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Home My WebLink About03-4255IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff VS. WILLIAM S SULLIVAN Defendant COMPLAINT IN CIVIL ACTION FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan, Esquire PA I.D. #47437 Gerianne Hannibal, Esquire PA I.D. #66622 WELTMAN, WEINBERG & REIS CO,, L.P.A, 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#03019676 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff VS. WILLIAM S SULLIVAN 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 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 LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 COMPLAINT Plaintiff is a corporation with offices in San Ramon, CA 94583. 2. Defendant is residing at 603 Good Hope Road, Mechanicsburg,, PA 17050. 3. Defendant applied for and received a credit card issued by Plaintiff bearing the account number 5291071605454972 . 4. Defendant made use of said credit card and has currently a balance due and owing to Plaintiff, as of October 12, 2000, in the amount of $1,124.30 . A true and correct 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 the parties provides that Plaintiff is entitled to the addition of finance charges at the rate of 21.24% 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, William Sullivan individually, in the amount of $1,124.30 with continuing finance charges thereon at the rate of 21.24% per annum from October 12, 2000 plus costs. THIS IS 3iN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED SHALL BE USED FOR THAT PURPOSE. wELT~G/4 & REIS,~., L.P.A. Willia~T~olczan, Esquir~ ' / PA I.D, #47437 Gerianne Hannibal, Esquire PA I.D. #66622 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#:03019676 Whvdo~od 0000000 0 5291071605454972 O0 1124300020001124302 EXHIBIT / VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA.C.S. {}4904 relating to tmswom falsifications to authorities, that he/she is a~ent of (Title) Tom Milana (Name) Caoital One (Compm~y) , plaintiff herein, that he/she is duly authorized to make this Verification, 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. Vv%VR# SHERIFF'S RETURN CASE NO: 2003-04255 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CAPITAL ONE BA/qK VS SULLIVAN WILLIAM S - REGULAR CPL. MICHAEL BARRICK , Cumberland County, Pennsylvania, says, the within COMPLAINT & NOTICE SULLIVAN WILLIAM S DEFENDANT , at 0932:00 HOURS, at 603 GOOD HOPE ROAD MECHANICSBURG, PA 17050 WILLIAM S SULLIVAN a true and attested copy of COMPLAINT Sheriff or Deputy Sheriff of who being duly sworn according to law, was served upon the on the 4th day of September, 2003 by handing to & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18 Service 8 Affidavit Surcharge 10 36 00 28 00 00 00 28 Sworn and Subscribed to before me this /7 J day of --~_. 2~-d3 A.D. Prothonotary So Answers: R. Thomas Kline 09/05/2003 WELTMAN WEINBERG REIS By: ~~~ Deputy Sheriff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff VS. WILLIAM S. SULLIVAN Defendant No. 03-4255 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#03019676 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, WILLIAM S. SULLIVAN Defendant Civil Action No. 03-4255 CIVIL TERM PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter Judgment against the Defendant, William S. Sullivan, above named, in the default of an Answer, in the amount of $1,838.74 computed as follows: Amount claimed in Complaint $1,124.30 Interest from 10/12~00 to 10/09/03 at the contract interest rate of 21.24% per annum $714.44 TOTAL $1,838.74 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. WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#03019676 Plaintiff's address is: ¢/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: 603 Good Hope Road, Mechanicsburg, PA 17050 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff VS. WILLIAM S SULLIVAN Defendant Civil Action No. 03-4255 CIVIL TERM IMPORTANT NOTICE TO: William S. Sullivan 603 Good Hope Road Mechanicsbur9, PA 17050 Date of Notice: ~/~ ff-~/~.-~ 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. William PA I.D. ff47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Buiiding 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR #03019676 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. WELTMAN, WEINBERG & REIS CO., LP.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#03019676