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Home My WebLink About07-666514 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK //?? Plaintiff No: b1- 6666 Civi ! berm vs. COMPLAINT IN CIVIL ACTION KATHRYN M GAGE 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 06015384 C A Pit KMJ IN THE COURT.OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff VS. KATHRYN M GAGE Defendant Civil Action No d 1- 66 G.S Ct;w-):;, 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 I COMPLAINT 1. Plaintiff, CAPITAL ONE BANK is a corporation with offices at 6851 JERICHO TURNPIKE #190 SYOSSET , NY 11791 . 2. Defendant is adult individual(s) residing at the address listed below: KATHRYN M GAGE 218 N QUEEN ST SHIPPENSBURG, PA 17257 3. Defendant applied for and received a credit card bearing the account number 4388642255340724 . 4. Defendant made use of said credit card and has a current balance due of $3490.06 , 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 15.900% per annum on the unpaid balance from September 05, 2007 . A copy of Plaintiff's Application is attached hereto, marked as Exhibit 111" and made a part hereof. 1 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 , KATHRYN M GAGE , individually , in the amount of $3490.06 with continuing interest thereon at the rate of 15.9001 per annum from September 05, 2007 plus costs. James C. armbrodt,42524 WELT EINBERG & REIS CO., L.P.A. 436 S en h Avenue, Suite 2718 Pitt urg , PA 15219 (412 434 7955 FAX• 412- 38-7130 060 538 C A Pit KMJ This law firm is a debt collector atte?hpt?&g to collect this debt for our client and any information obtain?d ill be used for that purpose. NO w w M n ago g C 3 j C w •. w p .? q ?M a ?•n O? 3? O 4 R7 L w .31 ? p ? N a ;ao? c y ?7Q h e fl. ? 7 N _ n O A Q ? 3 a 40 7 D q O `YSr e?L?` T A 10 n N n 0 s? 5??. Ty ICA p da o 00 %0 ? a s N G1 m o aq C O x O !-a f? O ro Q O 4 O Q •"F r. Q w 0 0 r VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA. C.S. 4904 relating to unsworn falsifications to authorities, that he/she is _ , (NAME) L of v 1 , plaintiff herein, that (TITLE) (COMPANY) he/she is duly authorized to make this verification, and that the facts set forth in the foregoing Complaint are true and correct to the best of his/her knowledge, information and belief. (SIGNATURE) WWR# C &O 1 5? S C] n 00 d Y b 71 N -77 c 'v r.yZ 1 -C 0 SHERIFF'S RETURN - NOT FOUND CASE NO: 2007-06665 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CAPITAL ONE BANK VS GAGE KATHRYN 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 GAGE KATHRYN M but was unable to locate Her in his bailiwick. He therefore returns the the within named DEFENDANT 218 N QUEEN STREET GAGE KATHRYN M NOT FOUND , as to SHIPPENSBURG, PA 17257 GIVEN ADDRESS IS VACANT. PER POST OFFICE, CURRENT ADDRESS IS 98 BRIDGEPORT AVE SWEDESBORO, NJ 08085-3078. Sheriff's Costs: So answers Docketing 18.00 Service 19.20 Not Found 5.00 R. Thom -Kline Surcharge, 10.00 Sheriff of Cumberland County .00 52.20 WELTMAN WEINBERG REIS 11/14/2007 Sworn and Subscribed to before me this day of A. D. Nov 13 2007 12:15 HP LASERJET FAX Nov. 13. 2007 9:10AM Cumberland Co. SheriifWs6& / . v. asp uftzberr? R. THOM$ WNE ShwN EDWOW L SCHORPP OFFICE OF THE SHERIFF One Courthouss Square Cetlisis, Penns*aWa 17013 No. 8338 P. 1/1 P•1 . RONW ti. AWEASON Chief Depulyr JODY S. SL"M Reel EUA0 Depugr Tv: Peatmaster Agerscy Cobol r 6 6 ' bate: -- Address Information Regvat pkase Am" this ggawy with the now addres. if suWable, for the fonovft individual or verity whether the address given below is ones at which marl for this indivi&W is coaeatly bafmg dotivcM& If ft fo kmdug WWrms is s post office box, pleaw twdsb the street address as tecarded on the box holder' c appbcadon fam Nun: 1P''r'1?P Last lawmAddress:. "Z'(6- Q"'Erx? I c ttVy the address iuferumdon for this individual is requbed for the paimmsnce of this ag:sacy's of cial (' tore Agenry Official) For Post Otllee Use Only () Matz is deEverod to address given. Now Address ( ).Not Known st Addms Given ' 9k BR 1?K too& ,y V ( ) Moved, Left No Forwarding Ad&= 5????s 6a•? ?? O ?,Pk5:30 7e ( ) No Sucb Address ( ) Other (Specify) Agowy B et<au Address Box holden' Street Aftesc Poannsrk/Dabe sump ?Please fax rosdts to the Cumberland County Sheriffs Me& Nw nber (717) 240-6397 Address lafermation Request (Required format) Exhibit 352.44' a )J" L 1 ? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. KATHRYN M GAGE Defendant No. 07-6665 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, Esquire PA I. D. #42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#06015384 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. Civil Action No. 07-6665 CIVIL TERM KATHRYN M GAGE 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: Att/Kp 271436 Pitt(41 SWORN TO AND SUBSCRIBED before me this Gday of 008 N C COMMONWEALTH OF PENNSYLVANIA IA laintiff Building Avenue 15219 955 5384 Notarial Seal Jennifer M. Borowski, Notary Public City of Pittsburgh, Allegheny County My Commission Expires Feb. 22, 2012 Member, Pennsylvania Association of Notaries r' rv ?-y C:D 4J? r7l co C-n