HomeMy WebLinkAbout08-2936IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK (USA),NA
Plaintiff No: D$" Igz(v 0-iVil --Twrp%
VS.
MATTHEW J MURPHY
COMPLAINT IN CIVIL ACTION
Defendant FILED ON BEHALF OF
Plaintiff
COUNSEL OF RECORD O
THIS PARTY:
James C. Warmbrodt, 2524
WELTMAN, WEINBERG & REIS CO., L.P.A.
436 Seventh Avenue, Suite 1400
Pittsburgh, PA 15219
(412) 434-7955
FAX: 412-338-7130
06398623 C N Pit AB
10
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK (USA),NA
Plaintiff
VS.
MATTHEW J MURPHY
Defendant
Civil Action No .Q
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 s 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 ONC IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHON THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFI E MAY BE ABLE
TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT Y OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO F E.
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 corpo
at 15000 CAPITAL ONE DRIVE RICHMOND , VA 23238 .
2. Defendant is adult individual(s) residing at the
below:
MATTHEW J MURPHY
222 HERMAN AVE
LEMOYNE, PA 17043
3. Defendant applied for and received a credit card
account number XXXXXXXXXXXXXXXX3599 .
4. Defendant made use of said credit card and has a
due of $2277.74 , as of April 08, 2008 .
ion with offices
ss listed
ing the
t balance
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
29.200% per annum on the unpaid balance from April 08,
of Plaintiff's STATEMENT is attached hereto, marked a:
made a part hereof.
at the rate of
2008 . A copy
Exhibit 111" and
7. Although repeatedly requested to do so by Plaintiff, Defendant has
willfully failed and/or refused to pay the balance d e to Plaintiff.
Wherefore, the Plaintiff prays for judgment in its favor and
against Defendant , MATTHEW J MURPHY , INDIVIDUALLY , in the amount of
$2277.74 with continuing interest thereon at the rate of 29.200% per
annum from April 08, 2008 plus costs.
James C. Wa mbrod
WELTMAN' WE NBERG
436 Se ent Avenu
Pitts rg , PA 1
(412) 43 -7955
FAX: 4 -338-7130
063 8 3 C N Pit
1,42524
& REIS CO., L.P.A.
Suite 1400
5219
kBR
This law firm is a debt collector attefivpting to colle t this debt for
our client and any information obtained will be used or that purpose.
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VERIFICATION
CAPITAL ONE BANK (USA), N.A., successor-in-interest to Capital One Bank
vs
MURPHY, MATTHEW J
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.
AYLOR
No is
JAMELA SINGLETARY
NOTARY PUBLIC
GEORGIA, DEKALB COUNTY
MY COMMISSION EXPIRES NOV 4, 2011
5178052460423599
A049
WELTMAN, WEINBERG & REIS CO., L.P.A.
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SHERIFF'S RETURN - NOT FOUND
CASE NO: 2008-02936 P
COMMONTWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
CAPITAL ONE BANK USA NA
VS
MURPHY MATTHEW J
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
MURPHY MATTHEW J but was
unable to locate Him in his bailiwick. He therefore returns the
the within named DEFENDANT
222 HERMAN AVE
MURPHY MATTHEW J
NOT FOUND , as to
LEMOYNE, PA 17043
PER POST OFFICE, DEFENDANT MOVED TO
16227 TRENTON RD UPPER CO, MD 21155.
Sheriff's Costs:
Docketing 18.00
Service 16.00
Not Found 5.00
Surcharge 10.00
/ Ic/6'/ ?1, v 49-000,
So ar rs :
fqs/ Thomas Kline -'
Sheri of Cumberland County
;\WEL MAN WEINBERG REIS
05/15/2008
Sworn and Subscribed to before
me this day of
A. D.
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK (USA),NA
Plaintiff No: 08- aq-N. Civi l -errn
VS.
MATTHEW J MURPHY
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
06398623 C N Pit ABR
? IE COPY FROM RECORD
A Teshmorty whereof, I two unto set"hand
,ind t" mW of said Cow at Cadl*, Pa.
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK (USA),NA
Plaintiff
vs. Civil Action No
MATTHEW J MURPHY
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
r
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:
MATTHEW J MURPHY
222 HERMAN AVE
LEMOYNE, PA 17043
3. Defendant applied for and received a credit card bearing the
account number XXXXXXXXXXXXXXXX3599 .
4. Defendant made use of said credit card and has a current balance
due of $2277.74 , as of April 08, 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
29.20001 per annum on the unpaid balance from April 08, 2008 . A copy
of Plaintiff's STATEMENT is attached hereto, marked as Exhibit 11111 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 , MATTHEW J MURPHY , INDIVIDUALLY , in the amount of
$2277.74 with continuing interest thereon at the rate of 29.200% per
annum from April 08, 2008 plus costs.
James C. Wa mbrodt,42524
WELTM??T, WE NBERG & REIS CO., L.P.A.
43G Se ent Avenue, Suite 1400
Pitts rg PA 15219
(412) 43 -7955
FAX: 4 -338-7130
OG3 8 3 C N Pit ABR
This law firm is a debt collector atte?6ting to collect this debt for
our client and any information obtained will be used for that purpose.
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VERIFICATION
CAPITAL ONE BANK (USA), N.A., successor-in-interest to Capital One Bank
vs
MURPHY, MATTHEW J
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.
TRACttAYLOR
Not b is
lvlY GJ?4?'t.?Lr . , .. . ... r•n " ?`lt/ 4.2Q1?
5178052460423599
A049
WELTMAN, WEINBERG & REIS CO., L.P.A.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK (USA),NA
Plaintiff
No.: 08-2936 CIVIL TERM
vs. PRAECIPE TO SETTLE, DISCONTINUE
AND END WITHOUT PREJUDICE TO REFILE
MATTHEW J MURPHY
Defendant
FILED ON BEHALF OF
Plaintiff
COUNSEL OF RECORD OF
THIS PARTY:
JAMES C. WARMBRODT, Esquire
PA I.D. #42524
WELTMAN, WEINBERG & REIS CO., L.P.A.
1400 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR#6398623
r1 1
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK (USA),NA
Plaintiff
vs. Civil Action No.: 08-2936 CIVIL TERM
MATTHEW J MURPHY
Defendant
PRAECIPE TO SETTLE. DISCONTINUE
AND END WITHOUT PREJUDICE TO REFILE
TO THE PROTHONOTARY OF CUMBERLAND COUNTY:
SIR:
Settle, 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 )n' tiff
1400 Kopp rilding
436 Seve h nue
Pittsbur , P219
(412) 4 4-79SWORN TO AND SUBSCRIBED
before me this ) day
of , 2008
NO ARY C
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Wcr_y ry e. ?ypublic
Cit OfPt::? , _:;enyCounty
y ,? 2010
P9y Commis- Y°n yuiy ,
ution of Notaries
pennz;yiv ni t+s'3^ ci
member,
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