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Home My WebLink About03-4014IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff VS. JOHN A. BOOSE Defendant COMPLAINT IN CIVIL ACTION FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan, 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#02948348 1N THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff VS. JOHN A. BOOSE Defendant Civil Action No. COMPLAINT IN CIVIL ACTION 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 timber 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 LAWYER REFERRAL SERVICE PA Bar Association P.O. Box 186 Harrisburg, PA 17108 1-800-692-7375 COMPLAINT Plaintiff is a corporation with offices in P.0. Box 85147, Richmond, VA 23276, 17055. Defendant is an adult individual residing at 5169 E. Trindle Road, 15, Mechanicsburg, PA 3. Defendant applied for and received a credit card issued by Plaintiff bearing the account number 4121741278910026. 4. Defendant made use of said credit card and has currently a balance due and owing to Plaintiff, as of June 15, 2000, in the amount of $l,338.20. A true and con:ect copy of Plaintiff's Statement of Account is attached hereto, marked as Exhibit "1" and made a part hereof. 5. Defendant is in default of the terms of the cardholder Agreement having not made monthly payments to Plaintiff thereby rendering the entire balance immediately due and payable. 6. Plaintiff avers that the Cardholder Agreement between tbe parties provides that Plaintiff is entitled to the addition of finance charges at the rate of 18.74% per annum on the unpaid balance. 7. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed and/or refused to pay the principal balance, finance charges or any part thereof to Plaintiff WHEREFORE, Plaintiff demands Judgment in its favor and against Defendant, John A. Boose individually, in the amount of $1,338.20 with continuing finance charges thereon at the rate of 18.74% per annum from June 15, 2000 plus costs. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED SHALL BE USED FOR THAT PURPOSE. WELTMAN, WEINBERG & REIS, CO., L.P.A. PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#:02948348 ,I Capital One® Values You As A Customer! ff you are unable to pay the amount due at this time, we strongly urge you to call us immediately at 1-800-955-6600. We are w'dling to work with you to help you out of your current financial situation and resolve the delinquency of your account. Don't further damage your credit. Your account will soon be reviewed to be charged-off as bad debt. If your account is cliarged-off, you will still be responsible for the debt, but it will be listed on your credit repo;t and could prevent you from receiving credit cards, loans and even affect future employment and housing opportunities. 9907M Capi~l(~z~' ANNUAL PERCENTAGE RATE applied this period · PLEASE RETURN PORTION BELOW WITH PAYMENT · 0000000 0 4121741279910026 O0 1338200100001338203 EXHIBIT L,hL,Ih,,I,Ih,,I,II,,Ih,,ll,,,Ih,,IL,,Ih,,Ih,,IL,,I VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA.C.S. {}4904 relating to unswom falsifications to authorities, that he/she is agent of (Title) Tom Milana (Name) Capital One (Company) , plaintiffherein, that he/she is duly authorized to make this Verification, and that the facts set forth in the fbregoing Complaint in Civil Action are true and correct to the best of his/her knowledge, information and belief. (Signature)~~%~ SHERIFF'S RETURN - REGULAR CASE NO: 2003-04014 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CAPITAL ONE BANK VS BOOSE JOHN A CPL. MICHAEL BARRICK Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE BOOSE JOHN A DEFENDANT , at 0943:00 HOURS, on the at 5169 E TRINDLE ROAD #15 MECHANICSBURG, PA 17055 JOHN A BOOSE a true and attested copy of COMPLAINT & NOTICE was served upon the 4th day of September, 2003 by handing to together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 7.59 Affidavit .00 Surcharge 10.00 .00 35.59 Sworn and Subscribed to before me this /7 ~ day of .~_~ · ~1~ ~ A.D. ~othonotary -- So Answers: R. Thomas Kline 09/05/2003 WELTMAN WE INBE/~,/~I S ~ Deputy Sheriff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff VS. JOHN A, BOOSE Defendant No. 03-4014 CIVIL TERM PRAECIPE FOR DEFAULT JUDGMENT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan, 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#02948348 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. JOHN A. BOOSE Defendant Civil Action No. 03-4014 CIVIL TERM PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter Judgment against the Defendant, John A. Boose, above named, in the default of an Answer, in the amount of $2,170.24 computed as follows: Amount claimed in Complaint $1,338.20 Interest from 6/15/00 to 10/09/03 at the contract interest rate of 18.74% per annum $832.04 TOTAL $2,170.24 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~ W' ' m ~A ID. #47437 WELTMAN, WEINBE~G & REIS CO., L.~.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#02948348 Plaintiff's address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7th Avenue, Pittsburgh, PA 15219 And that the last known address of the Defendant is: 5169 E. Trindle Road 15, Mechanicsburg, PA 17050 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff VS. JOHN A. BOOSE Civil Action No. 03-4014 CIVL TERM Defendant IMPORTANT NOTICE TO: John A. Boose 5169 E. Trindle Road 15 Mechanoisburg, PA 17050 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 WELTMAN, WEINBERG & REIS CO., L.P.A. WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR/102948348 VERIFICATION The undersigned does hereby verify subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities, that the parties against whom Judgment is to be entered according to the Praecipe attached are not members of the Armed Forces of the United States or any other military or non-military service covered by the Soldiers and Sailors Civil Relief Act of 1940. The undersigned further states that the information is true and correct to the best of the undersigned's knowledge and belief and upon information received from others. WELTMAN, WEINBERG & REIS CO., L.P.A. William T. Molczan;~-squ)ce PA I.D. #47437 / WELTMAN, WEINBERG & REIS CO., L~A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#02948348