HomeMy WebLinkAbout07-1183
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GREGG L. MORRIS, ESQ.
PATENAUDE & FELIX, A.P .C.
213 E. MAIN STREET
CARNEGIE, P A 15106
(412) 429-7675
FACSIMILE (412) 429-7679
P A ID#69006
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
CAPITAL ONE BANK,
)
)
) NO. O^l - IIP~
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Plaintiff,
v.
MICHAEL E ZIMMERMAN ,
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 J.D. #69006
Patenaude & Felix, A.P.C.
213 East Main Street
Carnegie, P A 15106
(412) 429-7675
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
CAPIT AL ONE BANK,
)
)
) NO.
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)
)
)
)
)
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Plaintiff,
v.
MICHAEL E ZIMMERMAN ,
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. TIDS
OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT IDRlNG A LAWYER.
IF YOU CANNOT AFFORD TO IDRE A LAWYER, TIDS OFFICE MAYBE
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 S. BEDFORD STREET
CARLISLE, P A 17013
717-249-3166
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
CAPITAL ONE BANK,
)
~ NO. 6'1 - //!3
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)
)
)
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)
)
~1~\LT~
Plaintiff
v.
MICHAEL E ZIMMERMAN ,
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,
A.P.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 MICHAEL E ZIMMERMAN, an adult individual, believed to
currently reside at 219 MEADOW DR , SHIPPENSBURG, P A 17257.
3. Defendant(s) obtained extensions of credit on the following open ended credit
card account issued by CAPITAL ONE BANK being Account No. 4305982484573467 ,
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$883.48, 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 $883.48, plus interest as attached hereto, with continuing interest thereon at
the legal rate from the date of Judgment plus costs.
Respectfully Submitted:
S,ESQ
E. Main Street
amegie, PA 15106
(412) 429-7675
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elWkMA
STATE OF GEORGIA
COUNTY OF GWINNETT
Personally appeared before me MAISHA DAVIS, 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, ZIMMERMAN, MICHAEL E is/are justly indebted to CAPITAL
ONE BANK in the sum of$1055.93 Dollars as of 09/05/2006 with 16.65% 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 18th day of September, 2006.
~~~
Affiant
Taken, subscribed and sworn to before me,
Henderson W. McKenzie II
Notary Public in and for the City/County and State aforesaid, in my City/County
aforesaid this 18th day of September, 2006.
Henderson W. McKenzie U ,
NotafIJ Public, Gwinn~tt County, GeorgIa
MV Commission Expires August 2, 20~ 0
My commission expires on
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Notary Public
A144
PATENAUDE & FELIX, A.P.C
4305982484573467
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VERIFICATION
AND NOW, Gregg L. Morris, verifies the statements made in this Complaint 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 of this 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.
Date:
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
CAPITAL ONE BANK,
Plaintiff
)
)
) NO. 07-1183
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)
)
)
)
)
v.
MICHAEL E ZIMMERMAN,
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 J.D. #69006
Patenaude & Felix, A.P.C.
213 E. Main Street
Carnegie, P A 15106
(412)429-7675
ZIMMERMAN, MICHAEL 762.2223.wpd
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
Plaintiff
)
)
) NO. 07-1183
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)
)
)
)
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CAPITAL ONE BANK,
v.
MICHAEL E ZIMMERMAN,
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
thisAdayof (\~ 2007,
~'Vt . ~
Notary Public ~
NOTARIAL SEAL
ERIN N BAlTZELL
Notary Public
CARNEGIE BOROUGH, AI.lEGHENY COUNlY
Mv Commlsslol"l Fl(plres Jul 21, 2010
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