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Home My WebLink About08-4617THIS IS DAMAGES Goldman & Warshaw, P.C. NAN11234 AN ARBITRATION MATTER. ASSESSMENT OF HEARING REQUIRED. BY: JEFFREY M. PARRELLA, ESQUIRE Identification No.: 201946 PO Box 806 West Caldwell, NJ 07007 973-433-2153 CAPITAL ONE BANK (USA), N.A successor in interest to CAPITAL ONE BANK 4851 Cox Road Glen Allen VA 23060 Vs. AMANDA MUNOZ 151 ASHFORD DR ENOLA PA 17025-2302 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 03- 146( *7 C iv i l -Iernt NOTICE 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 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 JUDGEMENT 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. CUMBERLAND COUNTY BAR ASSOCIATION 32 S BEDFORD STREET CARLISLE, PA 17013 717-249-3166 COMPLAINT IN CIVIL-ACTION 1. At all times relevant hereto, the defendant (s) was the holder of a credit card, which at the request of the defendant(s) was issued to the defendant (s) by the plaintiff under the terms of which the plaintiff agreed to extend to defendant(s)the use of plaintiff's credit facilities. 2. Defendant (s) accepted and used the aforesaid credit card so issued and by so doing agreed to perform the terms and conditions prescribed by the plaintiff for the use of said credit card. 3. The defendant (s) received and accepted goods and merchand- ise and/or accepted services or cash advances through the use of the credit card issued by the Plaintiff. A true and correct copy of the Statement of Account is attached hereto as Exhibit "A". 4. All the credits to which the defendant (s) is entitled have been applied and there remains a balance due in the amount of $1,492.63. 5. Plaintiff has made demand upon the defendant(s)for payment of the balance due of $1,492.63 but the defendant(s)has failed and refused and still refuses to pay the same or any part thereof. 6. Defendant's last payment on account was made on November 11, 2006. WHEREFORE, plaintiff claims of the defendant(s) the sum of $1,492.63 plus applicable costs, interest and attorney's fees. Goldman & Warshaw, P.C. BY: Jeffrey M. Parrell quire Attorney for Plai f THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE THIS COMMUNICATION IS FROM A DEBT COLLECTOR P01A.NAN VERIFICATION The undersigned, Jeffrey M Parrella Esquire, hereby states that he is the attorney for Plaintiff in this action and verifies that the statements made in the foregoing pleading are true and correct to the best of his knowledge, information and belief. Counsel has signed this verification at the request of Plaintiff as a matter of time and convenience. Plaintiff has represented to counsel that there is a debt due and owing from Defendant to Plaintiff in the amount as set forth within the foregoing pleading. Plaintiff has provided counsel with all relevant information in order to allow counsel to sign this verification. Plaintiff agrees to provide a verification signed by Plaintiff upon request by Defendant. The undersigned understands that the statements herein are made subject to the penalties of 19 Pa.C.S.A Section 4904 relating to unsworn falsification to authorities. By: Jeffrey M. P la, Esquire Attorney fo iaintiff EXHIBIT "A" NAN11234 CAPITAL ONE BANK (USA), N.A. AMANDA MUNOZ 5291071581491055 lacy Tayk;. AFFIDAVIT I, , being duly served sworn according to law, depose and say that: 1. I am the agent for the Plaintiff herein and I am familiar with the files relating to this account; 2. I have personal knowledge of the facts and circumstances in connection with this case; 3. Plaintiffs files are maintained in the usual and ordinary course of business; 4. This action is based on a claim for breach of contract and that damages are sought as a direct I= result of said breach; 5. After allowing for all offsets and credits, a balance remains on the subject account having account number 5291071581491055 in the amount of $1,013.55; and 6. If called upon, affiant can testify at trial as to the facts pertaining to this matter. The above facts are true and correct to the best my knowledge, information and belief. am pant) Sworn to and Subscribed APR 2 8 2008, before me this ,_ day of , 2 ry Public JAMEUI SMI WARY NOTARY PUBUG GEORGUI, DEWS COUNTY MY COMMISSION EXPIRES NOV 4, 2011 C') +v ? r f SHERIFF'S RETURN - REGULAR CASE NO: 2008-04617 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CAPITAL ONE BANK USA NA VS MUNOZ AMANDA MARK CONKLIN Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE MUNOZ AMANDA DEFENDANT was served upon the , at 0017:20 HOURS, on the 13th day of August , 2008 at 151 ASHFORD DR ENOLA, PA 17025-2302 by handing to AMANDA MUNOZ 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 15.00 Affidavit .00 Surcharge 10.00 oo 9 b3 n g 43 00 Sworn and Subscibed to before me this day So Answers: R . 'Thomas Kline 08/14/2008 GOLDMAN & WARSHAW By: Deputy Sheriff 0 f A. D. It its ''IL+NOTAA?-,, Goldman & Warshaw, P.C. Barry A. Rosen, Esquire `UMBERLAND COUNTY PA Identification No: 4295P1ENNSYLVANEA GOLDMAN & WARSHAW, P.C. 312 W. Broad Street Quakertown, PA 18951 267-373-9730 Counsel for Plaintiff CAPITAL ONE BANK (USA), N.A., successor in interest to CAPITAL ONE BANK VS. NAN11234 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 08-4617 AMANDA MUNOZ PRAECIPE FOR ENTRY OF JUDGbW.NT FOR WANT OF AN ANSWER ASSESSMENT OF DAMAGES, VERIFICATION OF ADDRESS AND NON-MILITARY SERVICE TO THE PROTHONOTARY: Enter judgment for want of an answer for plaintiff and against defendant(s) above named only and assess damages certified to be calculable as a sum certain from the complaint, as follows: Principal $1,013.55 Interest from 09/28/2006 @ 25.9% $1,168.63 Costs (Complaint & Service) $135.50 Payments after filing complaint -$150.00 Total: $2,167.68 Understanding the false statements made herein are subject to penalty under 18 Pa.C.S.A. §4904, Unsworn Falsification to Authorities, I verify that: 1. The last known addresses of the parties are: CAPITAL ONE BANK (USA), N.A.,successor in interest to CAPITAL ONE BANK and CLM4 ~ ola Pd a.Gtl e???3°?y 8 that the last known address of defendant, AMANDA MUNOZ, 151 ASHFORD DR, ENOLA PA 17025-2302. 2. The annexed notice(s) of intention to file this praecipe was (were) mailed to all parties, defendant and to their record attorneys, if any, after default occurred, and at least ten days prior to the date of filing of this praecipe. 3. The said defendant(s) is (are) not in the :military service of the United States or otherwise within the coverage of the Soldiers and Sailors Civil Relief Act and is (are) over 18 years of age. AND NOW, this ?- day of , '2011 Judgment is entered in favor of the plaintiff(s) and EUgainst defendant(s) by default for want of an answer anamages assessed at t}? sum of , $2,167.68 as per the above certi ati? 0".% , ) Y Goldman & Warshaw, P.C. BY: r BARRY A. EN, ESQUIRE Attorney for Plaintiff padj /scan ? ?-,'4 "'? ?. -? ?k?ytri., _,.; . C A vs. DOCKET N0.: 08-4617 AMANDA MUNOZ NOTICE OF INTENTION TO TAKE DEFAULT TO/PARA.: AMANDiA MUNOZ' DATE OF NOTICE/F$CHA DEL. AVISO: July 20, 2011 NOTICE YOU: ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OPCOY AN ATTORNEYAND.FILE IN WRITING WITH THE COURT YOUR.DMNSES OR OBJECTIONS TO. THE:CLAIMS SET FORTH AGAINST YOU. UNLESS :YOU.ACT'WITHIN TEN DAYS FROM THE. DATE OF THIS NOTICE; A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING .AND YOU:MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE,: IF.YOU.DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER, IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH WFORMAT- 1014 ABOUTAGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS A T A REDUCED FEE OR NO FEE: ,CUMBERLAND COUNTY BAR ASSOCIATION 32 S BEDFORD: STREET CARLISLE; PA 171113 717-249:3166 Goldman & Warshaw, P.C. . BY: BARRY A. tJ , ESQUIRE THIS IS AN ATTEMPT TO COLLECT.A DEBT AND. ANY INFORMATION OBTAINED WILL:BE USED FOR: THAT PURPOSE. THIS COIv MUNICATION:IS FROM A DEBT COLLECTOR. PIAD.NANI 123.4 Goldman & Warshaw, P.C. Barry A. Rosen, Esquire PA Identification No: 42951 GOLDMAN & WARSHAW, P.C. 312 W. Broad Street Quakertown, PA 18951 267-373-9730 Counsel for Plaintiff CAPITAL ONE BANK (USA), N.A., successor in interest to CAPITAL ONE BANK VS. AMANDA MUNOZ TO: AMANDA MUNOZ 151 ASHFORD DR ENOLA PA 17025-2302 NAN11234 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 08-4617 NOTICE Pursuant to Pa.R.Civ.P. 236 of the Supreme Court of Pennsylvania, you are hereby notified that a judgment has been entered against you in the above proceeding as indicated below. 1XL Judgment by Default $2,167.68 ?L Money Judgment $ ?L Judgment on Award of Arbitrators$ f? Judgment on Verdict$ IF YOU HAVE ANY QUESTIONS CONCERNING TH NOT CE, P SE CALL LAW _4 FIRM OF GOLDMAN & WARSHAW, P.C. AT THIS T EPHO U R: 267- 7 -9731 PROTHONOT padj /scan ? ? p ? ?`