HomeMy WebLinkAbout08-36004
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK (USA),NA
Plaintiff No:
VS.
RONALD G VANART
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
06467260 C N Pit VOC
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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
RONALD G VANART
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:
RONALD G VANART
39 STEWART PL
SHIPPENSBURG, PA 17257
3. Defendant applied for and received a credit card bearing the
account number XXXXXXXXXXXXXXXX9321
4. Defendant made use of said credit card and has a current balance
due of $3426.70 , as of May 01, 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
29.200% per annum on the unpaid balance from May 01, 2008 . A copy of
Plaintiff's STATEMENT 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 , RONALD G VANART , INDIVIDUALLY , in the amount of
$3426.70 with continuing interest thereon at the rate of 29.200% per
annum from May 01, 2008 plus costs.
James C:
WELTMAN,
436 Seve
Pittsbur
(412) 4
FAX: 4
064672 0
This law firm is a debt collector attemp
our client and any information obtained
rmbrodt,42524
INBERG & REIS CO., L.P.A.
Avenue, Suite 1400
PA 15219
55
8-7130
N Pit VOC
to collect this debt for
be used for that purpose.
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VERIFICATION
CAPITAL ONE BANK (USA), N.A., successor-in-interest to Capital One Bank
vs
VANART, RONALD G
The undersigned does hereby verify subject to the penalties of 18 Pa.C.S. Section 4904 relating to unworn
falsification to authorities, that he/she is, JAMELA SINGLETARY, 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.
LETARY
No Public
4862362522059321
A049
wELTMAN, WEINBERG & REIS CO., L.P.A.
ARYONNE MABSON
NOTARY PUBLIC
OEKALB COUNTY, GEORGIA
MY COMMISSION EXPIRES OCT. 29, 2011
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2010 JUN -7 PM I- 03
CUti. _ 1NTY
?Cf ?I?y:..• ? ?._s?rv
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK (USA),NA
Plaintiff
vs.
RONALD G VANART
Defendant(s)
No. 08-3600-CIVIL TERM
PRAECIPE TO SETTLE, DISCONTINUE
AND END WITH PREJUDICE TO REFILE
FILED ON BEHALF OF
Plaintiff
COUNSEL OF RECORD OF
THIS PARTY:
Lyndsay E Rowland, Esquire
PA I.D. #205520
WELTMAN, WEINBERG & REIS CO., L.P.A
1400 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR#6467260 SGB
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK (USA),NA
Plaintiff
VS. Civil Action No. 08-3600-CIVIL TERM
RONALD G VANART
Defendant(s)
PRAECIPE TO SETTLE DISCONTINUE AND END WITH PREJUDICE TO REFILE
TO THE PROTHONOTARY OF COUNTY:
Settle, Discontinue and End With Prejudice to Refile the above-captioned matter upon the records of the
Court and mark the costs paid.
WELT A , WEINBERG & IS CO., I.A.
By:
Lyndsay Rowla ,Esquire
PA I.D. 205520
WELTMAN, BERG & REIS CO., L.P.A
1400 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR#6467260
Sworn to and subscribed
Before mp,the
Day ofv?4
NOTARY PUBLIC
MMONVVtA?F PE:,:IASYLVANIA
Notarial Seal
Sheila G. Bevan, Notary Pudic
City Ot Pittsburgh, Allegheny ux,nty
My Commission Expires Nov. 15, 2010
Member, Pennsylvania Association of Notaries