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Home My WebLink About07-6679I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff No: toco9 vs. COMPLAINT IN CIVIL ACTION SUZANNE C EISENACHER 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 06139589 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 EISENACHER 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 r 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 EISENACHER 1404 TIMBER CHASE DR MECHANICSBURG, PA 17050 3. Defendant applied for and received a credit card bearing the account number 4862362254902730 . 4. Defendant made use of said credit card and has a current balance due of $2306.41 , 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 EISENACHER , INDIVIDUALLY , in the amount of $2306.41 with continuing interest thereon at the rate of 26.740W per annum from October 10, 2007 plus costs. James C Warmbrodt,42524 WELT WEINBERG & REIS CO., L.P.A. 436 ev nth Avenue, Suite 2718 Pit sbu gh, PA 15219 (4 2) 4-7955 F 4 2-338-7130 139 89 C A Pit LXR This law firm is a debt collector a to pting to collect this debt for our client and any information obta d will be used for that purpose. l First 3 months half-price a trtordtC 4 7 / $8.95hm. Omeaaer Now w/th FREE Arne/erator for dw feat 12 m anfhatr--a e80 value 0 SIGN UP TODAY! 00, 1-877-7784207 Mention Offer Code: GARNET Or visit www.peoplepc.com/go/gamet peoplepc- online \--,/ A better way to Internet. People aC Online offers the features you would expect from higher-priced Internet Service Providers at half price for the first 3 months! ® virus Protection powww by sona tec- ® Pop-Up BlockWm j Spam Controls Smarter Smart Dialer Technology 4w [W More Email Addresses ® * Intemet Call Waiting ? 9 Account Previous Balance $013.11 Payments, Credits and Adjustments $AO Transactions $74.00 Finance Charges $29.20 New Balance $1,416.31 Minimum Amount Due $1,416.31 Payment Due Date June 15, 2005 Total Credit Line $1,000 Total Available Credit $.00 Credit Line for Cash $1,000 Available Credit for Cash $.00 Atyourservice To all Ohstomer Relad m or to report a loot or stolen ark 1-800-903-3637 For free online women service and spend asooma aS m log on to wmv osprw.ne.eom Smd pryraetm to Send ingeiriea to Attu Rees taaoe Pmoeneq Cariul One Bank capital One Senior P.O. Box 790216 P.O. Box 85015 St Loris, MO 63179-0216 Richmond, VA 23285-5015 PLATINUM VISA ACCOUNT 4862-3622-5490-2730 APR 16 - MAY 15, 2005 Page 1 of 1 Payments, Credits and Adjustments Tnmmctions 1 15 MAY CAPITAL ONE MEMBER FEE $39.00 2 15 MAY PAST DUE FEE 35.00 You were awewed a past due fee of $3$.00 on 05/15/200$ because your minimum payment was not received by the due date 4 05/14/200. To avid this fee in the future, we recommend that you allow at least 7 business days for your payment to reach Capital One. rrsrr 1 Finance Charges Plram wreverienkfor:mpodast:nfornwtion Balesornstr aa;.ae ? ma m ,ver. naRr $ PURCHASES $1,328.45 .07326%P 16.744 529.20 ? CASH $.00 .07326%P 26.74% $.00 ANNUAL PERCENTAGE RATE applied this period 26.74% PLEASE RETURN PORTION BELOW WITH PAYMENT ?$e 0000000 0 4862362254902730 15 1416310056001416311 New Balance $1,416.31 Minimum Amount Due $1,416.31 Payment Due Date June 15, 2005 Total enclosed $ Account Number. 4862-3622-5490-2730 p.irt.uir.?va.x..yrr,hra?e8ee?+krav,s?gefOhrAer.#nsk Street Apt # Cary So ZIP Home Phone Alwnft Phom EmsaAddm #9013528994370977# MAIL ID NUMBER Capital One Bank SUZANNE C EISENACHER P.O. Box 790216 8 ANDES DRIVE St. Louis, MO 63179-0216 m MECHANICSBURG PA 17055-5503 Irlluu'Iuull'u???s?n??nur?r?nt??t??nur??s??u?n?s? ° Pleats roritryosv arcosart rn nsd er on yvsrr cbacf or money order asadc fayab& to Capital OwAanI end mad in for eudared exvdope 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 ism \encn l Ca k* 't`"-- (NAME) authorized agent of Capital One Bank, plaintiff herein, that he/she is duly authorized to snake 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# R? -d CtA SHERIFF'S RETURN - REGULAR CASE NO: 2007-06679 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CAPITAL ONE BANK VS EISENACHER 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 EISENACHER SUZANNE C the DEFENDANT at 1752:00 HOURS, on the 8th day of November , 2007 at 1404 TIMBER CHASE DR MECHANICSBURG, PA 17050 TIM COOK, 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 of So Answers: 18.00 12.48 .00 10.00 R. Thomas Kline 40.48 11/13/2007 WELTMAN WEINBERG REIS By: ?e',?G?---- day Deputy Sheriff A.D. M IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff VS. SUZANNE C EISENACHER Defendants No. 07-6679-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 7'" Avenue Pittsburgh, PA 15219 WWR#06139589 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff VS. Civil Action No. 07-6679-CIVIL TERM SUZANNE C EISENACHER 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, WAINBERG & REIS CO., L.P.A. By: James C. W rt brodt, Esquire Pa. I.D. N .42 24 Weltman Wei erg & Reis, Co, LLC 2718 K pers uilding 436 7t' ven Pittsb rgh, A 15219 WW #06 9589 Sworn to and subscrib? Before me the ?- a ; f December, 20 AY UBIC ??Pth^n^pfanr ? . , j ? r-; "'4'. 1,11Y OWN of ?0V. 4, 2'-1 ?9 McMOG Fw /` ?r;r r ccsaiiou of '?.a,: ; ?? ? ? r . , ;,ti ' ? ? ,.??, A . ' ? ?'.Y i ?.! t?}e ' ? i ,... .may' ?. _ ? .?" ? ,r7 L='`?_ ?. {??