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HomeMy WebLinkAbout08-2682 k IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff No: 0$- a(PIa 30t ??M VS. JUSTIN D EDELMAN COMPLAINT IN CIVIL ACTION 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 1400 Pittsburgh, PA 15219 (412) 434-7955 FAX: 412-338-7130 06376633 C N Pit ABR IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff VS. Civil Action No JUSTIN D EDELMAN 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: JUSTIN D EDELMAN 607 ERFORD RD. CAMP HILL, PA 17011 3. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXXXXXX8243 . 4. Defendant made use of said credit card and has a current balance due of $1241.13 , as of March 27, 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 21.050% per annum on the unpaid balance from March 27, 2008 . A copy of Plaintiff's STATEMENT OF ACCO UNT 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 , JUSTIN D EDELMAN , INDIVIDUALLY , in the amount of $1241.13 with continuing interest thereon at the rate of 21.050% per annum from March 27, 2008 plus costs. James Warmbrodt,42524 WELT EINBERG & REIS CO., L.P.A. 436 S ven h Avenue, Suite 1400 Pitt burg PA 15219 (41 43 -7955 FAX 41 -338-7130 06-V766 3 C N Pit ABR This law firm is a debt collector atting to collect this debt for our client and any information obtained will be used for that purpose. ?w N O N W U d U a ? y V pb p? C W g Ys g. •o ? 8 ?' o. °r w, s N UU? ?yy 4 W W 8 N 4 1 g? g? 'El .2 1 S6B98L O N r- N OM s a 0 0 0 0 r M ' O L r M 0 z N W ? M C N W N OD 3 d 3 1 N aUC 10 N N Q 10 N a O 'o z o w o u O O °• O O u L z - ? o a 0 o x a - L° N ? a Ln m to - ?o{SNpa c N Z V m ~ _ m F o ycpwpo o 3 x ? h u _ bB59T0 .m _ m 0 = N N m - N C w m co u - w z ?0 1w Im 0 _ z - b°2 - y u U W U _ r VERIFICATION CAPITAL ONE BANK (USA), N.A., successor-in-interest to Capital One Bank vs EDELMAN, JUSTIN D 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, TRACY TAYLOR, 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. (I'ACY T OR - r, /,/I-- N11"', JAMELA SNOLETARY NOTARY FUFLIC GFOP.ri A, Lit n:ALB X- !NTY MY COPS (MISSION EXF;RES NOV 4, 2011 4862362626648243 A049 WELTMAN, WEINBERG & REIS CO., L.P.A. O .W.1 O W V 00 s ( -73 [` J Cl"1 a SHERIFF'S RETURN - NOT FOUND CASE NO: 2008-02682 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CAPITAL ONE BANK USA NA VS EDELMAN JUSTIN D R. Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT EDELMAN JUSTIN D but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT & NOTICE , the within named DEFENDANT 607 ERFORD ROAD EDELMAN JUSTIN D CAMP HILL, PA 17011 PER EX-WIFE, DEFENDANT MOVED OUT NOVEMBER 2007. NO FORWARDING ADDRESS ON FILE AT POST OFFICE. NOT FOUND , as to Sheriff's Costs: So answw Docketing 18.00 Service 15.00 Not Found 5.00 R. Tho s Kline Surcharge 10.00 Sheriff of Cumberland County .00 f 48.00 WELTMAN WEINBERG REIS 05/08/2008 Sworn and Subscribed to before me this day of , A. D. copy FRom RECORD , I here unto set my han'3 ,n Tedit $06 of So M whe?CoaA rt Gib k Pa. Levi IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff No: -ar?aa Civil lern. VS. COMPLAINT IN CIVIL ACTION JUSTIN D EDELMAN 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 1400 Pittsburgh, PA 15219 (412) 434-7955 FAX: 412-338-7130 06376633 C N Pit ABR IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff VS. Civil Action No JUSTIN D EDELMAN 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 L 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: JUSTIN D EDELMAN 607 ERFORD RD. CAMP HILL, PA 17011 3. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXXXXXX8243 . 4. Defendant made use of said credit card and has a current balance due of $1241.13 , as of March 27, 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 21.050% per annum on the unpaid balance from March 27, 2008 . A copy of Plaintiff's STATEMENT OF ACCO UNT is attached hereto, marked as Exhibit "1" 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 , JUSTIN D EDELMAN , INDIVIDUALLY , in the amount of $1241.13 with continuing interest thereon at the rate of 21.0501 per annum from March 27, 2008 plus costs. James Warmbrodt,42524 WEL EINBERG & REIS CO., L.P.A. 436 S ven h Avenue, Suite 1400 Pitt burg , PA 15219 (41 43 -7955 FAX 41 -338-7130 06 66 3 C N Pit ABR This law firm is a debt collector atting to collect this debt for our client and any information obtained will be used for that purpose. O h ? N y U [" `' a a VUj ? ? pq- III a MW HIM c? W N I ?d SVOW? P. z u 6 s 3 3 m O 7- 7 u a . M ? E O ?r O 5t O M 0 N 0• M O? O ti N y M ^? N S 10 1O N N O M N 0 ao O O O O O O 0 0 8 ?e z L. a 0 0 ? a rn ? 7 o s N Ia a co a in G a - fps M n- ?Ux N 7 d' ? 685910 "L ?a =mom m_ a_ r .? H y( C1 r a? m CD mo C r• oxy bmo '4 wo .? uwu . r VERIFICATION CAPITAL ONE BANK (USA), N.A., successor-in-interest to Capital One Bank vs EDELMAN, JUSTIN D The undersigned does hereby verify subject to the penalties of 18 Pa.C.S. Section 4904 relating to unswom falsification to authorities, that he/she is, TRACY TAYLOR, 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. CY T OR t //I,-- NI'licti yCG,fk,'-; B';C'? •' <,'cS iy Y4, 2011 4862362626648243 A049 WELTMAN, WEINBERG & REIS CO., L.P.A. l?`r1 TAN l 81 -b V 8Z adV 0001 ` ;S -i ,I 0 3_,,IA?j J IN THE COURT OF COI IMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA) N Plaintiff as No. $0-2682 CIVIL TERM vs. PRAECIPE TO DISCONTINUE AND END WITHOUT PREJUDICE TO REFILE JUSTIN D EDELMAN Defendant 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. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#06376633 IN THE COURT OF ?OMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA) N Plaintiff vs. JUSTIN D EDELMAN Defendant Civil Action No. 80-2682 CIVIL TERM WITHOUT PREJUDICE TO REFILE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: SIR: 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 Plaintiff 1400 Koppers Buildi g 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#06376633 SWORN TO AND SUBSCRIBED before me this 26TH day PUB COMM NWEALTH OF PENNSYLVANIA Notarial Seal Heidi J. Kelly, Notary Public Of Pittsburgh, Allegheny County My ?ommlssiori E)Ores Nov. 4, 2009 Member, Pennsylvania Association of Notaries FILEDI--t r":ICE OF THE PPM ('NOTA?Y 2009 APR 14 A 9: 3 S 41 LAW", Fl.