HomeMy WebLinkAbout08-2882IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK (USA),NA
Plaintif f No : Qa ~o2~g.2, ~~ ~C .,2..~'!'"~
vs.
EDWARD A BECHDEL
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
06466525 C N Pit BLK
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK (USA),,NA
Plaintiff
vs.
EDWARD A BECHDEL
Defendant
Civil Action No
COMPLAINT AND NOTICE TO DEFEND
You have been sued in court. If you wish to defend against the
claims set forth in th.e 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 ar.~d a judgment may be entered against you by the
court witYiout 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 AFl?ORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE
TO PROVIDE YOU WITH IIJFORMATION 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:
EDWARD A BECHDEL
208 CLEARVIEW RD
NEW CLJMBERLND , PA 17 0 7 0
3. Defendant applied for and received a credit card bearing the
account number XXXXXXXXXXXXXXXX9108
4. Defendant made use: of said credit card and has a current balance
due of $1449.73 as of March 31, 2008 .
5. Defendant is in dE:fault by failing to make monthly payments when
due. As such, the ent_'Lre balance is immediately due and payable to
Plaintiff.
6. Plaintiff is entitled to the addition of interest at the rate of
29.2000 per annum on 'the unpaid balance from March 31, 2008 A copy
of Plaintiff's STATEMENT is attached hereto, marked as Exhibit "1" and
made a part hereof.
7. Although repeatedly requested to do so by Plaintiff, Defendant has
willfully f`.ailed and/or• refused to pay the balance due to Plaintiff.
Wherei=ore, the Plaintiff prays for judgment in its favor and
against Defendant EDWARD A BECHDEL INDIVIDUALLY in the amount of
$1449.73 with continuing interest thereon at the rate of 29.200% per
annum from March 31, 2008 plus costs.
James C. armbrocit,4~5~4
WELTMAN INBERG & REIS CO., L.P.A.
436 Se ent Avenue, Suite 1400
Pitts rg PA 15219
(412) 434 7955
FAX: 412 338-7130
064 65 C N Pit BLK
This law firm is a dek~t collector atte ing to collect this debt for
our client: and any information obtaine will be used for that purpose.
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VERIFICATION
CAPITAL ONE BANK (USA), N.~.., successor-in-interest to Capital One Bank
vs
BECHDEL, EDWARD A
The undersigned does hereby verify subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn
falsification to authorities, that he/slie is, SHERYL GRAY, 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 faith in the foregoing Complaint in Civil Action are true and correct to the best of
his/her knowledge, information and belief.
Not i
PAMELA S1NQL.ErARY
NOTARY PUBLIC
GEORGIA, DEKALB COUfV'111
'~(`f cOr.?MISSION EXPIRES NOV4, 2011
5178052568109108
A049
WELTMAN, WEINBERG & REPS CO., L.P.A.
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