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Home My WebLink About08-0360 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff No: ?8- 3(pa Civ? Ter Pi VS. COMPLAINT IN CIVIL ACTION KAREN L SHOLLY 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 06241214 C N Pit SGM IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff VS. Civil Action No KAREN L SHOLLY 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 COMPLAINT 1. Plaintiff, CAPITAL ONE BANK is a corporation with offices at 140 EAST SHORE DR GLEN ALLEN , VA 23059 . 2. Defendant is adult individual(s) residing at the address listed below: KAREN L SHOLLY 105 E CUMBERLAND RD ENOLA, PA 17025 3. Defendant applied for and received a credit card bearing the account number 5178052471784443 . 4. Defendant made use of said credit card and has a current balance due of $1103.31 , as of December 06, 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 27.7401 per annum on the unpaid balance from December 06, 2007 . A copy of Plaintiff's STATEMENT is attached hereto, marked as Exhibit 111" 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 , KAREN L SHOLLY , INDIVIDUALLY , in the amount of $1103.31 with continuing interest thereon at the rate of 27.740% per annum from December 06, 2007 plus costs. James C. brodt,42524 WELTMAN, EI BERG & REIS CO., L.P.A. 436 Seve th venue, Suite 2718 Pittsbu gh, A 15219 (412) 4 4-7 55 FAX: 4 2-33 -7130 062412 4 N Pit SGM This law firm is a debt collector attempt/Lnt to collect this debt for our client and any information obtained i be used for that purpose. rpeoplepc- online u A better way to Internet. Surf cep to i$497* tar ttr bat 12mon9esr-s a80 sa+red 1-888-587-9669 .15 Mention Offer Code: COIN a? Visit www.peoplepc.cwrn/go%oin UNLIMITED INTERNET ACCESS PeoplePC Online offers the features you would expect from higher-priced Internet Service Providers, including: 19 Virus Protection powered by symamtec- ® Pop-Up BlockerTM 1?j Spam Controls ® Smarter Smart Dialer Technology ®? More Email Addresses 4W ( Internet Cali Waiting ow PLATINUM MASTERCARD ACCOUNT 5178-05247178-4443 Account Summary Payments, Credits and Adiustments OCT 16 - NOV 15, 2005 Page 1 of 1 Previaas Balame $65&17 Payments Cmlim and Adjeatments $.00 Ttaaeactions Tramtctiour $29.00 Finance Charge $15.6g 1 15 NOV PAST DUE FEE $29.00 New Balance $702.85 As a valued Capital One customer, you are eligible to receive a free Year-End Summary for this Minimum Amount Due $702.85 sped& account that recaps your 2005 cLageq provided yrnm aecount;s in good standing and Payment Due Due December 15, 2005 you have made transactions during the calends yea. Please call 1-877-794-4487 before December 31, 2005, to reserve your copy for this account We will begin processing orders in January 2006. Total Credit Line $300 Total Available Credit $.00 a yaw business and you deserve great benefm. We'd like your to know that your Credit I" for Cash $300 Platinum card benefits have been updated For details, visit wwwxgitdone.com/aedi=& and Available Credit for Cash $.00 dick on the Guide to Benefits link. Thanks for chooeing Capital One. 1-800-903-3637 You were areend a past due fee of $29.00 on 11/15/2005 bemuse your minimum payment was not At your eeryice received by the due date of 11/15/2005. To avoid this fee in the fan¢e, we recommend that you To all Coroner Rds6ons w tv q n a uo or ataln ovn& allow at last 7 business days for your payment to reach Capital One. C ca*d one 6-r St 1 , Hox SLC U 30265 St , MO MO 6 63179-0216 SLC, Llr 9413"M ti 16 Seed pgm-e t. s-d mquiri« t« Aunt Rees t-oe Proaesdag Finatue Charges Pkacrae reoarxrrdelfir in partaat irg6nw we Bafawe+asr grab rJade Grrr?s?t Pe.m ePR _ Cj? WE PURCHASES CASH 6665.72 LOO .0760MLP 27.7416 .07600%P 27.74% 615.66 L00 ANNUAL PERCENTAGE RATE applied this period 27.74% V PLEASE RETURN PORTION BELOW WITH PAYMENT 0000000 0 5178052471784443 15 0702850025000702859 New r!«p.;.,-MWm li--& -.74.q..Irlea,..:WR--H i-k Balance $702.85 Minimum Amount Due $7" 9- Ape, s Payment Due Date December 15, 2005 Gy Seise ZSP Total enclosed $ Hume Ptaae Ab mte Plase Account Number. 5176 QS24 T178 4411 a Fa.alAddr- $9032085551547452$ MAIL ID NUMBER Capital One Bank KAREN L SHOLLY P.O. Box 790216 1r1u1u11u1u11r1u1 r 105 E CUMBERLAND RD St. Louia, MO 63179-0216 stn, I? ENOLA PA 17025-2510 0 PkaxurdeyovamsatnmoberoaYv.ecbakor.Wm yorderatodejaywbktoC-,W-7Ow11asfacednailistAeenrlarrd VERIFICATION CAPITAL ONE BANK vs SHOLLY, KAREN L The undersigned does hereby verify subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities, that he/she is, ARYONNE MABSON, Authorized Agent, of CAPITAL ONE BANK, Plaintiff Herein, that he/she is duly authorized to make this Declaration, 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. ARYONNE MABSON Notary Public MA" _; HA DAVI S NE'I` R Y ` C", INI Y, GEORGIA y. !^ DID 5178052471784443 A049 WELTMAN, WEINBERG & REIS CO., L.P.A. ?v COS. --4 , SLR , W 0 SHERIFF'S RETURN - REGULAR CASE NO: 2008-00360 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CAPITAL ONE BANK VS SHOLLY KAREN L 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 SHOLLY KAREN L the DEFENDANT at 1545:00 HOURS, on the 18th day of January , 2008 at 105 E CUMBERLAND ROAD ENOLA, PA 17025 KAREN SHOLLY by handing to a true 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 14.40 Affidavit .00 Surcharge 10.00 00 4 Sworn and Subscibed to before me this day So Answers: ?n R. Thomas Kline 01/22/2008 WELTMAN WEINBERG REIS By: 4 ? k- - ; ? Deputy Sheriff of A. D. 1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff VS. KAREN L SHOLLY Defendant No. 08-360 CIVIL TERM PRAECIPE TO SETTLE, DISCONTINUE AND END FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: PATRICK THOMAS WOODMAN, ESQUIRE PA I.D #34507 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#6241214 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION 1 Plaintiff VS. Civil Action No. 08-360 CIVIL TERM KAREN L SHOLLY Defendant PRAECIPE TO SETTLE DISCONTINUE AND END TO THE PROTHONOTARY OF COUNTY: Settle, Discontinue and End the above-captioned matter upon the records of the Court and mark the costs paid. WELTMAN, WEINBERG & REIS CO., L.P.A. By: 70-. &444- A1," G-bmI "A.* --- PATRICK THOMAS WOODMAN, ESQUIRE PA I.D #34507 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#6241214 Sworn to and subscribed efore me the ?ay of FEBRUARY, 2,p' PU -M ` ' ,,,^ ? m ? ? -?,., ? ?? ?; ? -.?. ? ?. ? ' rf ? n7r.,. n.- ... `-- --? ?r-^r, ,?' ?P""3 - ? - y- F ? `7 ?.3 ?tc3 '??