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Home My WebLink About03-5037 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff No. O'd-5ba1 C;.;J Iu- vs. COMPLAINT IN CIVIL ACTION JANET K. ROSNER Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Mo1czan, Esquire PA!.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#03128281 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. Civil Action No. 03 - $.l 31 c.;;.;..t (LA-- JANET K. ROSNER Defendant 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 1. Plaintiff is a corporation with offices in 6851 Jericho Turnpike #190, Syosset, NY 11791. 2. Defendant is an adult individual residing at 7043 Carlisle Pi., Carlisle, P A 17013. 3. Defendant applied for and received a credit card issued by Plaintiff bearing the account number 4121741429467827. 4. Defendant made use of said credit card and has currently a balance due and owing to Plaintiff, as of September 16,2003, in the amount of$2,227.36. 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. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed and/or refused to pay. WHEREFORE, Plaintiff demands Judgment in its favor and against Defendant, Janet K. Rosner jointly and severally, in the amount of $2,227.36 additional interest at the legal interest rate of 6% per annum from the date of judgment 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. W~~.E ,;re PA J.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#:03128281 VERIFICATION The undersigned does hereby verify subject to the penalties of 18 P A.C.S. 94904 relating to unsworn falsifications to authorities, that he/she is agent (Title) of Bridg:ette Nallv (Name) Cal'ital One , plaintiff herein, that (Company) 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. (Si!~~ WWR# SHERIFF'S RETURN - REGULAR CASE NO: 2003-05037 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CAPITAL ONE BANK VS ROSNER JANET K KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon ROSNER JANET K the DEFENDANT , at 1821:00 HOURS, on the 29th day of September, 2003 at 7043 CARLISLE PIKE LOT 311 CARLISLE, PA 17013 by handing to JANET ROSNER a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 4.83 .00 10.00 .00 32.83 r~~ R. Thomas Kline 09/30/2003 WELTMAN WEINBERG REIS me this .;I.~ day of Sworn and Subscribed to before By: 0~ .2-iJV.3 A.D. ~""t'.L () ~ A O~ .. protbonotary' T-' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff No. 03-5037 vs. PRAECIPE FOR DEFAULT JUDGMENT JANET K. ROSNER Defendant 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#03128281 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. Civil Action No. 03-5037 JANET K. ROSNER Defendant PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter Judgment against the Defendant. Janet K. Rosner, above named, in the default of an Answer, in the amount of $2,227.36 computed as follows: Amount claimed in Complaint $2,227.36 Interest from date of judgment at the contract interest rate of 6% per annum TOTAL $2,227.36 I hereby certify that appropriate Notices of Default. as attached have been mailed in accordance with PA RC.P. 237.1 on the dates indicated on the Notices. WELTMAN, WEINBERG & REIS CO., L.P.A. By !/v/;//(jk~ William T.~~(ESqUY PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh. PA 15219 (412) 434-7955 WWR#03128281 Plaintiff's address is: c/o Weltman, Weinberg & Reis Co., L.P.A.. 2718 Koppers Building, 436 7'h Avenue, Pittsburgh, PA 15219 And that the last known address of the Defendant is: 7043 Carlisle PI, Carlisle, PA 17013 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY. PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. Civil Action No. 03-5037 JANET K. ROSNER Defendant IMPORTANT NOTICE TO: JanetK.Rosner 7043 Carlisle Pi. Carlisle. PA 17013 Date of Notice: lOp; /03 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 .' :ELT;:;;z;rG & RE~A. w'm~ ,. Mo'''m ~ PA I.D. #47437 WELTMAN. WEINBERG & REIS CO.. L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh. PA 15219 (412) 434-7955 WWR #03128281 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. ~;'.mt:rtfl~ PA 1.0. #47437 WEL TMAN. WEINBERG & REIS CO.. L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#03128281 01( ~ - ~ ~ j ~ ~ ..:::: ~ f" ,..--.- -lq.. (:) ....0 1- ~ (?:cJ --0 p:::: ~::t--, liiE --.( C) :~:' C) - C~) "! ~; -~ "; f, .., S.,. _\ ~ ;-: .,- . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENN YLVANIA CIVIL DIVISION CAPITAL ONE BANK. Plaintiff No. 03-5037 vs. PRAECIPE FOR SATISFACTION F JUDGMENT JANET K ROSNER, Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt PA I.D #42524 WELTMAN, WEINBERG & REIS 0., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#03128281 .- .. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNS LVANIA CIVIL DIVISION CAPITAL ONE BANK, Plaintiff vs. Civil Action No. 03-5037 JANET K ROSNER, Defendant PRAECIPE FOR SATISFACTION OF JUDGMENT At the request of the undersigned attorneys for the Plaintiff, you are directed to satisfy the bove-captioned Judgment WELTMAN, WEINBERG & REIS 0., L.P.A. B~. James C. armbrodt PA I.D # 524 WELT A ,WEINBERG & REIS C 2718 0 ers Building 436 e nth Avenue Pitt b gh,PA 15219 (4 434-7955 \NWR #03128281 Sworn to and subscribed before me this~ )- ~ INO RYP~ f\i{' ,rsti: ('.,) ""'j " L.P.A. c <-, c".:..> "~ :;) r....:.., , :,..-:r: ..;-J .,,-' i , " r,) 'T( ...CJ :n " , " ,. r-:-l CII