HomeMy WebLinkAbout07-1021
GREGG L. MORRIs, ESQ.
PATENAUDE & FELIX, A.P.C.
213 E. MAIN STREET
CARNEGIE, PA 15106
(412) 429-7675
FACSIMILE (412) 429-7679
P A ID#69006
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYL VANIA
CAPITAL ONE BANK,
Plaintiff,
)
)
) NO. C7 -1DJ..l
)
)
)
)
)
)
)
C!;u~Cr~
v.
JAMES M JACKSON,
Defendant( s).
COMPLAINT IN CIVIL ACTION
Filed on behalf of:
CAPITAL ONE BANK,
Plaintiff
Counsel of Record for This Party:
Gregg L. Morris, Esquire
Pa I.D. #69006
Patenaude & Felix, A.P.C.
213 East Main Street
Carnegie, P A 15106
(412) 429-7675
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYL VANIA
CAPITAL ONE BANK, )
)
Plaintiff, ) NO.
)
v. )
)
JAMES M JACKSON, )
)
Defendant. )
)
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 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. TillS
OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE ALA WYER, TillS OFFICE MAY BE
ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER
LEGAL SERVICES TO ELIGffiLE PERSONS AT A REDUCED FEE OR NO FEE.
LAWYER REFERRAL SERVICE
CUMBERLAND COUNTY BAR ASSOCIATION
32 S. BEDFORD STREET
CARLISLE, PA 17013
717-249-3166
IN TIffi COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYL VANIA
CAPITAL ONE BANK,
Plaintiff
)
~ NO. 0'7. /p.2J G:v:J T.u--
)
)
)
)
)
)
)
v.
JAMES M JACKSON,
Defendant.
COMPLAINT IN CIVIL ACTION
AND NOW, comes Plaintiff, CAPITAL ONE BANK, by and through its
attorney, GREGG L. MORRIS, ESQUIRE and the law offices of PATENAUDE & FELIX,
AP.C. and files the following Complaint in Civil Action, and in support thereof aver as
follows:
1. Plaintiff, CAPITAL ONE BANK, is a corporation and for the purpose of this
litigation, maintaining a place of business c/o Patenaude and Felix, A.P.C., 213 East Main
Street, Carnegie, Pennsylvania 15106.
2. Defendant is JAMES M JACKSON, an adult individual, believed to currently
reside at 114 ROSS AVE, NEW CUMBERLAND, P A 17070.
3. Defendant(s) obtained extensions of credit on the following open ended credit
card account issued by CAPITAL ONE BANK being Account No. 4388641664592826 ,
for the purchase of goods and services.
4. The Defendant(s) made payments, but has refused to pay, and now refuses to
pay the balance due and owing on the aforesaid account in the said sum of$4,375.67, plus
interest and costs. An Affidavit of a representative of CAPITAL ONE BANK is attached
hereto as Plaintiffs Exhibit "A" and is incorporated herein by reference.
WHEREFORE, Plaintiff demands Judgment in its favor, and against Defendant, in
the amount of $4,375.67, plus interest as attached hereto, with continuing interest thereon at
the legal rate from the date of Judgment plus costs.
o
213 E. Main Street
Carnegie, PA 15106
(412) 429-7675
---f / /] -1 "'cJ I,.,.,..-~I' . nil, .,
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STATE OF GEORGIA
E~A
COUNTY OF GWINNEIT
Personally appeared before me HENDERSON W MCKENZIE II, who being duly sworn, made oath that
he/she is an authorized agent of CAPITAL ONE BANK, and that he/she is authorized to make this
affidavit, and to the best of his /her knowledge and belief, JACKSON, JAMES M is/are justly indebted to
CAPITAL ONE BANK in the sum of $5660. 13 Dollars as of 08/29/2006 with 26.99% interest from said
date, and reasonable attorney fees, and that the annexed account which is made part hereof is a true and
correct statement of said indebtedness. To the best of my knowledge, none of the above named
defendant(s) is/are active duty in the military service of the United States or any of its allies as defined in
the Soldiers and Sailor's Relief Act of 1940 with amendments.
Given under my hand this 14th day of September, 2006.
~f/{.IJ PiJ;j.,~
Affiant
Taken, subscribed and Sworn to before me,
Maisha Davis
Notary Public in and for the City/County and State aforesaid, in my City/County
aforesaid this 14th day of September, 2006.
rc:A!SHA OA\%
NOTARY PUBUC
DEKAlB COUNTY,GEORGIA
MY COMMISSION EXPIREs C'::TOBER 24.2008
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Notary Public
My commission expires on
A144
PATENAUDE & FELIX, A.P.C
4388641664592826
-----_.._-------~-------._------_._,.---_..~---,---- - - --------------
VERIFICATION
AND NOW, Gregg L. Morris, verifies the statements made in this Complaint that are true
and correct to the best of his knowledge, information and belief. I understand that false statements
herein are made subject to the penalties of Pa.C.S. Section 4904, relating to unsworn falsification
to authorities.
By virtue of the fact that the Plaintiff is outside the jurisdiction of the Court and the
verification cannot be obtained within the time allowed for the filing ofthis pleading, the pleading
is submitted by counsel having sufficient knowledge, information and belief based upon the
information provided by him by the Plaintiff. The verification of the party will be provided if
requested.
gg . Mo re
atenaude & Felix, A.P.C
213 E. Main Street
Carnegie, P A 15106
(412) 429-7675
Date:
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
CAPITAL ONE BANK, )
)
Plaintiff ) NO. 07-1021
)
v. )
)
)
JAMES M JACKSON, )
Defendant )
PRAECIPE TO SETTLE
AND DISCONTINUE
WITHOUT PREJUDICE
Filed on behalf of
Capital One Bank,
Plaintiff
Counsel of Record for This
Party:
Gregg L. Morris, Esquire
Pa LD. #69006
Patenaude & Felix, A.P.C.
213 E. Main Street
Carnegie, P A 15106
(412)429-7675
JACKSON, JAMES 762.2374.wpd
-
...
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
CAPITAL ONE BANK, )
)
Plaintiff ) NO. 07-1021
)
v. )
)
)
JAMES M JACKSON, )
Defendant )
PRAECIPE TO SETTLE AND DISCONTINUE WITHOUT PREJUDICE
TO: Prothonotary
Please settle and discontinue the matter captioned above without prejudice. Thank you.
Date:
Sworn to and subscribed before me
this ~ day of ~ 2007,
~ ~, ~A _
Notary Public ~
NOTARIAL SE;,
ERIN N 8Al.:TZ~
No ell
CARNEG/f 8ORo~ary Public
My commIulonG~. ALLEGHENY COUNTY
p/r., JUI27, 2070
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