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HomeMy WebLinkAbout08-4016IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff VS. DARLENE M JUMPER AKA DARLENE JUMPER Defendant No : Ll G"4 1 "? cCNI COMPLAINT IN CIVIL ACTION 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 06568765 C N Pit SMI 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 , DARLENE M JUMPER , INDIVIDUALLY , in the amount of $1782.19 with continuing interest thereon at te rate of 28.990% per Ii annum from May 22, 2008 plus costs. James Warmhrrodt,42524 WELT WEINBERG & REIS CO., L.P.A. 436 S enth Avenue, Suite 1400 Pitt b rgh, PA 15219 (41 ) 34-7955 F 12-338-7130 06 68 65 C N Pit SMI This law firm is a debt collector attting to collect this debt for our client and any information obtain will be used for that purpose. Ii Ca- to ^s First 3 months half-price a moMir 39.96/mo. ttlareafta'r 7 9 4 SIOM UP TODAY: ' 1-877-7784207 Mention Offer Code: CORAL Or visit www.peoplepc.coni/go/coral peoplepc- online N-11 A better way to Internet PeoplePC Online offers the features you would expect from higher-priced Internet Service Providers at half price for the first 3 months! ® Email Virus Protection ® Pop-Up BlockerT11 Spam Controls Smart Dialer $? Phisher Security Internet Call Waiting PLATINUM MASTERCARD ACCOUNT 5291-0716-3737-9338 JUN 04 - JUL 03,200-6 Page 1 of 1 Account Summary Payments, Credits and Adjustments Previous Balanm $1,536.61 Payments, Credits and Adjustments X00 Transactions Transactions C Financ Charges $35'04 137.04 1 03 JUL PAST DUE FEE $35.00 New Balance $1,608.65 You were messed a Pau due fee of $35.00 on 07/03/2006 because your minimum payment was not Minimum Amount Due $1,608.65 received by the due date of 07/03/2006. To avid this fee in the fume, we recommend that you Payment Due Date August 03, 2006 allow at least 7 business days for your payment to reach Capital One. Total Credit Line $800 Total Available Credit $.00 Credit Line for Cash $900 Available Credit for Cash $.00 At your service To all Customer Re xdt w to report a lest or stolen card: 1-800-903-3637 For free cruet twmnt aetvue and apedal mstoraee effms, log on to: www rapitdone.com Smd parvenu to Send iagnirsn t. Attn: Ranmanoe Proeeaing Capita One Bank Capiw oft P.O. Box 7%n6 P.O. Box 30285 St Louis, MO 63179-0216 SLC, UT 84130-0285 Important Account Information Take control and Startppaayyrrtt?ugg your bill online for free. Eliminate the hassle 0 writing d wJL% finding camps, and sealing envelopes Everything you need to access, review, and pay your bill is available online. Our website offers you a convenient, simple, and secure way to manage yow account Visit www.capitalone.com and register year account to start simplifying your life today! m 7 Finance Charges e w revertetiAe * impwaw titA?/a tm?latan Bslerrrarr Perie& ? ME ePftldto rsk 1:17AK PURCHASES $1,554.43 .0794AP 2899% $37.04 CASH $.00 .07942%P 2899% $.00 ANNUAL PERCENTAGE RATE applied this Period 28.99% T PLEASE RETURN PORTION BELOW WITH PAYMENT : oft ap ow 0000000 0 5291071637379338 03 1608650020001608658 Pkmeprdd-riag.W- e-uwiraa q. kekw-Vuro.u.k ink New Balance $1,608.65 Minimum Amount Due $1,608.65 s eet Apt 4 Payment Due Due August 03, 2006 Cary Smn ZIP Total enclosed $ 1 :1 Home phone Alwe Phone Account Number. 5291-0716-3737-9338 a EmaSAddces #9018562612295238# MAIL ID NUMBER DARLENE M JUMPER r Capital One Bank P.O. Box 790216 650 CONODOGQUINET AVE m CARLISLE PA 17013-8971 St. Louis, MO 63179-0216 ° asae>? 1111 1111 nsrI rrrsurI II III I ?uurrn?u1r1 PA%w waste yo acw at Namba onyx Jwl m money order madepayable to C#Oal0WBmik and mail iN theexdaed errodape. peoplepc- online u A better way to Internet. 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Grew Fortiori You will hne a mHman grace period of 26 days rd r is arrnce er on row puolaase, - beuhcs trades, raw sped pudreee and row od- civinism Ii Pay your tow assaini 1. a id In d titno for I k to he credited Notke for pafor payrrwu and In ne focredited by your Thad sramnrent fe,r rid pipe W tr b In amtlonI d?iere is gre?oempetlod on any trarectlon If you do not pay the mml 'New bWrm.' b. Aeanalnr Fihstss (7rys. Traraactlor With are not =L den of imagers .=_2 Tram. =) transaction h proosamed to your Account erato d3) from the Ast calendar day of ri cumk bli plebe Additionally, If you dM not pay the -New Balance from the previous bip period h fu, Ara,ce Hurries cefehr! m accrue to und! rsy aridr . a arm eris id in rs : wri rt TN. n that you mn you pay the eldm rbw Bala,hce htlcated on the front of your nawtxe by the mi sucanea hrI ' dam, but did not do se for the previous ammi Ur"M Amos danges re added m th. ?r?b esgtam of your Accors. tc. Mirase Fit- Orge. :"*= idNp period tlut vo r account Is sbject to dram, • miri t rrea `ursfroflanriMimiW k.. d cram!?soW t o dfbfebh.aa,rA,nhe bua m ihimm a ondac duns. url to do a ed neptra of your account. t d Thr to to notpleased- ed asepleased- - any y or fir as m finance sfinance rg drapey. rm reserve the dy nos for any ova, being period covered by pHs 100"a read, we take The b tre subtract ed bdanoe a eaehaemigniient esdh day, aldpdtlaia?annysnnesw the code N on tM statement roe Balance Rah Applied T? o also subtract any upaitl trance duq)e Included in to bstahee of each s .1 This ghsa r the ddY balsas o/ eedh crag t. T for hen,p uq ally did y Dalarhow? calm number of days In The period Tib glues u the ,.eryp dry bid- m each megwm. 3. Armed va+saga Pb. rIAP1lA a. Ths tam 'Aonhrl Polmnrage Rats' may appear as APR' on ri from M 1Hs st WTL i If the code P Q+rime). L 13-mo. LIBOR), C Mordecai of rIof Depo rm a S (BarivArd Pins) appears on the front Iwo nnemwertnr senpexorthdmnhgri pedode ratow, to pptl RATES False and d AWAAL PERCENTAGE c fray vary ,frftaM may maps or demwse based on the sated Indoor, as foul an The War Straer JbazW, plea to maryh proMady dbdosad m you Ttrw tlhrpw vA he w an the flat day of you hiRp period cowed by V. pedodc aaeman ending ctober. h ri martin Jrarry, *0 c. If the code D (Prins), F 1 -Frio. Bor 0 (3•,nc. UBOR Repriced Moral" the from sutenart next to The atebI ri pr'- y aTand oorroaoonhdne AN A1 of L PHiC Wl E RATER fwy wry moWey annddrwincrease or daaaame based on the started hdcers, as feed in The Wadi Surat Ja=41 the m igih pavfady disclosed to you. These vii he etncaw on The ant dint of van biim aelod 4. A.Mwmt of Lab, Ovaget and Reen W Payrnrt Few. Your account win be assessed nc moro thn two of the few listed hero Ow oocrr ou,nn ary bnahg peead. under the temm Of Your customer g ma , we remew the di m vwiw or not to asaw row bco vadhakrt alor iicstlon to vhhnut vwlving ore riglmt to eaaese dr acne or .radar at • leer One. &JR-imili You Account IF ... bendip for appears ah the frail of this staemem, you hove 30 days from the dins aim sstrmm was mNed to you to avoid paying the fare or to law audit fee cmdted to you if you caned you accent. Drip this period, you may cult! e m caw your account without hevip m pay the memberdip Ise. To CJIICBI you aeeard, you m notify us by caahg our Cmtaner Relrtlae Depnan ament and pay y?u New 8alai in full (excl d,p ri menhbsrasp fee) prior to to and of the thirty-dry period. awe e III you clares, your rr ace tvA by crtrp our Uepamad. You must deamy Y,sO cratlt w1d1s) and account access docks, cancel a pmmg hodzed being, . your aeopmt. If you do not cancel and comm udr preaWhalzed bnip annparenu, we wine consiydeerr ao?cou t. Adddarlly,yyaw account We not be dosed we you Pay all amorous you owe us I I I n: any trareadae You hr autlodied, Aha ce eha es, pea due rip, owtlntit fame, returned privni fees, cash advance few aid any oast fees assmnd to your steam. You ere MOP" is for sere anctnm wader doeo unutorheym at kraured abagi m ow dnm you rmWam to dae the you sgcoen m dose the astern. THa ,nay resit in surges appeadmg on your accent afla you hove y.mr scour if k hr dfee* been doeea her eumnpm, if you aaiodzed • putlms from • mmetrm ad we mceiw the be semi from di read -9 aka your accent Iw been doasd, yar aowtru wN he reopahed the amour 4 the hr? be added to You account, and you vat be fa payment. H team Is a m ckN?ppdfaf efmscocurri the ri we ucontinue m8 the sooouk balance hw been in M as dMhed above. 2d, card a ccent canna be 7. =Y==Y- arty Internet gsmbip verhr?scUora. ralrnh. Whrr you 8. 161Me Abort EWdmrAo s payment. mewk fu arat to sGr use infam nion fyo your dnd to males a ors tine sleetlonid firel awwfa from you bank account or to precep the ?? as a check uwwocdel. What we pre kM,==," rmatlan 1, your drat m make an aNaroft rud rrarwW, lends may be wMndrawn from you bank account as moon as the mane day we ,xdveyar ,,no, ad you we not mcehe your drdk heck ft- your financed BIWNG RIQi SUMMARY (h Caw Of Erma Or Quwdar About Your BBD B you tf** your bN Y wmp, or If you need more Mfamat- on a traowdm a bill, wdm to u on a aeparare drat w moon p possible a the add- for hhmdrlee darn an ri from at No statement. We must Iran from you nc lacer than e0 days Non ws male you the ion hN on vlidh ri anal a Prieblen appeared. Yw vh sell our Qrtoma( Rdatlom nrriber, but dung re wU not fenovlrhg prpave, Your dyda. In our easr, give u the hhIts sure your rune and account number, ri dollar snare of the suspected error, a description of ri enor and an a plaMllal, N possible, awAv you believe there is an error; or if You nwd more Information, a description of ri hem you ore vrmmaa abort. You do not teve to pay any anortt h lade mar are h, but you In ni m peal ri parr Of yon riot are nor n you . vve h vaom yea wwdm. we earn quesid: fep- orl you p estion. a halos airy emir to coNsGt the anent you mueslorh. i,t Specal Ikb For Crack Card Pudmw If you have a problem wit to quality of property a live Maned ih You nilh m earoet p,elian With the mm yonmay has ri agd not to pay he remaining the papetty or saviors. You hove Wa protection only wean tpr pudwepks was trore Mhrh $60.00 and ri pumwe was rode ih your hams due or vaieih 100 ntMs of yam tWN addasa M we own or operante to advardmmM mafroherik,pamifaty we malled a aeMaa, N pkntlrwea am wyaed mgaNer of arum a btsYm of prchre.) Rease mtatber m sign N oormapadeoe. t Desks ro! apply m oonavara aorrcm& card accaaas x Does -r apply m t +nom nmt- .* corny aroma t epporu ?ttce?k?deahmntri n giWry Protection: see our apital ?is a wfederallyr??. t md =V26. let Co4ordat All 11" Aver* DNy Ntlaltsa fireI I No. I Ladrawl. a. Fiume do," Is calculated by tmadplyi to Nfy, (advane Wa ras, spend trader, ad special pure came) by the mnwpe dne dally prattle mte(W tlrt hers been pnevfoely direlased m you Al thr end of each d. drip the Ihnrp oabd, we apply the Ihsaotlc ran talon writ aallma,e of en seeoak m ftr Wars of we ad trdae to and daily ra tioOar m ? your the me Mftr we si each rerla frmn wdh aeorrak a lea rite taut pt Acri Area dhanps for your ameat. To get ris, balance fa each si - of your account, von taken the bslaflpe fa each mevrrat and add new trrradkna acre any fnrer dr tm caleui aed an the Ihreviar dsys for thou asIII We Then abtraa aW prYmnm a mode posted as of the dry that am Nooma m the eaO re, t Ti Owe m the reforms dry balance Isdahmf04n"antva ash Y=c, .`pOe?Bfam;mm n ?rpdto'? If yea mar bdarce map zoo or a aadt anoan), row traradfor whkh past to your pudms or spectra purdsirs, ul ss Pam not ? m? ,gyp Nbd. We do di 6dnc?ae togetlrr a,d dvfdlp the sun by tit mbar of to days h tit m+rerr 6§kp cycle. To ealcrrisse ,r tad Areadrgs, " Yru &wmW dry:=cYaby tit m cr eip enaa ? of than m y do bWq be a enyn Wdw m between tuft calculation and the arrant of Arne i If the .27.== tram of IN. sW%_n nod m 'eaaance Ram A-DW To,- we rnua iy fit Yrpeten Ilsdom Payments you mN m us wall be credited to you accent as of The business day we recelw k provided (1) you sad to better patlon of tlis summon and your deck n the enclosed mdtta ce anvdape ad (2) your psyman is mwiwtl n w ant by 3 p.m. ET (12 moan Pr). Please allow a Mm tw (6) business days for p=W delivery. Paymars relived by u at any Won ioeatiarh or in any oga blur mry rot M eatlteE w as of the may, we modus Tram. Our business dare +re 6$amr tl.pWr smrd. , sxdudnf ri• PNps G nor us atapNs paper dpi prepartp par payment When you send a a deckW, you Modze us m robe a me tkw eNmm transfer GNt mr yo r belie ?c t 04 111,11, mr ? dock muatlmri+ppw ms a paper an cinder aeW k?emp tho bNkp cycle oven if mart by son eat star. If we camp pawn the transfer, you audodz. VERIFICATION CAPITAL ONE BANK (USA), N.A., successor-in-interest to Capital One Bank vs JUMPER, DARLENE M 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, DUDLEY TURNER, 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. Uvonda S. Brooks Notary Public Douglas County, Georgia My Commission Expires tary Public February 29, 2012 5291071637379338 A049 WELTMAN, WEINBERG & REIS CO., L.P.A. N W Ul C?, 1L N d ? A T f llz?? SHERIFF'S RETURN - REGULAR CASE NO: 2008-04016 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CAPTITAL ONE BANK (USA) NA VS JUMPER DARLENE M ET AL DENNIS FRY Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon JUMPER DARLENE M DEFENDANT the at 0009:30 HOURS, on the 12th day of July , 2008 at 650 CONODOGQUINET AVE CARLISLE, PA 17013 by handing to DARLENE M JUMPER AKA DARLENE JUMPER, 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 Service Affidavit Surcharge L;L 18.00 5.00 .00 10.00 nn ? .3.5. VV Sworn and Subscibed to before me this day of So Answers: r-r- ??? . R. Thomas Kline 07/14/2008 WELTMAN, WEINBERG & REIS By: Derputy Sher' A.D. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA), NA Plaintiff vs. DARLENE M JUMPER AKA DARLENE JUMPER Defendant No.08-4016-CIVIL TERM PRAECIPE FOR ENTRY OF JUDGMENT BY CONSENT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: Matthew D. Urban WELTMEN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 FAX: 412-338-7130 WWR#6568765 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA), NA Plaintiff vs. Civil Action No. 08-4016-CIVIL TERM DARLENE M JUMPER AKA DARLENE JUMPER Defendant PRAECIPE FOR JUDGMENT BY CONSENT TO THE PROTHONOTARY: Kindly enter Judgment against Defendant, DARLENE M JUMPER, in the amount of $1,779.77 plus costs, based upon the consent of the parties. CONSENTED TO: WELTMAN, WEINBERG & REIS CO., L.P.A., AKA DARLENE JUMPER, By: Attorney fof Plaintiff DARLENE M JUMPER By: 0a.+c 44":z. 1'Yl , Q 2?t> Defendant WWR#6568765 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA), NA Plaintiff vs. Civil Action No. 08-4016-CIVIL TERM DARLENE M JUMPER AKA DARLENE JUMPER Defendant STIPULATION OF THE PARTIES FOR PAYMENT AND FOR THE ENTRY OF JUDGMENT BY CONSENT TO THE PROTHONOTARY: Kindly enter Judgment in favor of Plaintiff and against the Defendant, DARLENE M JUMPER, above-named, in the amount of $1,779.77 pursuant to the Stipulation of the Parties for Payment and for the Entry of Judgment by Consent, as follows: Defendant admits indebtedness to Plaintiff in the amount of $1,779.77 with continuing interest thereon at a rate of 6% per annum plus costs from Date of Judgment. 2. To secure the repayment of said indebtedness, Defendant agrees that Judgment by Consent will be entered in favor of the Plaintiff and against the Defendant, DARLENE M JUMPER, in the amount of $1,779.77 plus continuing interest thereon at the rate of 6% per annum from Date of Judgment and costs. 3. Plaintiff agrees not to execute on its Judgment so long as Defendant causes to be delivered to Plaintiff the following payments in full by 12:00 NOON on the following dates: (a) $75.00 due by August 25th, 2008; (b) $75.00 due on the 25th day of each consecutive month thereafter until the Judgment amount plus accrued interest and costs are paid in full. 4. All payments are to be made payable to the order of "CAPITAL ONE BANK (USA), NA." All payments due under this agreement are to be received at the offices of Weltman, Weinberg & Reis, Co., L.P.A., 1400 Koppers Building, 436 Seventh Avenue, Pittsburgh, PA 15219. All future payments are to be mailed to the offices of Weltman, Weinberg & Reis, Co., P.O. Box 5430, Cleveland, OH 44101-0430. 6. In the event of default, each payment received shall be first attributed to costs, interest and then to principal. 7. Time is of the essence of this agreement and should the Defendant fail to have in the hands of Plaintiff or Plaintiff's counsel any payment in full within five (5) calendar days of the stated due date, then Plaintiff shall be immediately free to issue Execution as well as pursue all other remedies, in law or in equity, to collect the full balance of the Judgment entered hereunder plus appropriate additional interest and costs. 8. No act or omission of the Plaintiff, nor of anyone alleged to be acting on its behalf, shall constitute a waiver, estoppel, or any other excuse for non-performance of any duty undertaken by the Defendant in this Stipulation which the parties agree is final and complete. 010 1W ? tt 9. Intending to be legally bound, the parties set their hands and seals thi _day of v J, 20_ WELT N, WEINBERG & REIS CO., L.P.A. By Matthew D. Urban WELTMEN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 FAX: 412-338-7130 WWR No. 6568765 Defendant, DARLENE M JLTfAPER 00 } f.. W ? _ wry ? ?7 ?.J .. 4 ?\ rNI) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA), NA Plaintiff vs. Civil Action No. 08-4016-CIVIL TERM DARLENE M JUMPER AKA DARLENE JUMPER Defendant NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the following Order or Jud ment was entered against you on 102 (xx) Assumpsit Judgment in the amount of $1,779.77 plus costs. ( ) Trespass Judgment in the amount of $ plus costs. ( ) If not satisfied within sixty (60) days, your motor vehicle operator's license and/or registration will be suspended by the Department of Transportation, Bureau of Traffic Safety, Harrisburg, PA. (xx) Entry of Judgment of ( ) Court Order ( ) Non-Pros ( ) Confession ( ) Default ( ) Verdict ( ) Arbitration ( ) Award (XX) By Consent Prothonotary DARLENE M JUMPER 650 CONODOGQUINET AVE CARLISLE, PA 17013 ByAHONOTAR PR UTY) FILED-OFFICE OF THE PROTHONOTARY 1010 DEC -3 PM 3.- 42 CUMBERLAND COUNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff vs. DARLENE M JUMPER Defendant(s) No. 08-4016-CIVIL TERM PRAECIPE FOR SATISFACTION OF JUDGMENT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: Benjamin R Bibler, Esquire PA I.D. 493598 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#6568765 NPE 'O, 0? f1' 1 as 9 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff VS. Civil Action No. 08-4016-CIVIL TERM DARLENE M JUMPER Defendant(s) PRAECIPE FOR SATISFACTION OF JUDGMENT At the request of the undersigned attorneys for the Plaintiff, you are directed to satisfy the above-captioned Judgment. WELTMAN, WEINBERG & REIS CO., L.P.A. By: C Benjamin R i e s wire PA I.D. # 935 8 WELTMAN, E BERG & REIS CO., L.P.A. 1400 Kopper B ding 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR #6568765 Sworn to and subscribed before me this _ ' day of November, 10 N9TARY COMMONWEALTH OF PENNSYLVANIA Notarial Seal Wayne A. Jones, Notary Pub0c City of Pittsburgh, Allegheny County MY Commission Expires June 29, 2014 Member. Penncfi+inla Aecataatian of Notaries