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.
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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
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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
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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.
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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#
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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
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