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Home My WebLink About07-6678U IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff No: 07 - ( t,,#7 j CIVi? t rM vs. COMPLAINT IN CIVIL ACTION SUZANNE C ENGLAND 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 06139587 C A Pit LXR IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. Civil Action No SUZANNE C ENGLAND 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 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: SUZANNE C ENGLAND 1404 TIMBER CHASE DR MECHANICSBURG, PA 17050 3. Defendant applied for and received a credit card bearing the account number 4388642265599004 . 4. Defendant made use of said credit card and has a current balance due of $2286.20 , as of October 10, 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 26.740% per annum on the unpaid balance from October 10, 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 , SUZANNE C ENGLAND , INDIVIDUALLY , in the amount of $2286.20 with continuing interest thereon at the rate of 26.7400 per annum from October 10, 2007 plus costs. James C / rmbrodt,42524 WELT W INSERG & REIS CO., L.P.A. 436 S ent Avenue, Suite 2718 Pitt urgh PA 15219 (41 434- 955 F 412- 38-7130 06 39587 C A Pit LXR This law firm is a debt collector at emptAg to collect this debt for our client and any information obtai ed ill be used for that purpose. / First 3 months half-price ji. •? 1 amwror 4 7 $6.95/mo. merMw r?=MEEAccekva e w. Now 840 gop w+s...r. SU NE C EN EISENA I? 31QN up TODAn a S DR 1-877-778-1207 M ICSBUR 705550 Mention Offer Code: OPAL Or visit www.peoplepc.com/gcWopal 003 peoplepc- online Nl-/ A better way to InteiTtet. PeopleK Online offers the features you would expect from higher-priced Internet Service Providers at half price for the first 3 monthsl Email Virus Protection ® Pop-Up BklckerTM 'j Spam Controls ®,l Smart Dialer a! [W More Email Addresses e® q§ Internet Call Waiting C IO LGa GOLD VISA ACCOUNT 4388-6422-6559-9004 Aooomlt Previous Balance $1,520.24 Payme Credits and Adjustments 00 Transactions $39.00 Finance Charges $34.91 New Balance $1,594.15 Minimum Amount Due $1,594.15 Payment Due Due July 15, 2005 Total Credit Line $1,200 Total Available Credit $.00 Credit Line for Cash $1,200 Available Credit for Cash $.00 MAY 16 - JUN 15, 2005 Page 1 of 1 Payments, Credits and Adjttatments Transactions 1 15 JUN CAPITAL ONE MONTHLY MEMBER FEE $4.00 2 15 JUN PAST DUE FEE 35.00 You were assessed a past due fee of $35.00 on 06/15/2WS because your minimum payment was not received by the due date of 06/15/2005. To avoid this fee m the filture, we recommend that you allow at least 7 business days for your payment to reach Capital One. At your savice To taB Oumnw R4edow or to report a lent w stolen card: 1-800-903-3637 For free omit awmnt service and special ewtomer *Has, log on to w .npinl.m_ Send por a uto: Send inquM.ft Attn: Raoitomoe Proarxing C *d one Bank Ca*d One Savim P.O. Box 790216 P.O. Box 85015 St Lv* MO 63179-0216 Richmond, VA 23285-5015 EXHIBIT I Finance Charges Pkaa jar rmetiendefor important iixf nnnjattiionn Bdaaarrk PrraLr ?ARG? ?prara +? PURCHASES $1,31619 .07326%P 26.74% in.89 CASH $]20.89 .07326%P 26.74% $5.02 ANNUAL PERCENTAGE RATE applied this period 26.74% PLEASE RETURN PORTION BELOW WITH PAYMENT ????• 0000000 0 4388642265599004 15 1594150150001594154 Plravpriat sxorartdarr aal/x r-,aa7eMevjrj &laoarrr?Her cruet drl•_ New Balance $1,594.15 Minimum Amount Due $1,594.15 Payment Due Date July 15, 2005 Total enclosed f 71 Account Number. 4388-6422-6559-9004 Capital One Bank P.O. Box 790216 loluIueI I I I I I I I III St. Louis, MO 63179-0216 11111[11 111111 11111e11e111 111 tuII IIne11e11un111gill IIIII Street Apt # City Suet ZIP Home Phone Ahu wPhooe Ema1 Addrew #9016769922113603# MAIL ID NUMBER SUZANNE C ENGLAND EISENA Si! 8 ANDES DR MECHANICSBURG PA 17055-5503 v o aaa? o Pkare unteym armanl nwxba anynvcbmi or money order madepayabk to Capital OneB=k and mail in the endwed enrxlopu 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 3,ea,?cn N?an (NAME) authorized agent of Capital One Bank, plaintiff herein, that 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. WWR# S 9.31 CZ D? g 0 -60. (TI `? -T7 CLA SHERIFF'S RETURN - REGULAR CASE NO: 2007-06678 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CAPITAL ONE BANK VS ENGLAND SUZANNE C WILLIAM CLINE Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon ENGLAND SUZANNE C the DEFENDANT at 1752:00 HOURS, on the 8th day of November , 2007 at 1404 TIMBER CHASE DRIVE MECHANICSBURG, PA 17050 TIM COOH, ADULT IN CHARGE by handing to a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge Sworn and Subscibed to before me this So Answers: 18.00 12 .48 .?00 .00 10.00 R. Thomas Kline .00 40.48 11/13/2007 WELTMAN WEINBERG REIS By: - ,? day eputy Sheriff of A. D. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff VS. SUZANNE C ENGLAND Defendants No. 07-6678-CIVIL TERM PRAECIPE TO SETTLE, DISCONTINUE & END WITH PREJUDICE FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt, Esquire Pa. I.D. No. 42524 Weltman, Weinberg & Reis, Co, LLC 2718 Koppers Building 436 7rh Avenue Pittsburgh, PA 15219 WWR#06139587 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff VS. Civil Action No. 07-6678-CIVIL TERM SUZANNE C ENGLAND Defendants PRAECIPE TO SETTLE DISCONTINUE AND END WITH PREJUDICE TO THE PROTHONOTARY OF COUNTY: Please kindly Settle Discontinue and End the above captioned matter with Prejudice upon the records of the Court and mark the cost paid. WELTMAN, WEINBERG & REIS CO., L.P.A. By: James C. ar brodt, Esquire Pa. LD. o. 42 24 Welt n, We' berg & Reis, Co, LLC 2718 opper Building 436 Ave e Pitt burg , PA 15219 W R# 139587 Sworn to and sub )*b? Before me the //? 11 off 1P 1 ecember , 20 NOTARY PUBL C !A (i:•r:? ?zrbEic M.embtt, r'C, ; /rv .; ? : 'v cn of Nc,.x: a ?r s tz, R