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Home My WebLink About08-3938 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA), N. Plaintiff No: D$- 3g38 Gv?t VS. MICHAEL E BEECHER Defendant COMPLAINT IN CIVIL ACTION FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: Matthew D. Urban WELTMAN, WEINBERG & REIS CO., L.P.A. 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 (412) 434-7955 FAX: 412-338-7130 06664117 C N Pit IAS IN THE COURT OF COMMON PLEAS OF C:vAIBEi I,kN?' :'C;L-NrzY, tT-E1,R1SY1-\TkTI.e CIVIL DIVISION CAPITAL ONE BANK (USA), N. Plaintiff VS. MICHAEL E BEECHER Defendant Civil Action No COMPLAINT AND NOTICE TO DEFEND You have been sued in court. If you wish to defend. agains->'. the claims set forth in the follow.`:ng pages, you must take action within twenty (20) days after this complaint and notice are ser,r:_:d, by entering a written appearance personally or by an attorney and filin_, in writing with the court your defenses or objections t:o 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 rlaimed in'the`ccmplaint 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 LN4YER 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 P_ LAWYER, `T'HIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REIUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA.1701, (717) 24-9-3166 7. A1tAough•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 E BEECHER , INDIVIDUALLY in the amount of $4906.71 with continuing interest thereon at the rate of 27.600% per annum from May 15, 2008 plus costs. Matthew D. Urban WELTMAN, WEINBERG & REIS CO., L.P.A. 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 (412) 434-7955 FAX: 4127338-7130 06664117 C N Pit iAS This law firm is a debt collector attempting to collect this debt for our client and any information obtained wil be used for that purpose. f 500012 CaPft CW I what's in your wallet7' IT'S STILL NOT TOO LATE. Your account is unusable. But, we can help you prevent further damage to your credit record. Please pay the amount due on your statement within 30 days. Remember we're here to help! Let's work together to find a solution that's right for you. You can make a payment with our f= check by phone service or speak to an associate by calling 1.800.955.6600. ® 2006 Cayitd One Services, Inc. Capital One is a federal y regiaemd service mark. All rights reserved 500012-08503 FINANCE Previous Balance Payments 3 Credits CHARGE Transactions Now Balance Minimum Payment Due Date $3,826.16 - $0.00 + $92.75 + $39.00 $3,957.91 $95 X91 Sep. 07, 2007 Jul. 14, 2007 - Aug. 13, 2007 Page 1 of 1 MasterCard Platinum Account 5178452347784888 Your Account Information TOTAL CREDIT LINE $3,000.00 TOTAL AVAILABLE CREDIT $0.00 CREDIT LINE FAR CASH $3,000.00 AVAILABLE C OR FOR CASH $0.00 Finance Chary (Please see reverse for important Information) Bapppl ttoo Periodic Ccrrespording CFWK HARGtEE Purchases $3,879.57 0.07712% D 28.15% $92.75 Cash $0.00 0.07712% D 28.15% $0.00 ANNUAL PERCENTAGE RATE applied thb period: 28.15% ® At Your Service 1.800401.3837 To ar Cuatamr Relebm a b repel a bat a sWm card ® Send payments to. CWU One Bank • P.O. Box 70884.OwWM, NC 28272-0884 A Send Inquiries to: Capital One • P.O. Bon 30285 • Salt Lake City, UT 84130.0285 rvu nM FW AT LEAST THIS AMOUNT You're behind by five payments so we've permanently suspended your charging privileges. H you don't make a sufficient payment in the next 7 weeks your account is at risk for being charged off and reported to the national credit bureaus. Please don't let this happen. H you're feeling overwhelmed, call us at 1.800.955.6600. Well work with you to resolve this matter. Payments, Credits 8 Adiustments Transactions $39.00 1 07 AUG PAST DUE FEE Under terms previously disclosed to you, some or all of your Annual Percentage Rates (APRs) have been increased since your account was past due twice in the past 12 billing cycles. K your rates have already increased, subsequent delinquencies extended the duration of the increased odes. Remember: If we receive your minimum monthly payment on time for 12 consecufive billing cycles, this account will be reviewed for a possible return to your Non-Introductory APR. Your account is 90 days peat due and your Payment Protection coverage has been suspended. As stated in your Payment Protection agreement, your coverage and monthly charge will be reinstated once your account is no longer 90 days pest due. You may still be eligible for benefits to be paid to your account for loss events described in your Payment Protection agreement. Call Stonebr idge Benefit Services at 1-888.527.8904 to seed your situation quaNfies for benefits. You were assessed a past due fee because your minimum payment was not received by the due date. To avoid this fee in the future, we recommend that you allow at least 7 business days fa your minimum payment to reads Capital One. 6056 506 1 07 13 070813 PAGE 1 of 1 OlDM6056 PLEASE RETURN PORTION BELOW WITH PAYMENT OR LOG ON TO W W W.CAPrrALONE.COM TO MAKE YOUR PAYMENT ONLINE 0 5178052397785888 13 3957910378540957919 Cap#WO W I what's in your wdM?* Account Number. 5178-0523-9778-5888 New Balances ' Minimum Payment Due Date $3,957.91 $957.91 Sep. 07, 2007 PLEASE PAY AT LEAST THIS AMOUNT Amount Endosed c::= Capital One Bank I,Irrlrrl,lrl,lrllrrrl P.O. Box 70804 Charlotte, NC 28272-0964 LrLlLdrrddlrrdrdJllrrdrrlJrrLtLdltrLdnlLrrll Please print address or phone number changes below using blue or black ink. Address Home Phone Altemrte Phone E-mail address r& #9022666080032132# MAIL ID NUMBER MICHAEL E BEECHER 515 S VEST ST APT B CARLISLE, PA 17013-3844 !urlllarlllrnnrllnllurllrlalululrlullnrlnlullnlr Please write your account number on your check or money order made payable to Capital One Bank and mail with this coupon in the enclosed envelope. MICHAEL E BEEGHER 4 ? a Y ? VERIFICATION CAPITAL ONE BANK (USA), N.A. vs BEECHER, MICHAEL E 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, SHARON REUBENS, Authorized Agent, of CAPITAL ONE BANK (USA), N.A., 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. SHARON REUBENS Notary Public 5178052397785888 A049 WELTMAN, WEINBERG & REIS CO., L.P.A. O Z O ORD C4 s c.> r (,)A SHERIFF'S RETURN - REGULAR CASE NO: 2008-03938 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CAPITAL ONE BANK USA NA VS BEECHER MICHAEL E MICHELLE GUTSHALL , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon BEECHER MICHAEL E the DEFENDANT , at 0014:10 HOURS, on the 9th day of July 2008 at 515 S WEST STREET APT B CARLISLE, PA 17013 by handing to LISA BEECHER WIFE OF DEFENDANT a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 5.00 Affidavit .00 Surcharge 10.00 7 J??oP' Qom. .00 ? 33.00 Sworn and Subscibed to before me this day So Answers: R, rI'homas K ine 07/10/2008 WELTMAN WEINBERG & REIS By: Deputy Sheriff of , A. D. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA) N.A. Plaintiff No. 08-3938-CIVIL TERM vs. PRAECIPE TO DISCONTINUE AND END WITHOUT PREJUDICE TO REFILE MICHAEL BEECHER Defendants 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#06664117 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA) N.A. Plaintiff vs. Civil Action No. 08-3938-CIVIL TERM MICHAEL BEECHER Defendants PRAECIPE TO DISCONTINUE AND END 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: 1", _ Attorney for Plaintiff 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#06664117 SWORN TO AND SUBSCRIBED before^ e this day of LIC City Of h, ^ ' , MyCcmfo ,? ° C, -? . ; y ?i n . ? . 4 ? „.n.-y y j.,.6w ?? 1 ?'? 1 - ru t - ? L.<