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HomeMy WebLinkAbout07-6984N IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff VS. LESLIE L EVANS Defendant No: 1)?- jpggl 0ivil-Fezoi COMPLAINT IN CIVIL ACTION 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 06015332 C A Pit KMJ 14 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff VS. Civil Action No LESLIE L EVANS 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 U 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: LESLIE L EVANS 214 ROSS AVE # B NEW CUMBERLAND, PA 17070 3. Defendant applied for and received a credit card bearing the account number 4388642072514303 . 4. Defendant made use of said credit card and has a current balance due of $1394.60 , 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 25.740% per annum on the unpaid balance from September 05, 2007 . A copy of Plaintiffs Statement of Acco unt is attached hereto, marked as Exhibit 111" and made a part hereof. I 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 , LESLIE L EVANS , individually , in the amount of $1394.60 with continuing interest thereon at the rate of 25.740W per annum from September 05, 2007 plus costs. Jame WELT 436 Pit (4 2 0 Z Warmbrodt,42524 N, WEINBERG & REIS CO., L.P.A. v nth Avenue, Suite 2718 t gh, PA 15219 34-7955 2-338-7130 32 C A Pit KMJ This law firm is a debt collector aerating to collect this debt for our client and any information obta'n will be used for that purpose. peoplepc- online u A better way to Internet. A Cap/fal()ne. Account Su Suef up to 5x?ls?t??ar FREE Aooeleraibor for tha fbsf 12 mon$MSt-a $BO veh7af a a 1-888-587-9669 Mention Offer Code: COIN Visit www.peoplepc.com/go/coin Previous Balance $761.30 Payments, Credits and Adjustments $.00 Transactions $29.00 Finance Charges $16.27 GOLD VISA ACCOUNT 4388-6420-7251-4303 SEP 16 - OCT 15, 2004 Page 1 of 1 Payments, Credits and Adjustments Transactions 1 15 OCT PAST DUE FEE $29.00 New Balance $806,57 Your request to close your account has been received. Your account will be closed when it reaches a $0 balance Minimum Amount Due $806.57 . Until then, you will continue to receive statements and must continue to make payments. All terms and Payment Due Date November 15, 2004 conditions of the account will apply while a balance remains. Please remember to cut your cards and cancel all charges which automatically bill to your account. Total Credit Line $500 Total Available Credit $.00 You were assessed a past due fee of $29.00 on 10/15/2004 because your minimum payment was not Credit Line for Cash $500 received by the due date of 10/15/2004. To avoid this fee in the fume, we recommend that you Available Credit for Cash $.00 allow at least 7 business days for your payment to reach Capital One. At your service To call lCCustomer Relati?oana or to report a lost or stolen card: 1-800-608-5227 For flee online account mvice and special customer offer, log on to, w .capitalone.com Send payments to: Send inquirim to: Attn: Remittance Proces sing Capital One Services Capital One Services P.O. Box $5147 P.O. Box $5015 Richmond VA 23276 Ridlmond, VA 23285-5015 Important Account Information Want to make a difference this November? VOTE! Your vote is important, so get out there on November 2. Only you can make sure your voice is heard. Every vote counts! EIXU"IBIT Finance 1.. aT= Please jee revme rde* important inform n aioo M ? OIY[ 'Ww& n1[f c- 141 ti / ' PURCHASES CASH $43171 .07052%P 25.74% $9.15 $336.41 .07o52%P 25.74% $7.12 ANNUAL PERCENTAGE RATE applied this period 25.74% PLEASE RETURN PORTION BELOW WITH PAYMENT ow" 0000000 0 4388642072514303 15 08065 70150000806574 New Balance $906.57 Minimum Amount Due $806.5-7 Payment Due Date November 15, 2004 Total enclosed $ AccotmtNumber. 4388-6420-7251-4303 Capital One Bank P.O. Box 85147 1111111/111111111111111 Richmond, VA 23276 ?n?llnllul?l??u1111?n11n111n1111un11111u??n111n11? Pleasefriar m4*r adiru-& -,Am. below nnn6 hA. w31m1 brk arreet Apt t Gry Sate ZIP nome Anne Alo mate Phone !!M #9029075021241658# MAIL ID NUMBER ?- LESLIE L EVANS 214 ROSS AVE B .o NEW CUMBERLND PA 17070-2614 r ° In1111u111?n11It 1111nn11111111nu11111u1u11111n11ndi Manz= Please write your account number m your check w money order made payable to Capit410ne Bank and mail in the enclosed envelope. UNLIMITED3 INTERNET ACCESS PeoplePC Online offers the features you would expect from higher-priced Internet Service Providers, including: ® Virus Protection powered by symantec- ® Pop-Up BlockerTM Spam Controls ® Smarter Smart Dialer Technology ®? More Email Addresses ,gp Internet Call Waiting 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 i (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 hest nf his/her knowledge, information and belief. WWR# rTl Y ;7 v, T d .o 00 4C- Cri < r r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. LESLIE L EVANS Defendant No. 07-6984 CIVIL TERM PRAECIPE TO SETTLE, DISCONTINUE AND END WITHOUT PREJUDICE TO REFILE FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan, Esquire PA I. D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#06015332 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. Civil Action No. 07-6984 CIVIL TERM LESLIE L EVANS 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: Attorney for Plaint' 2718 Koppers Buil ng 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#06015332 SWORN TO AND SUBSCRIBED before me this day of abW" 2007 - 5?!? NOT AY P BLI Ili _ COMMONWEALTH OF PENNSYLVANIA Notarial seal Wendy L. Gaut, Notary Public County City of pigsburgh, Aft Jury 15, 2010 My commission Expi member, Pennsylvania Association of Notaries c? ? ? C ? ?t e ?„' -? rr; ? t ? -fir- .} -s's c?. `' '<: ?;? c.7Y