HomeMy WebLinkAbout03-6351IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK
Plaintiff
VS,
CHRISTINE A. WEDO
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 Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR#03128366
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK
Plaintiff
VS.
CHRISTINE A. WEDO
Defendant
Civil Action No. 03 - 0 371 ~.z~c~.J
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 fitrther 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 F1ND OUT WHERE YOU CAN GET LEGAL HELP
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
COMPLAINT
Plaintiff is a corporation with offices in 6851 Jericho Turnpike #190, Syosset, NY 11791.
PA 17007.
Defendant is an adult individual residing at 267 Plaza Drive, Building 5, Boiling Springs,
3. Defendant applied for and received a credit card issued by Plaintiff bearing the account
number 4121741485846468.
4. Defendant made use of said credit card and has currently a balance due and owing to
Plainti fl, as of September 3, 2003, in the amount of $2,042.44.
5. Defendant is in default of the terms of the cardholder Agreement having not made monthly
payments to Plaintiff thereby rendering the entire balance immediately due and payable.
6. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed and/or
refused to pay.
WHEREFORE, Plaintiff demands Judgment in its favor and against Defendant, Christine A.
Wedo individually, in the amount of $2,042.44 with additional interest at the legal interest rate of 6.00%
per annum from the date of judgment plus costs.
THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED
SHALL BE USED FOR THAT PURPOSE.
WELTMAN, WE1NBERG & REIS, CO., L.P.A.
PA I.D. #47437
WELTMAN, WE1NBERG & REIS CO., L.P.A.
2718 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR#:03128366
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
(Name)
Cavital 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.
WWR#
SHERIFF'S RETURN - REGULAR
CASE NO: 2003-06351 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
CAPITAL ONE BANK
VS
WEDO CHRISTINE A
JASON VIORAL , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
WEDO CHRISTINE A
DEFENDANT at
at 267 PLAZA DRIVE
BOIING SPRINGS,
CHRISTINE WEDO
a true
2055:00 HOURS,
PA 17O07
the
on the 10th day of December , __
BUILDING 5
by handing to
2003
and attested copy of COMPLAINT & NOTICE
together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing 18.00
Service 3.45
Affidavit .00
Surcharge 10.00
.00
31.45
Sworn and Subscribed to before
me this /~ day of
So Answers:
R. Thomas Kline
12/11/2003
WELTMAN WEINBERG REIS
By:
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK
Plaintiff
VS.
CHRISTINE A. WEDO
Defendant
No. 03-6351 CIVIL TERM
PRAECIPE FOR DEFAULT JUDGMENT
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#03128366
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.
CHRISTINE A. WEDO
Defendant
Civil Action No. 03-6351 CIVIL TERM
PRAECIPE FOR DEFAULT JUDGMENT
TO THE PROTHONOTARY:
Kindly enter Judgment against the Defendant, Christine A. Wedo, above named, in the default of
an Answer, in the amount of $2,042.44 computed as follows:
Amount claimed in Complaint $2,042.44
Interest from date of judgment
at the contract interest rate of 6% per annum
TOTAL $2,042.44
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., bP.A.
2718 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434~7955
WWR#03128366
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: 267 Plaza Drive, BIdg 5, Boiling Springs, PA 17007.
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPTIL ONE BANK,
Plaintiff
CHRISTINE A. WEDO,
Defendant
Civil Action No, 03-6351 CIVIL TERM
IMPORTANT NOTICE
TO: CHRISTINE A WEDO
267 PLAZA DRIVE, BLDG 5
BOLLING SPRINGS, PA 17007
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.
PA I.D. #47437
WELTMAN, WEINBERG & REIS CO., L.P.A.
2718 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR #03128366
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., 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#03128366