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Home My WebLink About07-5703IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. JEANNE L GELLING Defendant No. D'] - 57x3 Ci v i I ~r-rv~ COMPLAINT IN CIVIL ACTION FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt, Esquire PA I.D. #42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 1521.9 (412) 434-7955 W WR No. 06046965 IN THE C~ULJRT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. Civil Action No. JF,ANNE L GEILING Defendant COMPLAINT IN CIVIL ACT10N 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 I-LAVE A LAWYER OR CANNOT AFFORD ONE, GO TU OR TELEPHONE THE OFFICE SET FORTH. BELOW TO FIND OUT WHERF, YOU CAN GET LF,GAL HELP LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 W WR No. 06046965 !"~lll1 ~TnT A TA T'T 1. Plaintiff is a corporation with offices at 140 East Shore Dr Glen Allen, Va 23059-0000 . 2. Defendant is adult individuals (s) residing at the address listed below: Jeanne L Geiling 66 Country View Est Newville,Pa 1.7241. 3. Defendant applied for and received a credit card issued by Plaintiff bearing the account number 4388641485208321.. 4. Defendant made use of said credit card and has currently a balance due and owing to Plaintiff, as of SEPTEMBER. 19, 2007, in the amount of $1,406.28. 5. Defendant is in default of the terms of the cardholder Agreement having not made monthly payments to Plaintiff thereby rendering the en ire balance immediately due and payable. 6. Plaintiff is entitled to the addition of interest at the rate of 25.900% per annum on the unpaid balance from September 5, 2007. A copy of Plaintiff s STATEMENT is attached hereto, marked as Exhibit "1" and made a part hereof. W W R No. 06046965 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, Jeanne L Geiling individually, in the amount of $1,406.28 with continuing finance charges thereon at the rate of 25.900% per annum from SEPTEMBER 19, 2007 plus costs. WELTMAN, WEINBERG & REIS, CO., L.P.A. James armbrodt, Esquire PA I. . # 2524 WE TM N, WEINBERG & REIS CO., L.P.A. 27 8 Kop ers Building 4 6 Sev th Avenue ttsbu rh, PA 15219 412 34-7955 W WR No. 06046965 •° peoplepcT" online u Abetter way to Internet. ~ ~ ~ Surf trp to 'a ~ Sx fastert4~1 ~ FREE AcceMraier for the rrat 12 monthsr-a +60 trNuar 1-888-587-9669 •~ ° a • Mention Offer Code: DIAMOND ~ ~~ Or visit www.peoplepc.com/go/diamond UNLIMITED INTERNET ACCESS PeoplePC Online offers the features you would expect from higher-priced Internet Service Providers, including: ® V IrLI$ PfOteCtlOn powered by SymantecTM ® Pop-Up BlockerT"' `~ Spam Controls ® ' Smarter Smart Dialer Technology ®~ More Email Addresses 4t~e~` Internet Call Waiting CapitallQ~° Account S Previous Balance E952.23 Payments, Credits and Adjustments f.00 Transactions =29.00 Finance Chazges 521.17 New Balance =1,002.40 Minimum Amoum Due =1,D02.40 Payment Due Date February 21, 2006 Total Credit Line f500 Total Available Credit f.00 Credit Line for Cash 1500 Available Credit for Cash f.00 At vote service To call Customer ReLrions or to repox a lost or stolen card: 1-800-903-3637 For fra online amount swig and sp~ial customer offers, log on to: vtaw.npitalonnmm Send paymeMS to: Send inquiries to: Attn: Remittan« Promsing Capital On<Bank Capital One P.O. Box 790216 P.O. Box 30285 St Louis, MO 63179-0216 SLC, UT 84130-0285 EXHIBIT F'utance Charges Pkareru revere ri&for impar7ant information a Bal rrratr Prriod Cw.rsyrmdmg FI1~If~I~E m ~prirem .a<r APR CHA E PURCHASES f%2.43 .07096% 25.90% 121.17 CASH 1.00 .07096% 25.90% 5.00 ANNUAL PERCENTAGE RATE applied this period 25.9096 • PLEASE RETURN PORTION BELOW WITH PAYMENT ~/~a~~!`~' 0000000 0 4388641485208321 21 1002400024001002408 New Balance E1,002.40 Minimum Amount Due E1,002.40 Paymem Due Date February 21, 2006 Total enclosed f Account Numbc. 4388-6414-8520-8321 Capital One Bank P.O. Box 790216 (r~u~~~tut~i~ut~t~~ St. Louis, MO 63179-0216 ~t~~nu~~tut~~~w~~t~u~~uut~t~ut~~t~~tuu~~s~~u~u~t~ PLATINUM VISA ACCOUNT 4388-6414-8520-8321 DEC 22, 2005 -JAN 21, 2006 Page 1 of 1 Payments, Ctndits and Adjustments Transactions 1 21 JAN PAST DUE FEE 129.00 Your request to close your account has been received. Your account will be closed when it reaches a EO balance. Until then, you will continue to re«ive statements arld must continue to make paymenu All tams and conditions of the account will apply while a balance remains. Aerie remember to cut your cards and cancel all charges which atrtomatically bill to your account. This accounts Non-lntroduaory Rates as of 12/20/05 aze: purchase A.P.R = 23.1596V, cash advance A.P.R = 23.1596V and special transfer A.P.R = 19.8096. If the A.P.R is followed by "V,' then your corresponding A.P.R is a vaziable rate. You were assessed a past due fee of (29.00 on 01/21/2006 because your minvnum payment was not received by the due daze of 01/21/2006. To avoid this fee in the future, we recommend chat you allow at least 7 business days for your payment to reach Capital One. Plraa print mailing add~ar and r-mmldtmgu be! ruing bl o. blm~k rak Svect Apc R Cry Sate ZIP Home Phone Alternate Phone ~ #9002278425389526# MAIL ID NUhffiER ~ JEANNE L CEILING 66 COUNTRY VIEW EST °~ ~ NEWVILLE PA 17241-8749 o ~_ ° ~ ~ut~~~ut~u~t~t~u~nt~~~u~t~ut~t~n~~t~u~ut~~ r Pleare tt»iteyrorn arrount numbs on }roro rhak or monry ordn made payable to Capital One Bank an6 mail in the rnclored rnvelope. VERIFICATION CAPITAL ONE BANK vs CEILING, JEANNE L The undersigned does hereby verify subject to the penalties of 18 Pa.C.S. Section 4904 relating to unswom falsification to authorities, that he/she is, MARITZA ROBERTS, 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. ~,~~~~ ~~ MARIT A ROBERTS Notary P Tx.._, ,~~ur ;.Diary p~'ic Gw•~uwtt ~O1°~'~jgth 2010 Qpp~missiq- ~. 4388641485208321 A049 WELTMAN, WEINBERG & REIS CO., L.P.A. 00 "~ ~ , C `' -yl `- ~ i .. ~ -~ p p A D -- _' ~~i - ~ D ~.7 _"a ~_i Ui ~ r.: ~ _'~" -~ ~ ~r., ,. .., IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL., ONE BANK Plaintiff vs. JEANNE L CEILING Defendants No.: 07-5703-CIVIL PRAECIPE TO SETTLE, DISCONTINUE AND END 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 W W R#06046965 ~ "- t IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. Civil Action No.: 07-5703-CIVIL JEANNE L GEILTNG Defendants PRAECIPE TO SETTLE DISCONTINUE AND END TO THE PROTHONOTARY OF COUNTY: Settte, Discontinue and End the above-captioned matter upon the records of the Court and mark the costs paid WELTM:AN, WEINBERG &REIS CO., L.P.A. By: ,~' ~"_ James C. Wa ~ rodt PA LD #42 4 WELTM , W TNBERG &REIS CO., L.P.A. 271.8ICo ers uilding 436 Sev nth enue Pittsbu h, P 15219 (412) 34- 55 WW #0 46965 Sworn to and bsc ' d (~ Before me the Day of 007 ~r 11 nn ..... V~~VYCVi~.E~IVV'1m41.a~ ~~-t emu' Y'~IF~9ve`~f~'L'F~d~1+ N ARY PU -- 6~"a^'W:.3i~t: -- / V19er~dy L. t~vlt, ~.~,~..~y P'u~~ '" City Qf 1'Ittsbtary17,r'~herry Coun1Y My Canr~ssion E~ires,kaoy 15,2010 Me~nbsc-, Fcar~sylvanl&Nsso~,,,;~;n of P:G:;~~'s~s a „~ ~ ~y ' '..+ ~ .K ~^ `... '~ n'~ ' ~ ~'~ ,~ ~ ~~ .. l~ ~,/ ^ ~ ~.+ mot,. ~"~i ^ ` ~~ ~,~ +~ SHERIFF'S RETURN - REGULAR CASE NO: 2007-05703 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CAPITAL ONE BANK VS GEILING JEANNE L MARK CONKLIN Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon GEILING JEANNE L the DEFENDANT at 1020:00 HOURS, on the 8th day of October 2007 at 66 COUNTRY VIEW EST NEWVILLE, PA 17241 JEANNE GEILING by handing to 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 18.00 Service 14.40 Affidavit .00 Surcharge 10.00 j .00 !)~C~~/~'~ 42.40 Sworn and Subscibed to before me this day So Answers: R. Thomas Kline 10/09/2007 WELTMAN WEINBERG REIS By: Deputy Sheriff of A.D.