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Home My WebLink About07-2163~ ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff No• (~^J ~~/ `~ / Lv~C,~~Q.. v s . 1.... ~'Y~ COMPLAINT IN CIVIL ACTION J GEORGE W GREEN 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 05801982 C N Pit CXC i i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. Civil Action No GEORGE W GREEN 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 T 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: GEORGE W GREEN 5151 E TRINDLE RD MECHANICSBURG, PA 17050 3. Defendant applied for and received a credit card bearing the account number 5178052181147527 . 4. Defendant made use of said credit card and has a current balance due of $1454.95 as of March 19, 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 27.7400 per annum on the unpaid balance from March 19, 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 GEORGE W GREEN INDIVIDUALLY in the amount of $1454.95 with continuing interest thereon at the rate of 27.740°s per annum from March 19, 2007 plus costs. Jame C. Warmbrodt,42524 WELT WEINBERG & REIS CO., L.P.A. 436 ev th Avenue, Suite 2718 Pit sbu gh, PA 15219 (4 ) 34-7955 F 2-338-7130 0 80 982 C N Pit CXC This law firm is a debt collector at~npting to collect this debt for our client and any information obtained will be used for that purpose. Y •: ~ peoplepcrM online ~ Abetter way to Internet. J Su-f up to 5x fastert~, d FREE Accelerator car a,e cast 1s trtarttna+-a d6o va~kred i -888-587-9669 ~~ a Mention Offer Code: DOLLAR _~ Visit www.peoplepc.cotn/go/dollar Capita/iDy~• Account S Previous Balance i1,016.D8 Payments, Credits and Adjustments Y.DO Transarlions 535.00 Finance Chazges 523.42 New Balance 11,074.50 Minunum Amount Due =1,074.50 Payment Due Date January 07, 2006 Total Credit Line f600 Total Available Credit 5.00 Credit Line for Cash f600 Available Credi[ for Cash 5.00 At yottr service To ®B Customer Relations or to report a lost or rtolm card: 1-800-903-3637 UNLIMITED INTERNET ACCESS PeoplePC Online offers the features you would expect from higher-priced Internet Service Providers, including: ® V rus Protection powered by symarttect"1 ® Pop-Up BlockerT"' `~ Spam Controls ~r Smarter Smart Dialer Technology ®~ More Email Addresses ® ~` Internet Call Waiting PLATINUM MASTERCARD ACCOUNT 5178-0521-8114-7527 NOV OS -DEC 07, 2005 Page 1 of 1 Payments, Credits and Adjustments Transactions 1 07 DEC PAST DUE FEE 535.00 As a valued Capital One customer, you are eligible [o receive a free Year-End Summary for this specific account thaz recaps your 2005 rhazges, provided your account is in good standing and you have made transactions during the calendaz year. Please call 1-677-794-4487 before January 31, 2006, to reserve your copy for this account Orders will be mailed out by the end of February 2006. We appreciate your business and you deserve great benefits. We'd like you to know that your Platinum card benefits have been updated. For derails, visit www.capitalone.com/Qeditcards and dick on the Guide to Benefits link. Thanks for choosing Capital One. You were assessed a past due fee of (35.00 on 12/07/2005 because your minimum payment was not received by the due daze of 12/07/2005. To avoid this fee in the future, we recommend that you allow at least 7 business days for your payment to reach Capital One. For 6-ee online account service and apeaal watomec offrn, log on to: vaww.npitdonemm Send paymrnu to: Send inquiries to: ~~ ~ ~ ~~ Attn: Remittance Processing Capital One Bank Capiml One P.O. Box 790216 P.O. Box 30285 St Louis, MO 63179-0216 SLC, UT 84130-0285 I Important Account Information lt's Capital One Bowl week tune again! Tune in to ESPN and ESPN2 starting on December 20 for the best in post-season college football action to see your favorite teams fight for bowl championships. And on January 2 at 1 pm (ET), be sure to tune into ABC to watdr the Capital One Bowl live from Orlando, Florida! Finance Charges i or imfortant information Pltare ire reun s t s & j Ba! «rarr Prriadr C o ,, ~ p , ~ ~8 ~~~ m geplirdm rmr .fP R °f PURCHASES 51,027.35 .07600%P 27.74% 523.42 m CASH 5.00 .07600%P 27.74% 1.00 ANNUAL PERCENTAGE RATE applied this period 27.7496 • PLEASE RETURN PORTION BELOW WITH PAYMENT ~Onea 0000000 0 5178052181147527 07 1074500018001074506 New Balance 11,074.50 Minimum Amount Due 11,074.50 Payment Due Date January 07, 2006 Total enclosed f Account Number: 5178-0521-8114-7527 Capital One Bank P.O. Box 790216 ~t~u~~~ut~~nr~ur~~ St. Louis, MO 63179-0216 '1'I IIrrII IIII~I'ItII II III II11111'1'IrIIIIIIII IIIIIII'11IIIII Pleare rwitcyoro acrovnt number on yvsa Pkasrpriat mailiaga~uanb e-mail rhmcgu brlam asorg bl wb! kiaE Sveer Apc R Gry Snu ZIP Home Phone Almrmre Phone Fmsi1 Address ~ #9034273433102799# MAIL ID NUMBER GEORGE W GREEN ~ 5151 E TRINDLE RD ~ ~ MECHANICSBURG PA 17050-3624 m o ~ check or money order made Payable to Captal One Bank and mail in tbt rntlorrd envdoft. r iR~~ VERIFICATION CAPITAL ONE BANK vs GREEN, GEORGE W 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, WONDA BROOKS, 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. ~i~h9r~ . 4~.~~s., UVONDA BROOKS iurrwQ PRnvoEE Notary Public Gwinnett County Georgia MY Commission Expires July 31st 2009 -i~ Notary P is 5178052181147527 A049 WELTMAN, WEINBERG & REIS CO., L.P.A. t ~ `'~ Z ~ r, ~ ~-, ~ _~ ~.J a ~'"+ -fir ~J fjf'?'i ,~; `" '' ~ _, ~ ,, _r _,„ ~~r'i ~~ .. c: z -;;~ ~v ~ SHERIFF'S RETURN - REGULAR CASE NO: 2007-02163 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CAPITAL ONE BANK VS GREEN GEORGE W KENNETH GOSSERT Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon GREEN GEORGE W the DEFENDANT at 1904:00 HOURS, on the 23rd day of April 2007 at 5151 E TRINDLE ROAD MECHANICSBURG, PA 17050 by handing to GEORGE GREEN 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 18.00 Service 13.44 Affidavit .00 Surcharge 10.00 .00 5~?~f~o~ ~ ~ 41 .44 Sworn and Subscibed to before me this day of , So Answers: R. Thomas Kline 04/24/2007 WELTMAN WEINBERG REIS By: PuJ! Y A.D. t w IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. GEORGE W GREEN Defendant No.07-2163 CIVIL TERM PRAECIPE FOR ENTRY OF JUDGMENT BY CONSENT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molzcan, Esquire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412)434-7955 WWR#05801982 IN THE COURT OF COMMON P~,EAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DNISION CAPITAL ONE BANK Plaintiff vs. GEORGE W GREEN Defendant Civil Action No. 07-2163 CIVIL TERM PRAECIPE FOR JUDGMENT BY CONSENT TO THF. PROTHONOTARY Kindly enter Judgment against Defendant, GEROGE W GREEN, in the amount of $1490.88 plus costs, based upon the consent of the parties. CONSENTED TO: .: ~. WELTMAN, WEINBERG & REIS CO., L.P.A., GEORGE W GREEN, By•' By; ~i Attorney for Plainti Defendant WWR#05801982 - IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. Civil Action No. 07-2163 CIVIL TERM GEORGE W GREEN Defendant STIPULATION OF THr PARTIES FOR PAYMENT AND FOR THE ENTRY OF JUDGMENT BY CONSENT TO THE PROTHONOTARY: Kindly enter Judgment in favor of Plaintiff and against the Defendant, GEORGE W GREEN, above-named, in the amount of $1490.88 pursuant to the Stipulation of the Parties for Payment and for the Entry of Judgment by Consent, as follows: Defendant admits indebtedness to Plaintiff in the amount of $1490.88 with continuing interest thereon at a rate of 6.0% per annum plus costs from JULY 10, 2007. 2. To secure the repayment of said indebtedness, Defendant agrees that Judgment by Consent will be entered in favor of the Plaintiff and against the Defendant, GEORGE W GREEN, in the amount of $1490.88 plus continuing interest thereon at the rate of 6.0% per annum from JULY 10, 2007 and costs. Plaintiff agrees not to execute on its Judgment so long as Defendant causes to be delivered to Plaintiff the following payments in full by 12:00 NOON on the following dates: (a) $100.00 due by 5/25/07; (b) $100.00 due on the 25TH day of each consecutive month thereafter until the Judgment amount plus accrued interest and costs are paid in full. 4. :All payments are to be made pay`ble to the order of "CAPITAL ONE BANK" 5. All payments due under this agreement are to be received at the offices of Weltman, Weinberg & Reis, Co., L.P.A., 2718 Koppers Building, 436 Seventh Avenue, Pittsburgh, PA 15219. 6. In the event of default, each payment received shall be first attributed to costs, interest and then to principal. 7. Time is of the essence of this agreement and should the Defendant fail to have in the hands of Plaintiff or Plaintiff's counsel any paymentin full within five (5) calendar days of the stated due date, then Plaintiff shall be immediately free to issue Execution as well as pursue all other remedies, in law or in equity, to collect the full balance of the Judgment entered hereunder plus appropriate additional interest and costs. 8. No act or omission of the Plaintiff, nor of anyone alleged to be acting on its behalf, shall constitute a waiver, estoppel, or any other excuse for non-performance of any duty undertaken by the Defendant in this Stipulation ,~ which the parties, agree is final and complete. 9. Intending to be legally bound, the parties set their hands and seals this _day of , 20 ~~• WELTMAN, WEINBERG & REIS CO., L.P.A. w ~~ By: ~~ V ' Will am T. Molczan, uire • PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue ' Pittsburgh,PA 15219 •~ (412) 434-7955 WWR No. 05801982 By: Defendant, ROGE W GREEN "%i •~ . IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff GEORGE W GREEN Defendants} IMPORTANT NOTICE TO: GEORGE W GREEN 5151 E TRINDLE RD MECHANICSBURG, PA 170'Sn0 I~ Date of Notice : ~X r 0'' WWR#: 05801982 ~~ Case # ~~' /`IIY~~C~~~`~ 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: PATR CK T OMAS WOODMAN PA .D. #34507 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 KOPPERS BLDG, 436 7TH AVE. PITTSBURGH, PA 15219 "~, n C~ ~ ~- .~ ~* v i~. ~ _ i. ~ ~ - { .._ OO ~ ~ ~ ~~ `- a ~ -F-; ~`~ C7 'j ~'.~' ` c --~ c:^s IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CML DIVISION CAPITAL ONE BANK Plaintiff vs. Civil Action No, 07-2163 CIVIL TERM GEORGE W GREEN Defendant NOTICE OF JUDGMENT OR ORDER TO: ( )Plaintiff (xx) Defendant ( )Garnishee You are hereby notified that the following Order or Jud~.ment was entered against you on ~ p (xx) Assumpsit Judgment in the amount of $1490.88 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 ( ) Default ( ) Verdict ( ) Arbitration ( ) Award (XX) By Consent Prothonotary GEORGE W GREEN 5151 E TRINDLE RD MECHANICSBURG,PA 17050 By: s ~ ~.. Q~ PRO H NOTARY (OR DE TY) c~' _,, ~, xM ~-; ca w c.tr