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Home My WebLink About03-6226IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff VS. TIMOTHY A. WACHTMAN Defendant COMPLAINT IN CIVIL ACTION 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 Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#02991065 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff VS, TIMOTHY A. WACHTMAN Defendant Civil Action No. COMPLAINT IN CIVIL ACTION 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 LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff VS, TIMOTHY A. WACHTMAN Defendant Civil Action No. COMPLAINT AND NOW COMES, Plaintiff, by and through its counsel, WELTMAN, WEINBERG & REIS, CO., LPA., and hereby files this Complaint against Defendant, Timothy A. Wachtman, and, in support thereof, Plaintiff avers as follows: 1. The Plaintiff is a corporation with its principal place of business located at P.O. Box 85147, Richmond, VA 23285. 2. Plaintiff is the owner of this account, which is the subject matter of this action. 3. Defendant is an adult individual residing at 210 Louis Lane, Enola, PA 17025. 4. Defendant requested the account and made use of said account and has currently a balance due and owing to Plaintiff, as of April 30, 2003, in the amount of $1,485.03. A true and correct copy of Plaintiff's Statement of Account is attached hereto, marked as Exhibit "1" and made a part hereof. 5. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed and/or refused to pay the balance. WHEREFORE, Plaintiff demands Judgment in its favor and against Defendant, Timothy A. Wachtman, individually, in the amount of $1,485.03 with finance charges thereon at the rate of 6% per annum from April 30, 2003, plus costs. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED SHALL BE USED FOR THAT PURPOSE. WELTMAN, WEINBERG & REIS, CO., L.P.A. PA I.D.#47437 Weltman, Weinberg & Reis Co., L.P.A. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#: 02991065 Capital One® Values You As A Customer! If you are unable to pay the amount due at this time, we strongly urge you to call us inunediately at 1-800-955-6600. We are willing to work with you to help you out of your current financial situation and resolve the delinquency of your account. Don't further damage your credit. Your account will soon be reviewed to be charged-off as bad debt. ff your account is charged-off, you will still be responsible for the debt, but it will be listed on your credit report and could prevent you from recei~ng credit cards, loans and even affect future employment and housing opportunities. 476165 CapitalO;~' · PLEAS E RETURN PORTION BELOW WIT~ PAYMENT · 0000000 0 52910716251515~ O0 1485030025001485039 , , .................... EXiTIiBiT / h.hh,lh,,Mh.hlh,lh,,ll,,,lh,,lh,,Ih,,Ih.lh,,I * -- ~ I III III IIIIII II I I1[ II II III VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA.C.S. {}4904 relating to unswom falsifications to authorities, that he/she is agent of (Title) Tom Milana (Nmne) Capital One (Company) , plaintiff herein, that he/she is duly authorized to make this Verification, and that the facts set forth in the foregoing Complaint in Civil Action are true and correct to the best of his/her knowledge, information and belief. (Signature) WWR# SHERIFF'S RETURN - CASE NO: 2003-06226 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CAPITAL ONE BA~NK VS WACHTMA~N TIMOTHY A REGULAR VALERIE WEARY Cumberland County, Pennsylvania, says, the within COMPLAINT & NOTICE WACHTMAN TIMOTHY A DEPENDA/qT , at 1910:00 HOURS, at 210 LOUIS LANE ENOLA, PA 17025 LEAH WACHTN~N, MOTHER a true and attested copy of COMPLAINT Sheriff or Deputy Sheriff of who being duly sworn according to law, was served upon the on the 9th day of December , 2003 by handing to & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 10.35 Affidavit .00 Surcharge 10.00 .00 38.35 Sworn and Subscribed to before me ~this { ~ ~ day of So Answers: R. Thomas Kline 12/i0/2003 WELTMAN WEINBERG REIS Deputy IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff VS. TIMOTHY A. WACHTMAN Defendant No. 03-6226 PRAECIPE FOR DEFAULT JUDGMENT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan, Esquire PA I.D. ~N.7437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 16219 (412) 434-7955 WWR#02991065 THIS LAW FIRM IS ATTEMPTING TO COLLECT THIS DEBT FOR ITS CLIENT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff VS. TIMOTHY A. WACHTMAN Defendant Civil Action No. 03-6226 PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter Judgment against the Defendant, Timothy A. Wachtman, above named, in the default of an Answer, in the amount of $1,550.21 computed as follows: Amount claimed in Complaint $1,485.03 Interest from Apdl 30, 2003 to January 22, 2004 at the contract interest rate of 6% per annum $65,18 TOTAL $1,550.21 I hereby certify that appropriate Notices of Default, as attached have been mailed in accordance with PA R.C.P. 237.1 on the dates indicated on the Notices. WELTMAN, WEINBERG & REIS CO., L.P.A. PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#02991065 Plaintiff's address is: cio Weltman, Weinberg & Reis Co., LP.A., 2718 Koppers Building, 436 7th Avenue, Pittsburgh, PA 15219 And that the last known address of the Defendant is: 210 Louis Lane, Enola, PA 17025 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff VS, TIMOTHY A. WACHTMAN Defendant Civil Action No. 03-6226 IMPORTANT NOTICE TO: TIMOTHY A WACHTMAN 210 LOUIS LANE ENOLA, PA 17025 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER iMPORTANT RIGHTS, YOU SHOULD TAKE THiS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Ave Carlisle, PA 17013 800-990-9108 WELTMAN, WEINBERG & REIS CO., L.P.A. William T. Molczan PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR #02991065 VERIFICATION The undersigned does hereby verify subject to the penalties of 18 Pa,C.S. Section 4904 relating to unsworn falsification to authorities, that the parties against whom Judgment is to be entered according to the Praecipe attached are not members of the Armed Forces of the United States or any other military or non-military service covered by the Soldiers and Sailors Civil Relief Act of 1940. The undersigned further states that the information is true and correct to the best of the undersigned's knowledge and belief and upon information received from others. WELTMAN, WEINBERG & REIS CO., LP.A. WilrCa~ TYMolczan, Esquire/' PA I.D. ~47437 WELTMAN, WEINBERG & REIS CO., LP.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#02991065