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Home My WebLink About07-3501 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff No: Li t VS. COMPLAINT IN CIVIL ACTION JENNIFER R ADAMS 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 05912895 C N Pit BNT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff VS. JENNIFER R ADAMS Defendant Civil Action No 01- 36-01 O' ? /a,;.... 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: JENNIFER R ADAMS 141 MEADOW DR SHIPPENSBURG, PA 17257 3. Defendant applied for and received a credit card bearing the account number 5178052497913737 . 4. Defendant made use of said credit card and has a current balance due of $1209.97 , as of May 24, 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 28.2409o- per annum on the unpaid balance from May 24, 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 , JENNIFER R ADAMS , INDIVIDUALLY , in the amount of $1209.97 with continuing interest thereon at the rate of 28.240% per annum from May 24, 2007 plus costs. Jam Warmbrodt,42524 WEL WEINBERG & REIS CO., L.P.A. 436 Se enth Avenue, Suite 2718 Pi tsb rgh, PA 15219 ( 2) 434-7955 F 12-338-7130 59 895 C N Pit BNT This law firm is a debt collector aVt&ting to collect this debt for our client and any information obtap ed will be used for that purpose. V'peoplepc- online u A better way to Internet. ../ Surf p o 97 11 '• 47P' 1 5x fasterm 4 FREE Accelerator for ft first 12monihst-a SW vaWel 1-888-587-9669 Mention Offer Code: DIAMOND Or visit www.peoplepc.com/go/diamond 003 UNLIMITED INTERNET ACCESS PeoplePC Online offers the features you would expect from higher-priced Internet Service Providers, including: ® Virus Protection powered by SymantecT. ® Pop-Up BlockerTM `? Spam Controls ap Smarter Smart Dialer Technology ® More Email Addresses ® Internet Call Waiting Capffal0W PLATINUM MASTERCARD ACCOUNT 5178-0524-9791-3737 Account Summary Payments, Credits and Adjustments DEC 22, 2005 - JAN 21, 2006 Page 1 of 1 Previous Balance $830.20 Payments, Credits and Adjustments S.00 Transactions Transactions $29.00 Finance Charges $20.14 1 21 JAN PAST DUE FEE $29.00 New Balance $879.34 This account's Non-Introductory Rates as of 12/20/05 are: purchase A.P.R. = 17.65%V, cash Minimum Amount Due $879.34 advance A.P.R. = 22.74%V and special transfer A.P.R. = 17.65%V. If the A.P.R. is followed Payment Due Date February 21, 2006 by "V,' then your corresponding A.P.R. is a variable rate. Total Credit Line $500 You were assessed a past due fee of $29.00 on 01/21/2006 because your minimum payment was not Total Available Credit $.00 received by the due date of 01/21/2006. To avoid this fee in the future, we recommend that you Credit Line for Cash $500 allow at least 7 business days for your payment to reach Capital One. Available Credit for Cash $.00 At your service To call Custom- Relations or to report a lost or Aolm w& 1-800-903-3637 Send payments to: Send inquiries to: Attn: Remittance Processing Capital One Bank Capin) One P.O. Box 790216 P.O. Box 30285 St Lou6, MO 63179-0216 SLC, UT 84130-0285 F'mance Charges Pkare sa reverse si dekft important inforrnsattiim 13d -+ae< Pssiod'e ? C- 1g ? E m n geplird m +?< R Al m PURCHASES $839.90 .07737%P 28.24% 1120.14 CASH S.00 .07737%P 28.24% 11.00 ANNUAL PERCENTAGE RATE applied this period 28.24% PLEASE RETURN PORTION BELOW WITH PAYMENT ??e• 0000000 0 5178052497913737 21 0879340015000879349 Pleaseprm1 .dmgadd anddo+s malsMnge he/ asmgbl or black ink New Balance $879.34 Minimum Amount Due $879.34 5-t Ape Payment Due Date February 21,255; Cry sm. ZIP Total enclosed 5 Home Phone Al- Phone Account Numbs. 5178-0524 -9791-3737 Emil Add- #9002271505360699# MAIL ID NUMBER Capital One Bank Z JENNIFER R ADAMS P.O. Box 790216 13051 MONGUL RD St. Louis, MO 63179-0216 0 NEWBURG PA 17240-9672 Please tniteyour account number on your cbeck or money order madepayable to Capital One Bank and mail in the endaed envelope. VERIFICATION CAPITAL ONE BANK vs ADAMS, JENNIFER R The undersigned does hereby verify subject to the penalties of 18 Pa.C.S. Section 4904 relating to unworn 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 are true and correct to the best of his/her knowledge, information and belief. MAISHA DAVIS iL L otary Public MARITZA L. ROBERTS NOTARY PUBLIC. DEKALB COUNTY, GA MY COMMISSION EXPIRES 4-10-2011 5178052497913737 A049 WELTMAN, WEINBERG & REIS CO., L.P.A. ? p v ? n ^? c: U 0 n a IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. JENNIFER R ADAMS Defendant No. 07-3501 CIVIL TERM PRAECIPE TO SETTLE, DISCONTINUE AND END WITHOUT PREJUDICE TO REFILE FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt, P.A.I.D.# 42524 Weltman,Weinberg & Reis Co.,L.P.A. 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 (412)434-7955 Fax: 412-338-7130 WWR#5912895 I' IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. Civil Action No. 07-3501 CIVIL TERM JENNIFER R ADAMS Defendant PRAECIPE TO SETTLE DISCONTINUE AND END WITHOUT PREJUDICE TO REFILE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: SIR: 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: X' I l/- Attorne f 'Plaintiff 2718 opp rs Building 436 eve h Avenue Pitt urg , PA 15219 (4 ) 4 =7955 R 912895 SWORN TO AND SUBSCRIBED before me this ? day - ra c? O r_ -n c 70