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Home My WebLink About07-5176^ a. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff No: ~'7- rJI'7(p (~ivii ~iCr1M vs. AMANDA M MYERS COMPLAINT IN CIVIL ACTION 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 05879052 C N Pit SJS r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. Civil Action No AMANDA M MYERS 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 +~ Y 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: AMANDA M MYERS 41 HEIDI TER CAMP HILL, PA 17011 3. Defendant applied for and received a credit card bearing the account number 5178052426126765 . 4. Defendant made use of said credit card and has a current balance due of $3520.04 as of July 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 25.9008 per annum on the unpaid balance from July 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 AMANDA M MYERS INDIVIDUALLY in the amount of $3520.04 with continuing interest thereon at the rate of 25.900 per annum from July 30, 2007 plus costs. -, Jame Warmbrodt,42524 WEL WEINBERG & REIS CO., L.P.A. 436 Sev nth Avenue, Suite 2718 Pi sbu gh, PA 15219 (4 2) 4-7955 F 4 2-338-7130 0 879 52 C N Pit SJS This law firm is a debt collector a our client and any information obta, king to collect this debt for will be used for that purpose. ~' peoplepcrM online u Abetter way to fnternet. S'tef a a ~ • uPwflfe -" fo-Uta Rtaf 1Yneott6pt-a 460 raAaM ~ • i ~~~SBT~~g6g Mention Offer Code: DIAMOND 1~ Or visit w-+'w.Peoplepc.com/go/diamond uN~.~~~TE~ INTERNET ACCESS PeoplePC OrtNns offers the features you would expect from higher-priced Internet Service Providers, including: virus Protection aovwered by Symartroc*r ® Pop-Up BlockerTM `~ Spam Controls ® ~? S-narter Smart Dialer Technology ®~ More Email Addresses ®~ Internet Cafl Waiting ~~Yle~ PLATINUM MASTERCARD ACCOUNT 517&0524-2612-6765 ~.kpe:,ra,:~.~.r~A.-..~r~.vr,sr~.a:~ebe ~wat:ak Account Sumnury Payments, Credos and Adjustments ~~s ~anu 12,435.09 Paymeah, Credits and Adjuatmenu Transactions 1.00 '!'~~ Finance Charges 135.00 154.14 1 19 JAN PAST DUE FEE 135.00 New BaLtnce Minimum Amount Due 12,524.23 12,524.23 This armunt's Non-Introdurtory Rates as of 17/20/05 arr. purchase A.P.R =17.6S96V, a~ advance A.P.R . 22.65%V and s eaal uaaafa A P R 1 99% If Payment Due Date February 18, 2006 p . . = . . flee A.P.R is foIlowed bY'V; rhea your corresponding A.P.R is a violable rate. Total Credit Line ~„S00 You were aseraced a paw due f« of 135.00 on 01/19/2006 because or i i Total Anilable Credit Cred'n Line for C h 1,00 y e m n mum payment was not received by the due date of 01/19/2006. To avid thin fee in the furore, we recommend that you as 12,500 allow at least 7 businer days for your payment to reach Capiml One. Available Credit for Cash 1,00 At your aervioc To nB Qrroma Rake6ora a<to report a last as rtden a+rd: 1-800-903-3637 send paymeaa to: sad inquvin to: Aare Ranimnen Pmmeing Capital One Bank C'pi~ O1e P.O. Bas 790216 P.O. Bas 30265 St Lama, MO 63179-0216 sLC. UT gg13p-0265 J S'~/C~Z ~ ~~"""a" Pkamxrreverxnds~iiriasfrarraatia,/6raratioa Balansdr yflirlb Pnio& r~r ~ ~~~ o PURCHASES CASH u~f.0~0 ,p 2S.90K 25.90% 694.14 1.00 ANNUAL PERCENTAGE RATE applied this period 25.9096 • PLEASE RETURN PORTION BELOW W17Yt PAYMENT • ~a 0000000 0 5178052426126765 19 2524230100002524231 New B~ s24s3 Mtmmnm Amoum Due ~ 524.23 Paymem Due Date February 16, 2006 Totd enclosed 1 AeooaM Numbs: 5178-0524-2612-6765 6bn DEC 20, 2005 -JAN 19, 2006 Page 1 of 1 Ape t acme raone Alenaee Phone - • Pend Addrea ~~ 190020957157875101 MAIL ID Nt1MBER Capital One Bank '~ AMANDA M MYERS P.O. Sox 790216 Itlnlllnulnllslul m ~ 41 HEIDI TER St. Louis, MO 63179-0216 e ~ CAMP HZLL PA 17011-1141 Itllrrttllttetllltetllelttllretttlelattlltlletttelltlleeltelel ~ ~ Ittellltttllltttteelltteflttelitteliriteltttllrell,l Plrare rwittyma erroust aanrber oa yoea ~ ar nwney ardn+wadr feyble fi Gfital OaeBae! sad grail is rGr sartorad araebfe r CAPTTAL ONE BANK vs MYERS, AMANDA M VERIFICATION The undersigned does hereby verify subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities, that he/she is, TRACY TAYLOR, Authorized Agent, of CAPITAL ONE BANK, Plaintiff Herein, that he/sbe is duly authorized to make this Ikclaration, and that the facts set forth in the foregoing Complaint in Civil Action are true and correct to the best of hisJher knowledge, information and belief. otary Public T Uvonda S. Braaks Notary P'ublie Do~las County, Georgia ~F Co,ffimission Expires ' February 29, 2Q(?8 5178052426126765 A049 WELTMAN, WEINBERG & REIS CO., L.P.A. 6~ ~ ~ ~ ~ # ~ ~ L ... , ~ ~ V '_ i ~ ~ _, ~~... }.'`` 'Q -'- G`) I?7~ : ~ ~~ ~ D ~ V1 { a ~ '"' W ~ ~ -C ~ ~ = 7 ~ `r r .~- ~.s ~~ SHERIFF'S RETURN - NOT FOUND CASE NO: 2007-05176 P CGMMONTWEALTH OF PENNSYLVANIA ` COUNTY OF CUMBERLAND CAPITAL ONE BANK VS MYERS AMANDA M 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 MYERS AMANDA M but was unable to locate Her in his bailiwick. He therefore returns the ('~(lM T]T T TTTT f_ TT(ITTnL~ the within named DEFENDANT MYERS AMANDA M 41 HEIDI TER NOT FOUND as to CAMP HILL, PA 17011 MOVED OVER ONE YEAR AGO Sheriff ' s Costs : So answers ,~.-~ ~ ,--~_y~~_ ~ "" Docketin g i ~ 18.00 c'"~ ~ -- - ~ f J Serv ce , ~ ° 14.40 ~. Not Found ipq I 5 . 0 0 R . Tho s Kline Surcharge ~~ ~~ 10.00 ~~ Sheriff of Cu erland County 00/00/0000 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. AMANDA M MYERS Defendant No. 07-5176 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 PA I. D #42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#05879052 t, ., IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. Civil Action No. 07-5176 CIVIL TERM AMANDA M MYERS 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: r. Attorney for I intiff 2718 Kopp s uilding 436 Seve A enue Pittsburg , P 15219 (412) 43 -79 5 SWORN TO AND SUBSCRIBED before me this I ~ day of _, , 2008 - NOTARY LIC COMMONWEALTH OF PENNSYLVANIA Notarial Seal Wendy L, Gault, Notary Public City Or Pittsburgh, Allegheny County My Commission Expires July 15, 2010 Member, Pennsylv~nie 4ss~ciatie~ of Notaries