HomeMy WebLinkAbout08-2199IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK (USA),NA
Plaintiff
VS.
NICOLE M GRIMES
Defendant
No: O$- ))q 1 a-0 lest--
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 1400
Pittsburgh, PA 15219
(412) 434-7955
FAX: 412-338-7130
06365910 C N Pit SMI
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK (USA),NA
Plaintiff
VS. Civil Action No
NICOLE M GRIMES
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 (USA),NA is a corporation with offices
at 15000 CAPITAL ONE DRIVE RICHMOND , VA 23238
2. Defendant is adult individual(s) residing at the address listed
below:
NICOLE M GRIMES
1285 W TRINDLE RD
MECHANICSBURG, PA 17055
3. Defendant applied for and received a credit card bearing the
account number XXXXXXXXXXXXXXXX7946 .
4. Defendant made use of said credit card and has a current balance
due of $1343.72 , as of March 07, 2008 .
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
28.150% per annum on the unpaid balance from March 07, 2008 . A copy
of Plaintiff's STATEMENT is attached hereto, marked as Exhibit 11111 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 , NICOLE M GRIMES , INDIVIDUALLY , in the amount of
$1343.72 with continuing interest thereon at the rate of 28.150% per
annum from March 07, 2008 plus costs.
James W rmbrodt,42524
WELT EINBERG & REIS CO., L.P.A.
Avenue, Suite 1400
h
436 S te
Pith r h, PA 15219
(412,,J 4 4-7955
FAX;` 4 2-338-7130
063,55 0 C N Pit SMI
This law firm is a debt collector attempting to collect this debt for
our client and any information obtained will be used for that purpose.
o
W
j
a
O
U
5
a ?
g
fl- j
i
a
a
A g ,o o?"
a 5?
aW y
? O
?n
v
i
8gg? ??? $g??
V z
?o
ca
?J
z
g?
?f
I
S6CLLL
N
a
r
?
o?
0
°
o
0
0
a
`
p
O
r g
z p, §
8
,O
G. ?
e
d
f ?
A
3 z
S
0 0
m ?
N
O 1O
M
r
, N
y •o
? g
F
o
u o
o
.
v
iI
s
II
I?
fln
4
M
L
z
N ?
N ?
r n -
N
m Q -
m ad _
0. F U
N
nla3? -
m O N
xHro?
zNx _
111111111
6ETLT0
=m
m-_
o_
n
ro-
H
? m°
mmz =
4" r
oo
b co O _
vau _
r
VERIFICATION
CAPITAL ONE BANK (USA), N.A., successor-in-interest to Capital One Bank
vs
GRIMES, NICOLE M
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, MAISHA DAVIS, Authorized Agent, of CAPITAL ONE BANK (USA),
N.A., successor-in-interest to 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.
MAISHA DAVIS
Jel--
Nota1
JAMELA SINGLETARY
NOTARY PUBLIC
GEORGIA, DEKALB COUNTY
MY COMMISSION EXPIRES NOV 4, 2011
4862362606527946
A049
WELTMAN, WEINBERG & REIS CO., L.P.A.
NO
,
O l D ' C' rr?
?
cr,
SHERIFF'S RETURN - REGULAR
CASE NO: 2008-02199 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
CAPITAL ONE BANK USA NA
VS
GRIMES NICOLE M
DAWN KELL , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
GRIMES NICOLE M the
DEFENDANT , at 2107:00 HOURS, on the 21st day of April 2008
at 1285 W TRINDLE ROAD
MECHANICSBURG, PA 17055 by handing to
MELISSA BAKER MOTHER
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: So Answers:
Docketing 18.00
Service 6.00
L?,?, ! -ell
Affidavit .00
Surcharge 10.00 R. Thomas Kline
.00
?//a8/c8 ? 34.00
04/23/2008
WELTMAN WEINBERG REIS
Sworn and Subscibed to By: % j
QL?'1
&
before me this day 1?
Deputy Sheriff
of A.D.
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK
Plaintiff
VS.
NICOLE M GRIMES
Defendants
Civil Action No. 08-2199-CIVIL TERM
TO THE PROTHONOTARY OF COUNTY: i
Please kindly Settle Discontinue the above captioned matter upon the records of the Court with prejudice
and mark the cost paid.
WELTMAN, WEINI3ERG & REIS CO., L.P.A.
Sworn to and su
Before me the
Day of MAY-11
NOTARY PU
By' -- -
JAMES C. A
PA I.D. 42 4
CO.
WEL TM WE BERG & RI
1400 KO PERS I'DG.
436 7T AVE
PITTS UR PAi 15219
(412) 34- 55
WW 0 65910
i
I
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Wendy L. Gault, Notary Public
City Of Pittsburgh, Allegheny County
My Commission Fxoires . July 15, 201 0
Member, Penns',)%,."l of Notaries
C'? ?,,,
?,;?. ?
ti -'
,, ..
? °? ?'t?
?' °;????
?
?- ??.:? ? r;
? ?
.,C