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Home My WebLink About07-2165IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. JILL BLOOR Defendant ~~ v ~~ ~~.~-~ COMPLAINT IN CIVIL ACTION 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 05781565 C N Pit BNT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. Civil Action No JILL BLOOR 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: JILL BLOOR 6 BRIAR LN CAMP HILL, PA 17011 3. Defendant applied for and received a credit card bearing the account number 5178052313289932 . 4. Defendant made use of said credit card and has a current balance due of $1118.15 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 27.7400 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 JILL BLOOR INDIVIDUALLY in the amount of $1118.15 with continuing interest thereon at the rate of 27.740% per annum from March 15, 2007 plus costs. ~/ Y L/" - James Warmbrodt,42524 WELT WEINBERG & REIS CO., L.P.A. 436 ev nth Avenue, Suite 2718 Pit sbu gh, PA 15219 (4 2) 34-7955 F 4 2-338-7130 5781 65 C N Pit BNT This law firm is a debt collector to ting to collect this debt for our client and any information obt ed will be used for that purpose. The Deal You've Been Waiting for ... MOTOROLA l~'AZR V3 > fREE" Wireless Camera Phone '~°"`°~`~°~'~`~"~~'"""` > BONUS free Bluetooth® Headset (~60 ValueJ > fREE Shipping & Handling ~~~~ ~ ~~Xcing~la~r~~r~~_ V~%IREFLY ~ ~ ACT NOW Limited Time Offer ' f~cardno~i~e°,~~ 003 Capita/Q~• AcxountSu Previous Balance 1757.62 Payments, Credits and Adjustments 1,00 Transactions 129.00 Finance Chazges 117.47 New Balance 5804,Oq Minimum Amount Due 1804.09 Payment Due Date November 15, 2005 Total Credit Line 1300 Total Available Credit 1.00 Credit Line for Cash 1300 Available Credit for Cash 1,00 At your service To call Customs Re6tiona or to report. lost or atolm nrd: 1-800-955-7070 seta pa7ments t.: sa,a iny~tiria to: Attn: Remittance Procssing Ca}dtal Onc Bank Capital One P.O. Box 790216 P.O. Box 30285 St. Louis, MO 63179-0216 SLC, UT 84130-0285 Important Aaount Infomtation Twelve unsung heroes of college athletics aze Competing for the honor of Capital One National Mascot of the Yeaz -and you can help decide who wins! Each week, the mascots go head-to-head in competition, but only one will win the coveted title and 110,000 for the'v school Go to capitalone.com where you ran vote daily for your favorite mascot -and don't forget to tune in to the Capital One Bowl on ABC on Monday, January 2, 2006, to see who wilts! PLATINUM MASTERCARD ACCOUNT 5178-0523-]328-9932 SEP 16 - OCT 15, 2005 Page 1 of 1 Payments, Credits and Adjustments Transactions 1 15 OCT PAST DUE FEE 129.00 We appreciate your business and you deserve great benefits. We'd like you to know that your Platinum card benefits have been updated. For details, visit www.rapitalone.com/Qeditrardsancl click on the Guide to Benefits link. Thanks for choosing Capital One. You were assessed a past due fee of 129.00 on 10/15/2005 because your minimum payment was not received by the due date of 10/15/2005. To avoid this fee in the future, we recommend that you allow at least 7 business days for your payment to reach Capital One. EXHNBIT I Fina11Ce C}11rp'ea Pleare tee reverit.ridc for inaporront infOrm~ion Bal Tarr Pniod Cwrrpondmg ~~E ~ n geplud m .dr APPR $ ro PURCHASES CASH 5766.02 ,07600%P 27.74% 517.47 5.00 .07600%P 27.74% s,00 ANNUAL PERCENTAGE RATE applied this period 27.74% • PLEASE RETURN PORTION BELOW WITH PAYMENT ,~~ 0000000 0 5178052313289932 15 08040 90015000804091 New Balance f804 Oq Minimum Amount Due 1gOq Og Payment Due Date November 15, 2005 Total enclosed t Account Number: 5178-0523-1328-9932 Plracrprint mailing ad~rsso~ r-nrailrhmges br! mind bl or bbrk rnk avert Ape ;F Gry Scan Zlp Home Phone Alrsnate Phone ~ #9028912900121869# MAIL ID NUMBER Capital One Bank ~ JILL BLOOR P.O. Box 790216 ~t~n~u~~uu~~~r~ra~ n ~ 6 BRIAR LN St. Louis, MO 63179-0216 irri ~ CAMP HILL PA 17011-7903 ~t~~un~~uu~~~tu~~t~u~~nut~t~ur~~r~~uut~~t~~u~n~r~ ° ~~ Pleart write ygty arrount number on yoty rhxk or money ordn made payable to Capita! OncBaakand mail in the rnclared rnvelope. r ~' VERIFICATION CAPITAL ONE BANK vs BLOOR, JILL 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 DAVIS, 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 ace true and correct to the best of his/her knowledge, information and belief. MAISHA DAVIS No b is MYRA PRINDLE Notary Public Gwinnett County Georgia ~~y Commission Expires July 31st 2009 5178052313289932 A049 WELTMAN, WEINBERG & REIS CO., L.P.A. N ~V `~ ~Q G'"1 ~- ,•..~ r _-~ ~, -. ~.~:s n1 ._.., r.~ t~ u~r rj ='n ---~ -rt rye. ~j i '. rt v :._, (T'1 -+ -c SHERIFF'S RETURN - REGULAR CASE NO: 2007-02165 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CAPITAL ONE BANK VS BLOOR JILL MICHAEL BARRICK Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE BLOOR JILL was served upon the DEFENDANT at 6 BRIAR LANE at 1605:00 HOURS, on the 24th day of April 2007 CAMP HILL, PA 17011 ROY BLOOR, HUSBAND by handing to 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 ~/a ~ 101 ~,,, 41.4 4 Sworn and Subscibed to before me this day So Answers: R. Thomas Kline ~.lf 04/25/2007 WELTMAN WEINBERG R ,,~ i By. De uty Sherri of A.D. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. JILL BLOOR Defendant No. 07-21.65-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#05781565 Judgment Amount $ 1,195.48 THIS LAW FIRM IS ATTEMPTING TO COLLECT THIS DEBT FOR ITS CLIENT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. r IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. JILL BLOOR Defendant TO THE PROTHONOTARY: Civil Action No. 07-2165-CIVIL PRAECIPE FOR DEFAULT JUDGMENT Kindly enter Judgment against the Defendant, JILL BLOOR above named, in the default of an Answer, in the amount of $1,195.48 computed as follows: Amount claimed in Complaint $1,118.15 Interest from March 15, 2007 to June 14, 2007 at the interest rate of 27.740% per annum $77.33 TOTAL $1.,195.48 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. ~ a brodt, Esquire PA I.D. 425 4 WEL AN WEINBERG & REIS CO., L.P.A. 436 s venth enue, Suite 2718 Pitt urgh, A 15219 (41 ) 434- 955 F X: 2-338-71305 W 05781565 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: 6 BRIAR LN CAMP HILL,PA 17011 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. JILL BLOOR Defendant Civil Action No. 07-2165-CIVIL NOTICE OF JUDGMENT OR ORDER TO: ( )Plaintiff (xx) Defendant ( )Garnishee You are hereby notified that the following Order or J dgment was entered against you on 'l (xx) Assumpsit Judgment in the amount of $1,195.48 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 Prothonotary By: PR T NOTARY ) JILL BLOOR 6 BRIAR LN CAMP H1LL,PA 17011 Plaintiffs address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7`h Avenue, Pittsburgh, PA 15219 1-888-434-0085 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff JILL BLOOR Defendant (s) IMPORTANT NOTICE TO: JILL BLOOR 6 BRIAR LN CAMP HILL,PA 17011 Date of Notice: ~ o WWR#: 05781565 Case # ~~~~(CfZ~ C,(~I 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 : ~~.~~%G~rrv~ad ~D~-- 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. JILL BLOOR Case no: 07-2165-CIVIL NON-MILITARY AFFIDAVIT Defendant The undersigned, who first being duly sworn, according to law, deposes and states as follows: That helshe 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, JILL BLOOR 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, TILL BLOOR is not in the military service. Further Affiant sayeth naught. AFFIANT SWORN` TO AND SUB CRIB Din my presence this ~hday of Q 11~,VL.Q, ~l• ~ ~ COMMONWEAr_TF{ Qr ?E~i.~Yt_VANiA - Nota~a"' *.-c q- Y PUB- Wayne A. Jor+es, ~'°~sfary Public City Of Pittsburgh, r!I"9~Y ~tY My Commission Expires, June 29, 2010 Member, Pennsyivani~ assc;c+atinn bf Not~M« This law firm is a debt collector attempting 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 06:28:27 ~C Last Name First/Middle Begin Date Active Duty Status Service/Agency BLOOR JILL 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: httpa/www.defenselink`mil/faq/pis/PC09SLDR.html WARNING: This certificate was provided based on a name and Social Security number (SSN) provided https://www.dmdc.osd.mil/scralowa/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: VOYVACNFHX https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 6/1412007 N T` '~ ~, ~ a t r~ (}~,',~~ row, ~'J ~~: ' ~ ~ ~...~ "D y~ ! ~ ~ ~ ~ ~ ~~ ~~~ ~ ~~ ~ ~ ~ ~, .~-- ::~