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Home My WebLink About07-2031 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff No: 0~f -. ~03 ~~ ~~, (., vs. COMPLAINT IN CIVIL ACTION FRANCESCA CORDEIRO 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 ~ 05677930 C N Pit BNT 4 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. Civil Action No FRANCESCA CORDEIRO 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 140 EAST SHORE DR GLEN ALLEN VA 23059 . 2. Defendant is adult individual(s) residing at the address listed below: FRANCESCA CORDEIRO 512 PORSHA TER CAMP HILL, PA 17011 3. Defendant applied for and received a credit card bearing the account number 4862362418639384 . 4. Defendant made use of said credit card and has a current balance due of $1202.99 as of March 15, 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 25.9000 per annum on the unpaid balance from March 15, 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 FRANCESCA CORDEIRO INDIVIDUALLY in the amount of $1202.99 with continuing interest thereon at the rate of 25.900% per annum from March 15, 2007 plus costs. James C arm~odt,42524 WELT EINBERG & REIS CO., L.P.A. 436 S ent Avenue, Suite 2718 Pitts urgh PA 15219 (412 434- 955 FAX• 412- 38-7130 056 7930 N Pit BNT This law firm is a debt collector att¢mpti g to collect this debt for our client and any information obtai ed 11 be used for that purpose. First 3 months half-price .; '' 7 a mtxttlr ~.95/mo. thereafter' SIGN UP TODAY: ' 1-877-778-1207 Mention Offer Code: ONYX Or vtsft www.peoplepc.com/go/onyx 003 peoplepc®online u Abetter way to Internet. PeoplePC Online offers the features you would expect from higher-priced Internet Service Providers at half price for the first 3 months! ® FJrlail Virus Protection ® Pop-Up BlockerT"" ~j 5pam Controls Smart Dialer Phisher Security Internet Call Waiting Capital~° Account S Previous Balance E820.32 Payments, Credits and Adjustments 5.00 Transactions 129.00 Finance Chazges E18.24 New Balance (867.56 Minimum Amount Due E867.56 Payment Due Date October 15, 2005 Total Credit Line SS00 Total Available Credit E.00 Credit Line for Cash E500 Available Credit for Cash 5.00 At yotu service To all Customer Rdat"ans or to report a lost or stolen nrd: 1-800-903-3637 Srnd payments to: Send inquiries to: Attn: Remittance Proorssing C.piml One Bank Capital One P.O. Box 790216 P.O. Box 30285 St Louis, MO 63179-0216 SLC, i1T 84130-0285 ]moorrant Account Information Twelve unsung heroes of college atldetics aze competing for the honor of Capital One National Mascot of the Yeaz -and you can help deade who wins! Each week, the mascots go head-to-head in competition, but only one will win the coveted title and ft0,000 for their school. Go to capitalone.com where you ran vote daily for your favorite mascot -and don't forget to mne in to the Capital One Bowl on ABC on Monday, January 2, 2006, to see who wins! rt I' mante C•.e.b.,o Plrare ra reverse iidefor important information Bd resat. Pia C rp~.dmd FINANCE ` ` w gepludm ~ +aer APR ~ I-j~I~~ E PURCHASES f72211 tO .07096% 25.90% (15.89 CASH (106.78 .07096% 25.90% 1235 ANNUAL PERCENTAGE RATE applied this period 25.90% • PLEASE RETURN PORTION BELOW WITH PAYMENT ~~`~~~~~ 0000000 0 4862362418639384 15 0867560020000867566 New Balance (867.56 Minunum Amount Due E867.56 Payment Due Date October 15, 2005 Total enclosed f Accoant Number: 4862-3624-1863-9384 Pleauprar mailiag ad~r:: and r-mailrA~msdv &loru asing brae o. b/aoF ink Sve<t Ape i Cry Seam ZIP Home Phone Alarnare Phone Email Address ~_ #9025930908157803# MAIL ZD NUMBER Capital One Bank FRANCESCA CORDEIRO P.O. Box 790216 ~s~u~si~r~~u~i~si~i~ 512 PORSHA TER St. Louis, MO 63179-0216 ~ ~ CAMP HILL PA 17011-1266 ~r~~uu~~uu~~~ur~~r~u~~uui~i~us~~i~~uui~~r~~u~n~s~ ° ~ P/ears writeyour account number orsyoro flitrk or money order modspayab/e to Capital One Bank and mail in t/x ear/aredenvelope. PLATINUM VISA ACCOUNT 4662-3624-1863-9384 AUG 16 -SEP 15, 2005 Page 1 of 1 Payments, Credits and Adjustments Transactions 1 75 SEP PAST DUE FEE E29.00 You were assGSSed a past due fee of 129.00 on 09/] 5/2005 because your minimum paymem was not recimd by the due daze of 09/15/2005. To avoid this fee in the future, we recommend that you allow at least 7 business days for your payment to reach Capital One. l t~~ VERIFICATION CAPITAL ONE BANK vs CORDEIRO, FRANCESCA The undersigned does hereby verify subject to the penalties of 18 Pa.C.S. Section 4904 relating to unswom falsification to authorities, that he/she is, MAISHA DAMS, Authorized Agent, of CAPITAL ONE BANK, Plaintiff Herein, that he/she is duly authorized to make this Declaration, and that the facts set forth in the foregoing Complaint in Civil Action are true and correct to the best of his/her knowledge, information and belief. MAISHA DAMS ~'..~ Notary is MYRA PRINDLE Notan~ Public Gwinnett Gounty Georgia Mt7 Gomrnission Expires July 31st 2009 4862362418639384 A049 WELTMAN, WEINBERG & REIS CO., L.P.A. ~ n V A~ - V (V Q '6'4 V ^\ zJ a r- r.~P ra `.~ .~-q ~ ^TJ i v r't~ ~-n_--- f T Z Jv {::~ -3~ :__~'~n "~ 0 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. FRANCESCA CORDEIRO Defendant No. 07-2031-CIVIL PRAECIPE FOR DEFAULT JUDGMENT 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. 436 Seventh Avenue, Suite 2718 Pittsburgh, PA 15219 (412) 434-7955 FAX: 412-338-71305 WWR#05677930 Judgment Amount $ 1,280.67 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. FRANCESCA CORDEIRO Defendant TO THE PROTHONOTARY: Civil Action No. 07-2031-CIVIL PRAECIPE FOR DEFAULT JUDGMENT Kindly enter Judgment against the Defendant, FRANCESCA CORDEIRO above named, in the default of an Answer, in the amount of $1,280.67 computed as follows: Amount claimed in Complaint $1,202.99 Interest from March 15, 2007 to June 13, 2007 at the interest rate of 25.900% per annum $77.68 TOTAL $1.,280.67 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. ar brodt, Esquire PA I.D. 425 4 WEL M ,WEINBERG &REIS CO., L.P.A. 436 vent Avenue, Suite 2718 Pit bur , PA 15219 (4 2) 4 4-7955 A .412-338-71305 W R#05677930 Plaintiff s address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7~` Avenue, Pittsburgh, PA 15219 And that the last known address of the Defendant is: 512 PORSI lA TER CAMP HiLL,PA 17011 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. Civil Action No. 07-2031-CIVIL FRANCESCA CORDEIRO Defendant NOTICE OF JUDGMENT OR ORDER TO: ( )Plaintiff (xx) Defendant ( )Garnishee You are hereby notified that the following Order or Judgment was entered against you on J ~.OU? (xx) Assumpsit Judgment in the amount of $1,280.67 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 T~_aL _~ _~_~. FRANCESCA CORDEIRO 512 PORSHA TER CAMP HILL,PA 17011 Plaintiff s address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7`" Avenue, Pittsburgh, PA 15219 I-888-434-0085 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff Case # ~Z~'~,Q.~/'~,(~l FRANCESCA CORDEIRO Defendant(s) IMPORTANT NOTICE TO: FRANCESCA CORDEIRO 512 PORSHA TER CAMP HILL,PA 17011 Date of Notice: ~ ~~~ WWR#: 05677930 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 PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE FOLLOWING 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 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 BY ~ Via! ~.cc--~ ~~tO~tG~C1 INfx~ (~YU,~'--~ PATRICK THOMAS WOODMAN PA I.D. #34507 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 KOPPERS BLDG, 436 7TH AVE. PITTSBURGH, PA 15219 IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. FRANCESCA CORDEIRO Defendant Case no: 07-2031-CIVIL 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, FRANCESCA CORDEIRO 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, FRANCESCA CORDEIRO is not in the military service. Further Affiant sayeth naught. AFFIAN SWORN T AND SU SC IBED in my presence this ~ day of COiVIiNONWEALTH':'t~- ~k.i\^<JYLVAI~ie%ti Notary ;_'< tti~ NOT PUBL Wayne A Jcnrss, ~ ~ °~tary Public City Of Pittsburgr3, : +,~ ~heny County Wy Commission Expir~> June 29, 2D10 Member, Pennsylvania Assaclatlon of Notaries This law firm is a debt collector attem g 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 Military Status Report Pursuant to the Servicemembers Civil Relief Act Page 1 of 2 JUN-14-2007 07:22:54 < Last Name First/Middle Begin Date Active Duty Status Service/Agency CORDEIRO FRANCESCA 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. ~ ~. ~y-~- 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:h_ttp://www.defenselink.mil/faq/pis/PC09_SLDR,html 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 6/14/2007 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.•BXZLOBDJMFK https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 6/14/2007 Request for Military Status Department of Defense Manpower Data Center Military Status Report Pursuant to the Servicemembers Civil Relief Act Page 1 of 2 J[JN-14-2007 07:22:54 ~C Last Name First/Middle Begin Date Active Duty Status Service/Agency CORDEIRO FRANCESCA 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. ~~ ~-~- 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: http://www.defenselink.mil/faq/pis/PC09SLDR.htm1 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 6/14/2007 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: BXZLOBDJMFK https://www.dmdc.osd.miUscra/owa/scra.prc_Select 6/14/2007 ~ ~ r 0 ~~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~- t"1 ~ p z~:: ~ ~, ~. ~.:. ~. ~~ -~- _n ^#,~ ( , V %i -~ ~1 ` _4~ :`..J _~-y. • t:- • ~~.. ply ~~ SHERIFF'S RETURN - REGULAR CASE NO: 2007-02031 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CAPITAL ONE BANK VS CORDEIRO FRANCESCA MICHAEL BARRICK Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon CORDEIRO FRANCESCA the DEFENDANT at 1909:00 HOURS, on the 24th day of April 2007 at 512 PORSHA TERRACE CAMP HILL, PA 17011 by handing to FRANCESCA CORDEIRO 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 Service Affidavit Surcharge 18.00 14.40 .00 10.00 So Answers: _ .~f .~ -~~ ~. ~~ 42.40 Sworn and Subscibed to before me this day of , R. Thomas Kline 04/26/2007 WELTMAN WE INBE E I S _...-~ By : ~~~/ A.D. riff