The URL can be used to link to this page

Home My WebLink About07-2479IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. KENDRA GOTSHALL Defendant No : Q 7 - ~~ 7 C'~.L`T~ 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 05815389 C N Pit CXC IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. Civil Action No KENDRA GOTSHALL 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: KENDRA GOTSHALL 1111 YVERDON DR APT #B3 CAMP HILL, PA 17011 3. Defendant applied for and received a credit card bearing the account number 5178052424135503 . 4. Defendant made use of said credit card and has a current balance due of $1189.01 as of March 30, 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 30, 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 KENDRA GOTSHALL INDIVIDUALLY in the amount of $1189.01 with continuing interest thereon at the rate of 25.900 per annum from March 30, 2007 plus costs. James ., Warmbrodt,42524 WELT WEINBERG & REIS CO., L.P.A. 436 S e th Avenue, Suite 2718 Pitts ur h, PA 15219 (412) 4 4-7955 FAX: 41 -338-7130 058 3 9 C N Pit CXC This law firm is a debt collector atte ing to collect this debt for our client and any information obtaine will be used for that purpose. Surf up to 5x fastert4~t a FREE Aooelerator for the rust 12 monthst-a A60 vahte! 1-888-587-9669 'I Mention Offer Code: COIN Vsit www.peoplepc.com/golcoin 003 UNLIMITED INTERNET ACCESS PeoplePC Online offers the features you would expect from higher-priced Internet Service Providers, including: ® Virus Protection Powered by symantecr'^ ® Pop-Up BlockerT"" `~j Spam Controls ® Smarter Smart Dialer Technology ®~1 More Email Addresses ®~ Internet Call Waiting Capita/Q~a Account Sum Previous Balance E830.68 Payments, Credits and Adjustments 5.00 Transactions E29.00 Finance Charges (18.47 New Balance 5878.15 Minimum Amount Due E878.15 Payment Due Date December 15, 2005 Total Credit Line (400 Total Available Credit E.W Credit Line for Cash E400 Available Credit for Cash E.00 AL your service To all Customs Relations or to report a lose or stolen ard: 1-800-903-3637 Send payments to: Send inquitis to: Attn: Remitronm Processing Capital One Bank Capihl On< P.O. Box 790216 P.O. Box 30285 St Louis, MO 63179-0216 SLC, UT 84130-0285 PLATINUM MASTERCARD ACCOUNT 5178-0524-2413-5503 OCT 16 - NOV 15, 2005 Page 1 of 1 P~ents, Credits and Adjustments Ttartsactions 15 NOV PAST DUE FEE Take control and pay your Capital One credit card bill online for Gee. Eliminate the hassle of writing checks, finding stamps and sealing envelopes. Everything you need to access, review and pay your bill is available online. Our Web site offers you a conveaieny simple and secure way to manage your account. Veit vvww.capitalone.com and register your account to start simplifying your life today! As a valued Capital One cus[omey you are eligible to receive a free Year-End Summary for this specific accoum that recaps your 2005 dtarges, provided your account is in good standing and you have made transactions during the calendaz year. Please call 1-877-794-448J before December 31, 2005, to reserve yoty copy for this account. We will begin proassirg orders in January 2006. We appreciate your business and you deserve great benefice We'd like you to know that your Platinum card benefits have been updated. For details, visit www.capitalone.com/Qeditcardscrnd dick on the Guide to Benefits link. Thanks for choosing Capital One. You were assessed a past due fee of E29.00 on 11/15!2005 because your minimum payment was not received by the due date of 11/15/2005. To avoid this fee in the future, we recommend that you allow at least 7 business days for your payment to reach Capital One. EXHI61! E29.00 'I`manCe CI11rgeS PJeare ru resew<nde for important information Bd rr ~r Aniodl'r Ceerrryaadag ~I~E rn yeplirdto ror< APPR E m PURCHASES 5839.58 .0709691 25.90% 718.47 CASH 5.00 .07096% 25.90% 5.00 ANNUAL PERCENTAGE RATE applied this period 25.90% • PLEASE RETURN PORTION BELOW WITH PAYMENT ~~~` j~~~ 0000000 0 5178052424135503 15 087815 0050000878153 New Balance E878.15 Minimum Amount Duc (878.15 Payment Due Date December 15, 2005 Total enclosed f Aaount Number: 5178-0524-2413-5503 PGasefrimtm~ilingadafersany r-mailrbmgesbr! usingbGuo.Starkink Apc ;/ l:iry Sna ZiP Home Phone Alternate Phone ~ #9032006621515758# MAiL ID NUMBER Capital One Bank ~ KENDRA GOTSHALL P.O. Box 790216 Islnlnllulullalatl 1028 MILL RD St. Louis, MO 63179-0216 ~ ~ MECIIANICSBURG PA 17050-2126 Itlltaatllt.atlllttttill„Iltttttltlattlltlltttaalfallttitalal Please tarite yov account number on ymv rl~etk m money order made payable to Capita! One Bank and mail in t/x eraJared envelope. peoplepc~ online ~ Abetter way to Internet. r ~~~ w' 5 ., r VERIFICATION CAPITAL ONE BANK vs GOTSHALL,KENDRA 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, UVONDA S 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. -- ~ ~. --- UVONDA SBROOKS otary~ is MYRA PRINDLE Notary Public Gwinnett County Georgia My Commission Expires July 31st 2009 5178052424135503 A049 WELTMAN, WEINBERG & REIS CO., L.P.A. /~.) ~ V Q ~J n c _~„ ;- t r -. ~ _ f ,' -c __ i r~ f_ _. N ~_ a -.J °- K.+ 7 .~ (rf~l 0 -~, ~~ R1 ~ ~J a fT~1 -t'+ /.~' /~~~ W ~ :yy "~ SHERIFF'S RETURN - NOT FOUND CASE NCO: 2007-02479 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CAPITAL ONE BANK VS GOTSHALL KENDRA 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 GOTSHALL KENDRA but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT & NOTICE the within named DEFENDANT GOTSHALL KENDRA 1111 YVERDON DR APT #B3 CAMP HILL. PA 17011 PER LEASING OFFICE, DEFENDANT LIVES AT 203 VALLEY STREET #4 MARYSVILLE, PA 17053. NOT FOUND as to Sheriff ' s Costs : So answer~,...%? - _ __~=-~'' Docketing 18.00 -" ~..- ". Service 13.44 -'" Not Found 5.00 R. Thoma Kline Surcharge 10.00 Sheriff of Cum erland County .00 S/ao(b7 `~7"'^ ~ 46.44 05/07M/200EINBERG REIS Sworn and Subscribed to before me this day of , A.D. r ~ ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. KENDRA GOTSHALL Defendant No.: 07-2479-CIVIL PRAECIPE TO SETTLE, DISCONTINUE AND END WITHOUT PREJUDICE TO REFILE FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: JAMES C. WARMBRODT PA l . D #42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#05815389 ~ ~'~ IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. Civil Action No.: 07-2479-CIVIL KENDRA GOTSHALL Defendant PRAECIPE TO SETTLE DISCONTINUE AND END WITHOUT PREJUDICE TO REFILE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: S1R: Settle, Discontinue and End the above-captioned matter upon the records of the Court without prejudice to refile and mark the costs paid. WELTMAN, WEINBERG & REIS CO., L.P.A. By: Attorney PlaintiffA- 2718 Ko pe s Building 436 Se ent Avenue Pittsb rgh, A 15219 (412 434- 55 #05 15389 COMMON EA H OF PENNSYLVANIA ota.riai SQaI City. ~bur~;t•~, ; ~y Caun~s n ° ~ too; , , lion Ex~"r~: ~ ~,1 ~ .. . . ~.~~rr,t ~ yw ~7~ A~ _,.-of Kota-._ SWORN TO AND SUBSCRIBED before me this '~Np day t"~ , ~ ~, -" -cs ~'+°: ~..,? ~ ~::.. ; -'' ~`_ "~ _...; ~~ ~ ~~ ..~1