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Home My WebLink About07-1823GREGG L. MORRIS, ESQ. PATENAUDE & FELIx, A.P.C. 213 E. MAIN STREET CARNEGIE, PA 15106 (412) 429-7675 FACSIMILE (412) 429-7679 PA ID#69006 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CAPITAL ONE BANK, Plaintiff, V. SHAWN HOUSE, Defendant(s) NO. 0.7 - IYa3 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, PA 15106 (412) 429-7675 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CAPITAL ONE BANK, Plaintiff, NO. V. SHAWN HOUSE, 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. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. 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 S. BEDFORD STREET CARLISLE, PA 17013 717-249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CAPITAL ONE BANK, V. Plaintiff Defendant. NO. 01 - /.0.1,3 COMPLAINT IN CIVIL ACTION AND NOW, comes Plaintiff, CAPITAL ONE BANK, by and through its SHAWN HOUSE, l.: Icy ?.? attomey,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 SHAWN HOUSE, an adult individual, believed to currently reside at 135 N HANOVER ST APT 1, CARLISLE, PA 170132446. 3. Defendant(s) obtained extensions of credit on the following open ended credit card account issued by CAPITAL ONE BANK being Account No. 4862362425001743 , 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 $865.03, plus interest and costs. An Affidavit of a representative of CAPITAL ONE BANK is attached hereto as Plaintiff s Exhibit "A" and is incorporated herein by reference. WHEREFORE, Plaintiff demands Judgment in its favor, and against Defendant, in the amount of $865.03, plus interest as attached hereto, with continuing interest thereon at the legal rate from the date of Judgment plus costs. Respectfully Submitted: Carnegie, PA 15106 (412) 429-7675 STATE OF GEORGIA COUNTY OF GWINNETT 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, HOUSE, SHAWN is/are justly indebted to CAPITAL ONE BANK in the sum of $1071.19 Dollars as of 09/21/2006 with 25.90% 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 26th day of October, 2006. A fi nt Taken, subscribed and sworn to before me, MYRA PRINDLE Notary Public in and for the City/County and State aforesaid, in my City/County aforesaid this 26th day of October, 2006. Notary P lic N My commission expires on Mote 1 E " F'Ubii Gwinriatt County Georgia My Commission Expires July 31 st 20C9 A144 PATENAUDE & FELIX, A.P.C 4862362425001743 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: 213 E. Main St. Carnegie, PA 15106 (412) 429-7675 1 ` ?o c i t-- na .?1 N -°+ 7*C Y? c.n 0 ?rl =G ?:J SHERIFF'S RETURN - NOT FOUND CASE NO: 2007-01823 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CAPITAL ONE BANK VS HOUSE SHAWN R. Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT HOUSE SHAWN but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT & NOTICE , the within named DEFENDANT 135 N HANOVER STREET APT 1 , HOUSE SHAWN NOT FOUND , as to CARLISLE, PA 17013-2446 PER PROPERTY OWNER, DEFENDANT MOVED OUT OVER A YEAR AGO. Sheriff's Costs: Docketing 18.00 Service 4.80 Not Found 5.00 Surcharge 10.00 .00 NJ1q-7 37.80 So answers, C R. Thomas Kline Sheriff of Cumberland County PATENAUDE & FELIX 04/12/2007 Sworn and Subscribed to before me this day of A. D. ? w IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CAPITAL ONE BANK V. SHAWN HOUSE Plaintiff ) NO. 2007-1823 Defendant(s) ) PRAECIPE TO REINSTATE COMPLAINT Filed on behalf of: CAPITAL ONE BANK Counsel of Record for This Party: Gregg L. Morris, Esquire Pa I.D. #69006 Patenaude & Felix, A.P.C. 213 E. Main Street Carnegie, PA 15106 (412) 429-7675 PA_159 Prcp to Reinst Cmplt P&F File No. 762.4103 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CAPITAL ONE BANK Plaintiff V. SHAWN HOUSE Defendant(s) NO. 2007-1823 PRAECIPE TO REINSTATE COMPLAINT TO: Prothonotary Please reinstate Complaint in Civil Action on behalf of Plaintiff, CAPITAL ONE BANK and against Defendant(s), above named. Thank you. Respectfully C. Date: PA_159 Prep to Reinst Cmplt Oregg L. Morris, Esquire 213 E. Main Street Carnegie, PA 15106 (412) 429-7675 P&F File No. 762.4103 OC sIr o L C7, p «J .. cn s fn acs c SHERIFF'S RETURN - REGULAR CASE NO: 2007-01823 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CAPITAL ONE BANK VS HOUSE SHAWN MARK CONKLIN Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon HOUSE SHAWN the DEFENDANT , at 1030:00 HOURS, on the 8th day of May , 2008 at 1 E FIRST STREET BOILING SPRINGS, PA 17007-2446 by handing to JEOFFREY KEITH, OWNER, ADULT IN CHARGE a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 51)+t (?, Sworn and Subscibed to before me this So Answers: 18.00 5.00 . 00 10.00 R. Thomas Kline .00 33.00 05/09/2008 PATENAUDE & FELIX By: day Deputy Sheriff of A. D. n IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CAPITAL ONE BANK Plaintiff NO. 2007-1823 V. SHAWN HOUSE Defendant(s) PRAECIPE FOR DEFAULT JUDGMENT Filed on behalf of: CAPITAL ONE BANK Counsel of Record for This Party: Gregg L. Morris, Esquire Pa I.D. #69006 Patenaude & Felix, A.P.C. 213 E. Main Street Carnegie, PA 15106 (412) 429-7675 PA_119 Prcp Def Jg Both P&F File No. 762.4103 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CAPITAL ONE BANK Plaintiff V. SHAWN HOUSE Defendant(s) NO. 2007-1823 PLAINTIFF'S PRAECIPE FOR DEFAULT JUDGMENT TO:PROTHONOTARY Please enter a judgment against the defendant, above named, for failure to file an Answer to Plaintiffs complaint. Amount claimed in Complaint Interest from October 20, 2005 Less payments received Attorney's fees TOTAL $865.03 $591.44 $0.00 $0.00 $1,456.47 With continuing interest on the principal amount of $1,456.47, with interest at the legal rate, plus costs of suit. I hereby certify that a written notice of intention to file this praecipe was mailed to the defendants and defendants' counsel (if known), after the default had occurred and at least ten (10) days prior to the date of the filing of this praecipe. A copy of the4otice is attached. A.P.C. Date: June 10, 2008 PA_119 Prcp Def Jg Both Gregg Morris, Esquire Z) X. Main Street Carnegie, PA 15106 (412) 429-7675 P&F File No. 762.4103 >. ttrC° C\l U ; r `? U IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CAPITAL ONE BANK ) Plaintiff ) V. ) SHAWN HOUSE ) Defendant(s) ) NO. 2007-1823 PLAINTIFF'S AFFIDAVIT OF NON-MILITARY SERVICE AND MAILING OF NOTICE PURSUANT TO PA.R.C.P. 1037(b) COMMONWEALTH OF PENNSYLVANIA ) SS. COUNTY OF CUMBERLAND ) Before me, the undersigned authority, a Notary Public in and for said County and State, personally appeared GREGG MORRIS, attorney for and authorized representative of Plaintiff, who being duly sworn according to law, deposes and states that the defendant(s), SHAWN HOUSE, is not in the military service of the United States of America to the best of his knowledge, information and belief and certifies that Notice of Intent to take Default Judgment was mailed in accordance with Pa.R.C.P.237.1, as evidenced byAkhe attached copy. Patgk6(k & Felix, A)P.C. Date: June 10, 2008 Sworn to and sub ribed before me this 11L day of a COMMONWEALTH OF PENNSYLVANIA Notarial Seal Carolyn J. StDAW, Notary Pd* Carnegie Boro, Allegheny County My Commission EA*es Aug. 14, 2011 regg L. Morris, Esquire 13 E. Main Street Carnegie, PA 15106 (412) 429-7675 Member, Pennsylvania Association of Notaries PA 120 Aff of Non Mil P&F File No. 762.4103 r N ?}G cam , ? ? N IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CAPITAL ONE BANK Plaintiff NO. 2007-1823 V. SHAWN HOUSE Defendant(s) IMPORTANT NOTICE Filed on behalf of: CAPITAL ONE BANK Counsel of Record for This Party: Gregg L. Morris, Esquire Pa I.D. #69006 Patenaude & Felix, A.P.C. 213 E. Main Street Carnegie, PA 15106 (412) 429-7675 PA_111 10 Day Dl P&F File No. 762.4103 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CAPITAL ONE BANK Plaintiff V. SHAWN HOUSE Defendant(s) To: Shawn House 1 E. First St Boiling Springs Pennsylvania 17007--244 Date of Notice: May 29, 2008 NO. 2007-1823 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle PA 17013 717-249-3166 submitted: & Felix, A.P.C. Date: May 29, 2008 Gregg L Morris, Esquire 213 E. Main Street Carnegie, PA 15106 (412) 429-7675 PA_111 10 Day D1 P&F File No. 762.4103 I, GREGG MORRIS, attorney for Plaintiff, CAPITAL ONE BANK, hereby certify that a true and correct copy of foregoing document was served this date by ordinary mail upon the following: Shawn House 1 E. First St Boiling Springs PA 17007--244 Date: May 29, 2008 6X g L. Morris, Esquire atenaude & Felix, A.P.C. 213 E. Main Street Carnegie, PA 15106 (412) 429-7675 PA_l 11 10 Day Dl P&F File No. 762.4103 X 'D d - - v IQ. Pe) C_? - :.C J CV) Ilk LLJ C1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CAPITAL ONE BANK Plaintiff NO. 2007-1823 V. SHAWN HOUSE Defendant(s) NOTICE OF ORDER, DECREE OR JUDGMENT Filed on behalf of: CAPITAL ONE BANK Counsel of Record for This Party: Gregg L. Morris, Esquire Pa I.D. #69006 Patenaude & Felix, A.P.C. 213 E. Main Street Carnegie, PA 15106 (412) 429-7675 PA_123 Ntc Jgmt Both P&F File No. 762.4103 C IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CAPITAL ONE BANK Plaintiff V. SHAWN HOUSE Defendant(s) NO. 2007-1823 NOTICE OF ORDER. DECREE OR JUDGMENT AGAINST SHAWN HOUSE ONLY TO: ( )Plaintiff ( x )Defendant ( )Garnishee ( )Additional Defendant You are hereby notified that the following Order, Decree, or Judgment has been entered against you on ,r_t_ / 3 ,? d d ( ) Decree Nisi in Equity ( ) Final Decree in Equity ( X) Judgment of ( ) Confession ( ) Verdict ( ) Court Order ( X) Default ( ) Non-suit ( ) Non-Pros ( ) Arbitration Award ( X) Judgment in the amount of $1,456.47, plus costs. ( ) District Justice Transcript of Judgment in the amount of $ , plus costs. ( ) If not satisfied within sixty (60) days, your motor vehicle operator's license will be suspended by the Department of Transportation. Prothonotary By r If you have questions concerning the above, please Contact: Name of Attorney: GREGG MORRIS, Esquire 213 East Main St Carnegie PA 15106 (412)-429-7675 PA_ 123 Ntc Jgmt Both P&F File No. 762.4103