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Home My WebLink About07-5917I t IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff No: 07- 591,7 CIVI 1 Term vs. COMPLAINT IN CIVIL ACTION JOHN O WORKMAN 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 06119010 C N Pit KMJ I lk IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff VS. Civil Action No JOHN 0 WORKMAN Defendant COMPLAINT AND NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claims set forth i the following pages, you must take action within twenty (20) days a ter 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 yo and a judgment may be entered against you by the court without furt er 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 C OT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIN r UT WHERE YOU CAN GET LEGAL HELP. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WIT INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIB E PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE ERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 P 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: JOHN O WORKMAN 3 MICHAUX DR NEWVILLE, PA 17241 3. Defendant applied for and received a credit card bearing the account number 486362228644178 . 4. Defendant made'use of said credit card and has a current balance due of $1350.22 , as of September 05, 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 28.490% per annum on the unpaid balance from September 05, 2007 . A copy of Plaintiff' Statement of Acco unt is attached hereto, marked as Exhibit 111" and made a part hereof. 7. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed land/or refused to pay the balance due to Plaintiff. Wherefore, the Plaintiff prays for judgment in its favor and against Defendant, JOHN O WORKMAN , individually , in the amount of $1350.22 with continuing interest thereon at the rate of 28.49096 per annum from September 05, 2007 plus costs. James,C. Warmbrodt,42524 WELTM?N WEINBERG & REIS CO., L.P.A. 436 eve th Avenue, Suite 2718 Pit sbur h, PA 15219 (4 2) 4 4-7955 F 4 2-338-7130 0 119 10 C N Pit KMJ This law firm is debt collector at pting to collect this debt for our client and an information obtained will be used for that purpose. - -- ------------ --------------------------- t Show Mom 003' ' your love! Special savings for Capital One` Cardholders! t , i 5 0 * on your next purchase when Save /? you use Promotion Code CAP66 (See reverse for details) , Save this code! Offer good all year long! ; Remember: Mother's Day is Sunday, May 141h 1-800-flowers&oma- 1 Call 1-800-FLOWERS- (?I -800-356-9377) or Click www.1800flowers.com tedaul '------------- er .. t ---------------------------------------------------i Account S Previous Balance Payments, Credits and Adjustments Tram actions Finance Charges New Balamce Minimum Amount Due Payment Due Date Total Credit Line Total Available Credit Credit Line for Cash Available Credit for Cash At PLATINUM VISA ACCOUNT 4862-3622-2864-4178 MAR 22 - APR 21, 2006 Page 1 of 1 Payments, Credits and Adjustments $919.20 $29.00 Transactions $22.50 1 21 APR PAST DUE FEE $29.00 $970.70 Reminder: If we receive your minimum monthly payment on time for 12 consecutive billing $970.70 Periods, this account will be renewed for a possible return to your Non-Introductory A.P.R. May 20, 2006 You were assessed a put due fee of $29.00 on 04/21/2006 because your minimum payment was not $500 received by the due date of 04/21/2006. To avoid this fee in the future, we recommend that you $.00 allow at least 7 business days for you payment to reach Capital One. $500 $.00 To all Customer Rdatins or to report a lost o stolen atd: 1-500-903-3637 send Payments to: Send Attn: Rant-Pmcessing Capital One Bank CaPit P.O. B. 790216 P.O. SL Latin, MO 63179-0216 SLC N m One- 30285 89130-0285 EXHIBIT CEN 1 AGE RATE applied this period FI.I.. Charges Pleaseta revnieti de for isrpartarrt isfarr?ation PURCH I?A1LJto fOr` p o,r R a ASES CASH $930.04 $.00 .07805%P 07805%P 28.49% $22.50 . 28.49% $.00 ANNUAL PER PLEASE RETURN PORTION BELOW WITH PAYMENT V 0000000 0 4862362228644178 21 0970700025000970703 Plearrprm,111in1a4?-mss r--ailrGmed bdoa?Wring hhrr-.44.k ark Payment Due Dar Total enclosed Account Number; 20,2006 Cry Snu Home Phone Alrernate Apt e 28.49% Emd Addrea Capital One Bank P.O. Box 790216 tltrlnrnllnltnlllrrrl St. Louis, MO 63179-02 6 IrIInnllnndill nlltlul6nnlrlurll IlrrndlrlLnLdd #9011205779633331# MAIL ID NUMBER JOHN 0 WORKMAN 3 MICHAUX DR NEWVILLE PA 17241-9599 LrrlllnrrLdnltltdnnlllrlrnlddJtdnLnrnlL Pleart 14iteyov ar -t nu-bn ongrow J?xf or „?aey ??, made fayabJe to Cafita! One Ban,E and mail in the encloted envelope. VERIFICATION CAPITAL ONE BANK vs WORKMAN, JOHN O The undersigned does hereby verify subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities, at he/she is, UVONDA S BROOKS, Authorized Agent, of CAPITAL ONE BANK{' arc! Plaintiff Herein, that he/she s duly authorized to make this Declaration, and that the facts set forth in the foregoing Complaint in Civil Action true and correct to the best of his/her knowledge, information and belief. UVONIDA S BROOKS C Notary Public V0TARYP ??n ROBERTS OYC (I'le"1 issioNT?=X-1RES ?1 0-,_701 If 4862362228644178 A049 WELTMAN, WEINBERG & ?IS CO., L.P.A. 4h 00 a) 91 p CIA SHERIFF'S RETURN - REGULAR CASE NO: 2007-05917 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CAPITAL ONE BANK VS WORKMAN JOHN O WILLIAM CLINE , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE WORKMAN JOHN O was served upon the DEFENDANT , at 1718:00 HOURS, on the 6th day of November 2007 at 3 MICHAUX DRIVE NEWVILLE, PA 17241 by handing to JENNIFER BARNARD, ADULT IN CHARGE 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 Sworn and Subscibed to before me this of So Answers: 18.00 34.56 .00 10.00 R. Thomas Kline .00 62.56 11/07/2007 WELTMAN WEINBERG REIS By: day Deputy Sheriff A.D.