?ymsro
or credo. pf Me cads N appaam m 1M from rib
•trsermrs Fast to 'Bdaloa Ran Applied To,' we duo
star act achy uaupaid fihsrce dw(p fnc?NrdeO in the blame
of each uvr?m 1 This gives u tlhe ddIV balance of each
segmert. Then, we add tq erg the 1W yy bdanms far each
eegrrerht for the bill np petted said of , by that tad
.-.be of days in the carp period. TWO Vve us the
3 agneht.
. Mama l4r di deaga bsll? of Floe IAUtT
s. The tae 'Aroud Pemsa
'APR' m Me from of W
b. it dhe code P (Polar). L 1
Deposit), a S (Bwdr-d
tNs aatemem nest to tai
rues afW
may very stated a n
a the mated insets, as
Joan plea fir fnapn
Than period "410, will be at
by
being peeled covered
it, tai mad. J arasry, i
c. If the tale D (prima, F
LIBOR Repd-d M-Wid
stator mat Fast to the pa
and cmremmh6nb ANMI
Me' my appear as
to V_
or i .Mv
S m y
f. rate W PAGEAbas, the MTEemay
on of of decrease based
Irhe N Street m the
e r..bvrrs/, plus
hea ro
eel ad
day M==
an.
a. Aesasaert of Leta, tOVaraatR sect Rawarnd =L
Your steers will be demand ro mole thin uses
bond hem that ocsaa ddarhg airy bWv period. Ueda tai
teme of you c stmner apneshat, em feserw the rya to
.mi- or na to Mama any, feu weeded prbr notlfcatarh to
Wttar Waiving our rigid 10 asaees tai s Ca ainilar
a a leer tktm.
5. Yov Aoaast. If a fnembenehip lie
eppaam m iM tfam a via rtataeod, you how to 30 to
yoo
days tmn the dare 1 hove w aar in c cued
avid paying the be st a to to !erested to you
=r hcai You our. During tilt padod, y fury
m for your acmur vMlhour hevfno m sty Hite
membomNp foe. To untcel You s"'sa", Yat theta
rutty m by curing our Qlaamet Rdetrar Department
=T dys?Pue New Bdanrce in IN (epdudnp the prim to
the 8. Iirer?Cleat Your scow lrrw - request act ear,
Yymour eccm V by calling our Gatamr Radios
0epatoward. You mud destroy Your chest -rolls) and
accosts access dsclu, -ncd M prowmhod:ed biraq,
and cease uus yrer atxoutr. N Yoe da rot eerhml
pafaWgdted bnNnhg aatingennemt, wt War -otidtf
rerxipt a a dirge your adrrizata to reapers Vaar
acwae. Adstnruny, Vote ec-aa war rot be dosed
udn you pay all annotera Volt owe us shdoraf g: wry
tmmecdou you hew suahodzed, faanm charges. past
dot feu, d-01alft lees, ratumed pot wort fees, -ah
edwroe fee and any otlrr fees assessed to Vmr
a.mut. Volt am mWas". to, thew setouds woaher
they appesr W Yam aC.ord a the film you am= to
dour the araara or they are W-,.d sbaquem ro
Vat mgtmst to doe the scrota. This may result in
derma appeada a yew accoee after Volt haw
vow acrnsa i1 it hes dmady bear, dowel. For exaarge.
if Volt eralerizad a purdhese ham a msreete aro we
renxdw the tnnhtsetian tam to f Agch m after yaw
accord has been dowel, You accord will be reopered,
the amourd .1the defile war be added to your e-Mll,
and yea will be responsible for paVr ANA N liters Is a
memhaeahip on for your acwaa. the Ise will c.*W-
to be charged, to Ube eMe1t pPonhued by law, t" the
.c..W balance hem hem path I. WI as dafawd above.
7. Using rev Aeasue.Vwr card a aamna umber be
used in caroec. ion wiM arry, he~ gsmbtinp
traracTiore.
BILUNG NIGHTS SUMMARY
(In Can Of Firers Or Guawkm Abma Yow Bill
B you tank Vorr bar I. wrong, or if Vw feed men
ktomrtrnn m a uaraata or bar, wMe to W m a
separate drat as men as poesble a the address for
kquidu shown on the lass of ft:a aeturre. We mum
hear from you W later then BO d!yyss after we seta you the
JIM bar m which the error or proMwn appeared. You ten
can ors gwmmr Relators maalm, but doing m will rot
preserve Vma doss- M your letter. give u the OlOwrrp
infometipn your name and smwre m r1ber, Flat doors
errrwa of the wspeaed error, a descmpdm of the ester
and an eplauta, it passible, of why you bear- them is
error; or if you reed shore inimmstmh, a deacdpUat of
the than you am torturer abou. Vw do nor hove to pay arty
ammrd in qualm while war acs kwast4latiall it, bus Vw
are so obligated to pay the pans of y" bill that am not
in weatim While we investigate ymrr queatinn, vie cs.ha
r y OF take any acdm to tellers the
t,t" Spedd Rule For Crest Cold PLarhsare
If you how a problem with to Pslfty of Pr4mrty or
mrAm tit you purchased W M a crest -d and you
how flood in good taith ro mrnact tae WON= veldt the
merdhss, you my how the ripe not to pay the remaking
amour clue m the property or services. Yee hew this
8r aactorh rally war the wrcMa farm was mom thin
60.00 amt the pt-hose a made in Vour hand eau or
within 100 rapes of your evening addma. (t - own or
operate dm fmrdhag, or it we maned you Flat
dwdsmrrm for the property or serhdms, all Purchases
arc coverOd regsldea of arnoutt or Ioration of purchase.)
Please tefrlmtWr to sign erg mneapredmee.
t Does, ant apply td coonaer noo-cresi card -.-Its
t Does nor apply W auemss -mdfir cod arc Ws
capita Ors support Informadon Privacy pmrecdm: soe our
wnWite at wow. alorhe.conn.
Capital Om is a 1dY Ignored wrvim ..,it I Capital
eke Finandd Grporafon. All do" ---ad. a 2003
Gpitd Om
01LGLBAK
1. "err To Avoid A Faara vraae.
t,. Grave Partdd. You wa hew a m'iril- grace period of
25 days whhev TNenm m
dwryePwduse m new pucraea, w
epeda
blonde vaalem, new a and rew Mr
we if Ym pay war mw . New Balance , in
adcadrhm with tee krrPertanlt Nuke fpr psymm blow,
and in Alma iw it to be cradted by blur nerd damned
doakp date. There is m gram period m -dl adranh.ee
and special tmFafes. In add", them is Fa grace period
a any vaaedtan if yad do na Pay flat Ind -New
balance.'
b. Aawukrg Fb- C hags. Trrhraaaker volion am not
fl Chet au= oi rho traraedanan 2) bars the data d.
trarwaafm I. pm-ad to yore Aecdud or 3) from the
firer -lands, day of the waiters bikrp period, Addarndly,
if you did not pay the -New Belated- tram the PM4"
bilWV perfect in full, reamupes racist to J-`lFe to
yyaowu ovoid beta, ce well the hmpdd balance Is paid I. 1J1.
Tlis means tut you fmy? as oar frhanm durges, even f(
yon pay the enim New Belame Yhdcatad m fed hold of
you Fast d by the rhea Metamea deists dam, tea old
not do m for the po"" mofah. lMpeid Ounce charged
am added to the appYcable "am of your Acmrsn.
t' c. b9lhirsnfru Fihsrvw CAaP. for adh brlfetg Pedad?h,
you amman is abject to a nnhsnuce dupe, a nuinknun
total RNANCF CHKARIGE of 00.50 war W knpoed. If the
told Imewe 6, " For flan the application of you
Perbdc rate(s) is lees =0 .50, won will aLimcs thot
a.. from the $0.50 aawdrfl and the Age race will be
bleed 1o the puhdrse segr?t of 1'era accacra.
t d. Tanh(harary Reduaden I. Fine WfN. Ws reaerve the
right to nag seems any a ad find a charges for any given
2. AvergaW DYy glows 1heYrd rp New Nedrssd-
a. Frahm large is -I It W fmadplyhp Me rWY
balar" of dedh eeplam of your MCFaFF t te.g.. oral
adwn-, purchase. Wec411muNr, and special Purchase)
by doe coramponAnp daily periodic rauW het her bem
pteviouty disdmed to you. At "a wal of emb dayy dump
the bgep period. war apply tai dailyyperiod. tae for seta
6 .. Thom at the vial Its, ainkghoperiod, - add up
the malts of terse dam cdmtatiare to arrive a y-r
periodic insrxe charge lot e"" from ..h ssag mm io atri sarrom. a the foci periodic
aster)- Berge for you awoes. To gar the daily bals-
for each sou n of was, accord, we uke tot beprrap
balance dot emh saWsoa end add arw new traFaatsinrr
and anype dose falsetto charge edadaed a the pmvios
days bala,hm for that aeginsor. We then mbtmet any
peyovern OF aadhe pared as of that day that are .1ocaud
to that septum. TNs give w the separate daily bden
for sech estimate of Vote acome. Ibwever, if you paid the
Hew Betenm shown on Vfsr previous tiamhaa kit kill (01
If year Faw Wlence was zero or a amdrt amaad), new
vamunias winch pal to your purchase or special
Purdhsse =1;1 not added to V. any baeteas. We
calaiste dally biome by adding es On daily
Wlaroes together and dividing the arso by the ma rber of
the days in the a MA Nang cede. To -loins, Vora total
finafrm charg=W% avenge el aegy bdaFas by the
daily prtlesc nmWr aye M the Nnrq
period. Due to touWbp m • any basis, tram rosy be a
slWa wderoe between Ws calalatim and the smmad of
fimn durge aauany aweesed.
b. If the node Z w N appears m the lead of Ibis aas-'a
ma to 'Bdanee Rate Applied To,' we FaA iply the
6657M
Irrportaa Notice: Vmr payment won W erastsd to your stamen ere of rho eta vw receive n, provided you wed the bottom Donlon of this watarnate said your .luck M the erndosed
re,dnunm envelope, sal your paYrrrsrr s recdhrd m our po-sdrhti comer by 3 p.m. Pa?mms sddreaaed to ow Vir¢rhia m Georgia promsdrq came mot a mcdved a a iasimsc ay
by 300 D.m. Fr. Psyanenu atldressed m our Washbpm Pnomadnp cohur mu[ be mcdwd on a bukhwa daY M 3:00 P.m. frT. Plewe allow a lea nor (51 buuluw daq for peso)
ddnwry. Psymoas mmived by us a anY other lotetion or in mpttar tom may not W tested tai smite day we re-fve firm. Our budrea aYa em Moodsy dhrouy, SrturdeY. euiusnp
hoadsys. Pleaw a rot hse aadu, paper dipa, ere. vdherh t ?? to?igpadh?m.•ks remiwd?dud? the bga?kW. Yw auhodze u u make a one-rime dearaic traufm deNt trap yaw
amt accost for tai amaad oft tho check TTNNss authorization a lip cyder ehen if rat by aoseana else. If vie eamol praeeas red tramier, you
ehahorin o to make a durpe agirha your Wink emoted tang the deck, a paper dmh ol Chair tan.
VERIFICATION
The undersigned does hereby verify subject to the penalties of 18 Pa. C.S. §4904
relating to unsworn falsification to authorities, that he is an attorney for the Plaintiff herein and
makes this Verification based upon the facts as supplied to him by the Plaintiff because the
Plaintiff is outside the jurisdiction of the court and the Plaintiffs Verification cannot be obtained
within the time allowed for the filing of this pleading; and that the facts and circumstances set
forth in this pleading, are true and correct to the best of his knowledge, information and belief.
k
CERTIFICATE OF SERVICE
A true and correct copy of the Amended Complaint in Civil Action has been served by First Class
/? 6
Mail, postage pre-paid, on 17 day of rL , 2007 upon the following:
Nichole M Walters, Esquire
Elder Law Clinic
150 South College Street,
Carlisle, Pa. 17013-2899
By:
WWR No.
9n
-0
P -
?4 J
0
SHERIFF'S RETURN - REGULAR
CASE NO: 2007-00997 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
CAPITAL ONE BANK
VS
DARHOWER CAROLINE M
JASON VIORAL , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
DARHOWER CAROLINE M the
DEFENDANT , at 1710:00 HOURS, on the 23rd day of February , 2007
at 371 ARMY HERITAGF nRTVF AIDT 14
CARLISLE, PA 17013
by handing to
CAROLINE DARHOWER
a true and attested copy of COMPLAINT & NOTICE
together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing 18.00
Service 4.40
Affidavit .00
Surcharge 10.00
.00
3101C?L'?, ? 3 2 .4 0
Sworn and Subscibed to
before me this day
of
So Answers:
p F..
R. Thomas Kline
02/26/2007
WELTMAN WEINBERG REIS
By:
pUty Sheriff
A.D.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK,
Plaintiff
VS.
CAROLINE M DARHOWER
Defendant
No. 07-997 CIVIL TERM
PRAECIPE FOR DEFAULT JUDGMENT
ON AMENDED COMPLAINT
FILED ON BEHALF OF
Plaintiff
COUNSEL OF RECORD OF
THIS PARTY:
James C. Warmbrodt, Esquire
PA I.D.#42524
Weltman, Weinberg & Reis Co., L.P.A.
2718 Koppers Bldg.
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR#05701486
Judgment Amount $ 2,555.92
THIS LAW FIRM IS ATTEMPTING TO COLLECT THIS DEBT FOR ITS CLIENT AND ANY
INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK,
Plaintiff
VS. Civil Action No. 07-997 CIVIL TERM
CAROLINE M DARHOWER
Defendant
PRAECIPE FOR DEFAULT JUDGMENT ON AMENDED COMPLAINT
TO THE PROTHONOTARY:
Kindly enter Judgment against the Defendant, CAROLINE M DARHOWER above named, in the default of
an Answer, in the amount of $2,555.92 computed as follows:
Amount claimed in Complaint $2,446.32
Interest from January 26, 2007 to June 12, 2007
at the legal interest rate of 11.900% Per annum $109.60
TOTAL $2,555.92
I hereby certify that appropriate Notices of Default, as attached have been mailed in accordance with PA
R.C.P. 237.1 on the dates indicated on the Notices.
WELTMAN, WEINBERG & REIS CO., L.P.A.
By:
James C. Wa rodt, Esquire
PA I.D.#42 4
Weltman, ei erg & Reis Co., L.P.A.
2718 Ko pers dg.
436 Se nth A enue
Pittsb gh, P 15219
(412 434-7 55
WW #05 01486
Plaintiffs address is:
c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Build , 436 70' Avenue, Pittsburgh, PA 15219
And that the last known address of the Defendant is: 371 ARMY HERITAGE DR APT., CARLISLE,PA 17013.
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK
Plaintiff 07-997 CIVIL TERM
CAROLINE M DARHOWER
Defendants
IMPORTANT NOTICE ON AMENDED COMPLAINT
TO:
CAROLINE M DARHOWER
371 ARMY HERITAGE DR APT
CARLISLE,PA 17013
Date of Notice: 0 ?'f 2 Z l0 -7
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE
PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS
TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS
NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR
PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF
YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE
TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
LAWYER REFERRAL SERVICE
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
(717) 249-3166
WELTMAN, WEI ERG & REIS CO., L.P.A.
By.
James C. W odt, Esquire
PA I.D. #4 524
MN, INBERG & REIS CO., L.P.A.
WELT
2718 piers uilding
436 Seventh enue
PittsbJ?`rg 1, A 15219
(412 434 955
W R #5701486
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK
Plaintiff 07-997 CIVIL TERM
CAROLINE M DARHOWER
Defendants
IMPORTANT NOTICE ON AMENDED COMPLAINT
TO:
Nichole M. Walters, Esquire
Elder Law Clinic
150 South College Street,
Carlisle, PA. 17013-2899
Date of Notice: d J-/z 2- `J 7
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE
PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS
TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS
NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR
PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF
YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE
TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
LAWYER REFERRAL SERVICE
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
(717) 249-3166
WELTMAN, WEINBERG & REIS CO., L.P.A.
By:
James C. W odt,
PA I.D. #425
WELTMAN,/WEII I
2718 KoppOrs Builc'ii
436 Seventh Ave
re
Pittsburg,', PA 15 19
(412) 434-795$
W WR A5*486
Esquire
ERG & REIS CO., L.P.A.
IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK,
Plaintiff
vs.
CAROLINE M DARHOWER
Defendant
Case no: 07-997 CIVIL TERM
NON-MILITARY AFFIDAVIT
The undersigned, who first being duly sworn, according to law, deposes and states as follows:
That he/she is the duly authorized agent of the Plaintiff in the within matter.
Affiant further states that the within Affidavit is made pursuant to and in accordance with the
Servicemembers' Civil Relief Act (SCRA), 50 U.S.C. App. § 521.
Affiant further states that based upon investigation it is the affiant's belief that the Defendant, CAROLINE M
DARHOWER is not in the military service.
Affiant further states that this belief is supported by the attached certificate from the Defense Manpower Data
Center (DMDC), which states that the Defendant, CAROLINE M DARHOWER is not in the military service.
Further Affiant sayeth naught.
AFF
SWORN TO AND
of U1n^1
Y
in my presence this A day
7 COMMONWEALTH OF PENNSYWAN4A
Notarial Seat
Wayne A. Jones, Notary Public
City Of Pittsburgh, A{iegheny Co 2010
My commission E?ires June 29,
Member, Pennsy11jaN8 A sociaiion of Notaries
This law firm is a debt collector attempting to collect this debt for our client and any information obtained will be
used for that purpose.
Request for Military Status
Department of Defense Manpower Data Center
Addvffih?
IV Military Status Report
Pursuant to the Servicemembers Civil Relief Act
Page 1 of 2
JUN-12-2007 10:22:52
Last Name First/Middle Begin Date Active Duty Status Service/Agency
DARHOWER Based on the information you have furnished, the DMDC does not
possess any information indicating that the individual is currently on
active duty.
Upon searching the information data banks of the Department of Defense Manpower Data Center, based
on the information that you provided, the above is the current status of the individual as to all branches
of the Military.
y6y,
Mary M. Snavely-Dixon, Director
Department of Defense - Manpower Data Center
1600 Wilson Blvd., Suite 400
Arlington, VA 22209-2593
The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that
maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the
official source of data on eligibility for military medical care and other eligibility systems.
The Department of Defense strongly supports the enforcement of the Servicemembers Civil Relief Act
[50 USCS Appx. #167;#167; 501 et seq] (SCRA) (formerly the Soldiers' and Sailors' Civil Relief Act of
1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the
individual is currently on active duty" responses, and has experienced a small error rate. In the event the
individual referenced above, or any family member, friend, or representative asserts in any manner that
the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly
encouraged to obtain further verification of the person's active duty status by contacting that person's
Military Service via the "defenselink.mil" URL provided below. If you have evidence the person is on
active-duty and you fail to obtain this additional Military Service verification, provisions of the SCRA
may be invoked against you.
If you obtain further information about the person (e.g., an SSN, improved accuracy of DOB, a middle
name), you can submit your request again at this Web site and we will provide a new certificate for that
query.
This response reflects current active duty status only. For historical information, please contact the
Military Service SCRA points-of-contact.
See: httr)://www.defenselink.mil/faq/pis/PC09SLDR.htmi
WARNING: This certificate was provided based on a name and Social Security number (SSN) provided
https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 6/12/2007
Request for Military Status
Page 2 of 2
by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided.
Report ID:BVKQWVECLUH
https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 6/12/2007
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IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK,
Plaintiff
vs.
CAROLINE M DARHOWER
Defendant
NICHOLE M WALTERS, ESQUIRE
ELDER LAW CLINIC
150 SOUTH COLLEGE STREET,
CARLISLE, PA. 17013-2899
Civil Action No. 07-997 CIVIL TERM
NOTICE OF JUDGMENT OR ORDER
TO: ( ) Plaintiff
(xx) Defendant
( ) Garnishee
You are hereby notified that the following
Order r J tment was entered against you
on ?ao7
(xx) Assumpsit Judgment in the amount
of $2,555.92 plus costs.
( ) Trespass Judgment in the amount
of $ plus costs.
( ) If not satisfied within sixty (60)
days, your motor vehicle operator's license and/or registration
will be suspended by the Department of Transportation, Bureau
of Traffic Safety, Harrisburg, PA.
(xx) Entry of Judgment of
( ) Court Order
( ) Non-Pros
( } Confession
(xx) Default
( ) Verdict
( ) Arbitration
Award
Prothonotary
By: -C / D, . -
PR NOTARY (8*}. `--?
Plaintiff's address is:
c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7t' Avenue, Pittsburgh, PA 15219
1-888-434-0085
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK,
Plaintiff
vs. Civil Action No. 07-997 CIVIL TERM
CAROLINE M DARHOWER
Defendant
NOTICE OF JUDGMENT OR ORDER
TO: ( ) Plaintiff
(xx) Defendant
( ) Garnishee
You are hereby notified that the following
Order r J dgment was entered against you
on ;L66
(xx) Assumpsit Judgment in the amount
of $2,555.92 plus costs.
( ) Trespass Judgment in the amount
of $ plus costs.
( ) If not satisfied within sixty (60)
days, your motor vehicle operator's license and/or registration
will be suspended by the Department of Transportation, Bureau
of Traffic Safety, Harrisburg, PA.
(xx) Entry of Judgment of
( ) Court Order
( ) Non-Pros
( ) Confession
(xx) Default
( ) Verdict
( ) Arbitration
Award
Prothonotary
By:
PR ONOTARY
CAROLINE M DARHOWER
371 ARMY HERITAGE DR APT
CARLISLE,PA 17013
Plaintiff's address is:
c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7 h Avenue, Pittsburgh, PA 15219
1-888-434-0085
I
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK
Plaintiff
vs.
CAROLINE M. DARHOWER
Defendant
No. 07-997-CIVIL TERM
AFFIDAVIT OF SERVICE
ON AMENDED COMPLAINT
FILED ON BEHALF OF
Plaintiff
COUNSEL OF RECORD OF
THIS PARTY:
James C. Warmbrodt, Esquire
PA. I.D.#42524
WELTMAN, WEINBERG & REIS CO., L.P.A.
2718 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
W W R#05701486
I
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK
Plaintiff
vs.
CAROLINE M. DARHOWER
Defendant
No. 07-997-CIVIL TERM
AFFIDAVIT OF SERVICE ON AMENDED COMPLAINT
BEFORE ME, the undersigned authority, personally appeared James C. Warmbrodt, Esquire, who
according to law deposes and says that a copy of the Amended Complaint in Civil Action has been served on the
Defendant's Attorney, Nicole M. Walters, Esquire.
1. On or about April 17, 2007, Plaintiff mailed a copy of the Amended Complaint to Nicole M.
Walters, Esquire by first class mail. Attached is the Certificate of Service as Exhibit "I".
2. On or about May 22, 2007, Plaintiff mailed Important I O-Day Notices on Amended Complaint to
both the Defendant and her Counsel, which was 35 days after sending the Amended Complaint. Attached as Exhibit
46219
Service is deemed perfected on April 17, 2007.
WELTMAN, WEINBERG & REIS, CO., L.P.A.
Sworn to and subscribed
before me this 2-1
day of 007.
"/Xa/?y d - _
NOT RY PUBL.
James '1rmbrodt, Esquire
PA I. 42524
j7Ko M N, WEINBERG & REIS CO., L.P.A.
ers Building
ve th Avenue
r , PA 15219
47955
05701486
COMM M F P V V ANA
Nom w
W, pm x Jom, NOW UMIC
city
My Com. nisnim E*kM y 28.2010
Member, Pennsylvania Association of Notaries
I rl_
CERTIFICATE OF SERVICE
A true and correct copy of the Amended Complaint in Civil Action has been served by First Class
t?
Mail, postage pre-paid, 417 day of L 2007 upon the following:
Nichole M Walters, Esquire
Elder Law Clinic
150 South College Street,
Carlisle, Pa. 17013-2899
By:
EXHIBIT
W WR No.
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK
Plaintiff 07-997 CIVIL TERM
CAROLINE M DARHOWER
Defendants
EIPORTANT NOTICE ON AMENDED COMPLAINT
TO:
CAROLINE M DARHOWER
371 ARMY HERITAGE DR APT
CARLISLE,PA 17013
Date of Notice: 0;j'/2 z- lD
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE
PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS
TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS
NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR
PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF
YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE
TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
LAWYER REFERRAL SERVICE
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
(717) 249-3166
WELTMAN,
By:
James C.
PA I.D. I
WELTM
2718 K9j
436 See
Pittsb
(412 432
ERG & REIS CO., L.P.A.
Esquire
ERG & REIS CO., L.F.A.
A 15219 "WHIT
55
1486 ??
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK
Plaintiff 07-997 CIVIL. TERM
CAROLINE M DARHOWER
Defendants
IMPORTANT NOTICE ON AMENDED COMPLAINT
TO:
Nichole M. Walters, Esquire
Elder Law Clinic
150 South College Street,
Carlisle, PA. 17013-2899 /
Date of Notice: 0 f -/2 -L
(? 7
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE
PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS
TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS
NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WLT'HOUT A HEARING AND YOU MAY LOSE YOUR
PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF
YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE
TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
LAWYER REFERRAL SERVICE
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
(717) 249-3166
WELTMAN, WEINBERG & REIS CO., L.P.A.
By:
James C. W dt, Esquire
PA I.D. #42524
WELTMAN WEINBERG & REIS CO., L.P.A.
2718 Kopp BuiI4in9
436 Seven Ave e
Pittsburgl,PA 1P19 EXHIBIT
(412) 434-795 -
W WR?05 7486 `? 2 "
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