HomeMy WebLinkAbout08-3168IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK (USA),NA
Plaintiff No: 08- 31108 ?idi( ?erw?
VS.
COMPLAINT IN CIVIL ACTION
MICHAEL T KULP
Defendant FILED ON BEHALF OF
Plaintiff
COUNSEL OF RECORD OF
THIS PARTY:
James C. Warmbr-odt,42524
WELTMAN, WEINBEIRG & REIS CO., L.P.A.
436 Seventh Avenue, Suite 1400
Pittsburgh, PA 15219
(412) 434-7955
FAX: 412-338-7130
06397990 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
MICHAEL T KULP
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
IN
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:
MICHAEL T KULP
649 BALTIMORE PIKE
GARDNERS, PA 17324
3. Defendant applied for and received a credit card bearing the
account number XXXXXXXXXXXXXXXX6767
4. Defendant made use of said credit card and has a current balance
due of $2700.20 , as of April 15, 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
19.150% per annum on the unpaid balance from April 15, 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 , MICHAEL T KULP , INDIVIDUALLY , in the amount of
$2700.20 with continuing interest thereon at the rate of 19.1508 per
annum from April 15, 2008 plus costs.
James C. W rmbrodt,42524
WELTMAN W NBERG & REIS CO., L.P.A.
436 Se enth Avenue, Suite 1400
Pittsb rgh, PA 15219
(412) 434- 955
FAX: 12- 38?-7130
0639799 C N Pit ABR
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.
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3,
VERIFICATION
CAPITAL ONE BANK (USA), N.A., successor-in-interest to Capital One Bank
vs
KULP, MICHAEL T
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.
TRACY TAYLOR
4,2011
4305982407776767
A049
WELTMAN, WEINBERG & REIS CO., L.P.A.
• SHERIFF'S RETURN - NOT FOUND
CASE NO: 2008-03168 P
COMMONTWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
CAPITAL ONE BANK USA NA
VS
KULP MICHAEL T
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
KULP MICHAEL T but was
unable to locate Him in his bailiwick. He therefore returns the
COMPLAINT & NOTICE ,
NOT FOUND , as to
the within named DEFENDANT
649 BALTIMORE PIKE
GARDNERS, PA 17324
KULP MICHAEL T
DEFENDANT NO LONGER OWNS GIVEN ADDRESS.
BELIEVED TO BE LIVING IN YORK SPRINGS - ADAMS COUNTY.
Sheriff's Costs:
Docketing 18.00
Service .00
Not Found 5.00
Surcharge 10.00
.00
Gy/Of 33.00
So answers: R. Thoma6 Kline
Sheriff of Cumberland County
WELTMAN WEINBERG REIS
05/28/2008
Sworn and Subscribed to before
me this day of
A. D.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK (USA) N.A.
Plaintiff
vs.
MICHAEL T KULP
Defendant
No. 08-3168-CIVIL TERM
PRAECIPE TO DISCONTINUE AND END
WITHOUT PREJUDICE TO REFILE
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#06397990
t..
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK (USA) N.A.
Plaintiff
vs. Civil Action No. 08-3168-CIVIL TERM
MICHAEL T KULP
Defendant
PRAECIPE TO DISCONTINUE AND END
WITHOUT PREJUDICE TO REFILE
TO THE PROTHONOTARY OF CUMBEERLAND 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 Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR#06397990
SWORN TO AND SUBSCRIBED
before me this 15TH day
of JANUA 9
N TARY P
COMMONWEALTH OF PEW4SYLVAM
NotWW seal
V4&* L Gait, Notary PubNc
Cky Of PRt kwO, AbOmW C=*
W Comp *Wm Ewi w July 15, 2010
Member, PennWvanfa Assodaftn of. Nohow
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