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HomeMy WebLinkAbout08-5352 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA), NA Plaintiff No: Q$ _r?35a Lwa terl-% VS. BRYAN H EDWARDS 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 06807927 C N Pit IAS % 1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA), N. Plaintiff vs. Civil Action No BRYAN H EDWARDS 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 I 1 COMPLAINT 1. Plaintiff, CAPITAL ONE BANK (USA), N4 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: BRYAN H EDWARDS 161 E MULBERRY AVE CARLISLE, PA 17013 3. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXXXXXX7787 . 4. Defendant made use of said credit card and has a current balance due of $1832.73 , as of July 29, 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 27.600% per annum on the unpaid balance from July 29, 2008 . A copy of Plaintiff's STATEMENT is attached hereto, marked as Exhibit "1" 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 , BRYAN H EDWARDS , INDIVIDUALLY , in the amount of $1832.73 with continuing interest thereon at the rate of 27.600W per annum from July 29, 2008 plus costs. James C. rmbrodt,42524 WELTMAN, NBERG & REIS CO., L.P.A. 436 Seve t Avenue, Suite 1400 Pittsbu gh PA 15219 (412) 4 955 FAX: 4 2- 38-7130 06807 27 C N Pit IAS This law firm is a debt collector attempt/ i g to collect this debt for our client and any information obtained 1 be used for that purpose. caP"alOW NOT PAYING YOUR DEBT 500013 what's in your wallet?' DOESN'T MAKE IT GO AWAY. In fact, even if we report your account as charged off, you'll still be responsible for paying your debt. So why not call us to see what we can do together to keep you from receiving such a serious mark on your credit record? We're here to help. Please contact us to find a solution that's right for you. You can make a payment with our = check by phone service or speak to an associate by calling 1.800.955.6600. Make sure you call or pay the amount due on your statement within 30 days to keep your account from being charged off. Q 2006 Capital One Services, Inc. Capital One is a federally registered service mark. AL rijbts reserved 500013-08503 FINANCE Previous Balance Payments & Credits CHARGE Transactions New Balance Minimum Payment Due Date $1,399.65 - $0.00 + $32.34 + $39.00 = $1,470.99 $470.99 Nov. 19, 2007 Sep. 26, 2007 - Oct. 25, 2007 Page 1 of 1 MfAM PAY AT UAGT M5 AMOUNT Visa Platinum Account 4862-3623-1028.7787 Your Account Information TOTAL CREDIT LINE $1,000.00 TOTAL AVAILABLE CREDIT $0.00 CREDIT LINE FOR CASH $1,000.00 AVAILABLE CREDIT FOR CASH $0.00 Finance Charges (Please see reverse for important information) Balance rate Periodic Corre applied to rate r CHARGE Purchases $1,422.94 0.07575% D 27.65% $32.34 Cash $0.00 0.07575% D 27.65% $0.00 ANNUAL PERCENTAGE RATE applied this period: 27.65% ® At Your Service 1-BW4903.3637 To eel Customer Relations or to report a lost or stolen card: ® Send payments to: Capital One Bank - P.O. Box 70884 - Charlotte, NC 28272.0894 Your account is six payments behind. If we charge off your account due to late payments, we will report the charged-off status to several national credit bureaus, and the Purchase APR as reflected on this statement will be applied to all your outstanding balances. Act now to prevent this from happening. Please pay the amount due on your statement or give us a call at 1.000.955.6600. We'll work with you so you can take control of your account and star[ rebuilding your credit with Capital One. "Important Notice" Under the terms we previously disclosed to you, your account is now eligible for an increase in Annual Percentage Rates (APRs) effective immediately. However, Capital One has elected not to raise your APRs at this time. Please be advised that'd you fail to keep your account in good standing, Capital One reserves the right to raise your APRs in the future. Payments. Credits & Adiustments Transactions 1 20 OCT PAST DUE FEE $39.00 A Sand inquiries to: As you asked, we've designated your account to dose. Please note that your account balance must remain at Capital One • P.O. Box 30285 • Sale Lake City, UT 84130-W5 $0 for two consecxttive monthly statements before R is dosed. Please continue to make necessary payments on ® Have a question about a charge on your statement? your account and stop any automatic payments or pre-authorized charges you may have set up. If you make Please refer to the Bitting Rights Summary on the back of any charges on your Capital One credit card before your account doses (Including automatic or pre-authanzed your statement or visit www.raoitalcne.comldisoules. charges), your account will remain open and well remove the request to close your account. 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 for your minimum payment to mach Capital One. DIM 6056 506 1 07 25 071025 PAGE 1 of 1 OlDM6056 PLEASE RETURN PORTION BELOW WITH PAYMENT OR LOG ON TO W W W.CAP TALONE.COM TO MAKE YOUR PAYMENT ONLINE 4862362310287787 25 1470990028000470992 Gw1work what's in your wallet?. New Balance Minimum Payment Due Date $1,470.99 $470.99 Nov. 19, 2007 PLEASE PAY AT LEAST THIS AMOUNT Amount Enclosed Capital One Bank P.o. Box 70884 Irlrrlrrllrrrlrlrrllrl Charlotte, NC 26272-0664 hdJLPLrrLllrreLPLIILrrlrrldrrlrrlrrllrrLrhrlhrttl Account Number: 4862-3623-1028-7787 Please print address or phone number changes below using blue or black ink. Home Phone Alternate Phone #9029976387400491# MAIL ID NONEER BRYAN H ED:ARDS 161 E nULBRRY AVE CARLISLE, PA 17013-3030 IrrrlllrrrlllrrrrrJ6elLrrlLlLrrrrlldLPrrlLtrrrllPLlrl 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. BRYAN H EDWARDS 1. Nov to Avoid a Finance Chvpe. t a. Grace Period. You will have a minimum grace period of 25 days wirhot finance charge on new purchases. new balm" tanskm, new special purchases and new other drrges r you pay your WW'Naw Balance. In accordance with the imprbnl Notice ter payments below, and in tine for it to be cmdbd by your payment due date. Them Is no grace period on ash advances and apadel transient. In addition, them is no grace period on arty transaction If you do not pay the foist w babince.• b. Accruing Finance Chap". Trarmacdons ~ are not sdhjed to s gran period are sss-e i Mena change 1) from the data of the Wa saogm or 2) from to date to transaction a processed to you Account or 3) from the W calendar day d the current bang period. AdtlNeWly, t you did not pay Ihe'New Balance am the previous blkg padod in full, franc charges omenue to accrue to your unpaid heWnce until to unpaid balance is paid in full. This means that you may aW owe finance dupes, even ir you pay are entire New Balance Indicated on the from of your statement by the payment due data, but dal not do so fr the previous month. Unpaid finance dirges me added to the applicable sagmem of your Account. T c. Minamen Farm- Charge. For each hitting period am your scant Is subject b a tinanca charge, a minimurn total FINANCE CHARGE or 50.50 sea be imposed. t d. Temporary Reduction In Finesse Chaps. We reserve the npa to not aa-as my or as stance charges for any given Mang period. 2. Average Daly Balance (krcttrdtg Naar PaMams} Fffwm am daily belance of each Segme nt is calculated of your acco int (*4, ??1 advance, purdhese, special transfer and spwW purchase) by the wmapadkg dairy prude cob(s) that has been previously dstlaed to you. At the eed of each day during the bating period, sea apply cis daily periodic rate for each segment of your account to the dally balance of each seprtwd. Then at is and of the hHng period, sea add np the mats of Mesa daily circulation to rise at your periodic finance Charge for each segment. We add tp the resuas nom each segment to arrive at the toW periodic snare charge fr your armum. To gar the duty balance for each Segment of oar eroaunl, we aka Use begaarhg balarpce fur each segment ed add arty rswaa-elms and arty periodic finance charge caudated on cis previous days balance R. tst sagnera We Men whtrac my payments or credite posted - deal dry that m allocated to that sag-A. This gives us the sepem s dNy balance for each sepnrb of your account However, t you paid to New Balance shown m your previous statement in fil (r t your new balance was zoo or • refit amount), new transactions, which post W your purchase or Sperm purchase segments are not added to the daily batanow. We calculate the average daily balance by adding al the dairy balances together and drA ing the sum by the number or the days in the current biting cycle. To calculate, you total finance charge, multiply Me mention of days in the bang Period. Due to rounding on a daily basis or due to mlnlmum finance duwp aaseaw vnt, Mere may be a variance between this calculirtion ant! the amount of tnrve throe actually assessed. 3. Annual Percentage Raba (APft a. The term'Anmusi Percentage Rata' may appear -'APR' on the from of" stremam. b. if the code P (Oserarly Prima), L (t3usrterty LIBOR). C (Ouanedy CD), r S (Benloard Prima) appears m --- of this Statement rand to the Parodic rate(s), to periodic miss end oomispondlrg ANNUAL PERCENTAGE RATES may wry quarterly, and may nvaeae or deva-e based on to stated indices. as found in The WWI Street Journal, plea the margin previously dwdnsed b you. These dwVw wail be effective on the *9 day of your W" period cmeed by your perindc statement ending in the monde of January April, July NW October. c. t D. code D (Monthly Rime), F (Monthly LIBOR), or G (Treasury LIBOR) appears m the from at yore resounan men to the periodic rate(s), the, periodic rams and corresponding ANNUAL PERCENTAGE RATES may wry monthly end may it nsue or decrease bred m av staled Intllaa, as road In The Wall Street Jamb, plus the margin previously disdowd to you. These dung- will be effective on Ma first day of your billing period each month. 4. Aaeeeamrrt of Lea, OvrNmlt sort Retur-d Payment Fws, Under the terns of your cu3k r agnemem, sea reserve the right to valve or ra to seem arty fan wmw prior noascaton b you wlthout waiving our rf gM to ass-s gv "me or sMnaarba ata IaMame. T S. R"nneng Voter Acgrat It a meffbrshlp fee appears on the front of your aralerneK you have 30 days from the date Mts statement was mailed to you b avoid Peyng the fee r to have such fee ranted to you if you and your accost vAW having to pay the membership fee, To grad your axw4 you must notify us by aling our Customer Relations Department and pay your i4ew Bloke in full (exclix rig the mwrbem* fee) prior te the and of the Miry-day, period. S. It You Close Your Account. You an requrat to dose your account by calling our Customer Relations DepamwnL You must destroy yon cridltaW(s) and account acts darks, caned al prsetww oad bating wd came using your account. After your raquus a to dose, if you comrse to raised or do not anal praatuthorized biling anti ge nvma. ,re vAl consider raceipt der loge your adr-buiaon to keep your account open. Additionsly, your aunt will not be dosed until you pay of anoints you owe us including: my Im-od" you have suNwrized, aroma charges, past der tees, ovensei[ Seek, returned payment fees, Cash advefice fees and arty other fees assessed to your acoum. You re reapansbis for these amount wtemrthey appear on your account at the tent you request to dose to account or they am Incurred subsequent b your request to does the 8caum. This may taut n daag- sppearkg on your account after you have requeaed the -1 to be closed, 7. Using Ymr AccoSmL Your card oracooum cannot be used in connection with arty Internet gembifng aws ecbms. S. Notice About Electronic Check Cormsusi n. When you provide a duck as payment you sullorba us either to use information from your duck to make a one-time electronic fund! Vermeer *am your bank accord or to process the payment as a check transaction. When we use Information from your dwck to make an *Wcbonk: Mot transfer, finds may be velixi awn from your bank aecetrm a soon w the awns dry we moeive your payment, and you wNl not receive your check back from your finandal kviftbon. BILLING RIGHTS SUMMARY (In Cam of Enos or Ouewiors about Your 91) If you MWk your hill In wrong, or If you need mac Irdpmetion on a transaction a b1, write to us on ¦ seprata Shed a som as possible at ter address for kxWm shown on the fmnt of this wetensm. We mat hew from you no later ten 60 days after sea Bern you the first h1 m wtnuh the error r problem sppearad. You an erg or Customer Relations number, but dwV so will not preserve your rights. In your fewer, give a the folosing Information: your name std account number, the tlollr amaint of the suspected emu. a description of the error and an explanation. If possible, of why you believe them is an error, or If you need more Informed- a description of the it.. you am unere about. You do not have to pay any amount in question role vro am nvatgatng 1L but you are sdt obligated to pay the parr of your bill tut ara not in quaton. While we hvessgate your question, we an at repro you as delinquent or take any action to oolact the amrlnt you question. t, f SPecW R U18 for Cmdt Cam Furness If you have a problrn min the Wailty, d property or Services that you purchased wish a o etlN card anti you have tried n good faith to correct the problem with to merdwnt you may have the rigid not to pay the remaining arum rd IXw on the property or senias. You have I N& protection only whin to purchase price Sees more than 550.00 and Me purchase w- made In your home state or wlWn 100 miss of your mailing address. Of sea own or operate the msrchmL r It am maned you the strariffisfient for the property or Services, all purchases are covered regardless of amount or baton of pachass.) Plmas remember to sign all correspondence. T Does not apply it) consumer non cmdlt camatsoums Does not applym buSksa nowt r card account. Capital O- supports pmonn rbon privacy protection: we our xebabe at 7 con Capital One is a federally registered service mark of Capisl One Financial Corporation. AN rights reserved. 02006 Capital One 01 DMOD56 - 1- 04/10/07 laeaMlt N"Nec Psymass you met ID US M is Cndlad byes BMOWUtithehi*mderwmce t.provNed(1) you send tee bdlun pMm of ft MWnadad your dot n Me andoeed IM11bne anwlope ad (2) for paym m is mead in der pr oe arg Omer by3pm. ET(12noon PT). PW dmaMdtn(5)bmMendaysforpwWdenary. Pay nee noeMdbywWawateboomrn cry otlrferm may not b sand ar dtls day w pecaka tlnern. Qr butte days n faalday taalM Saaaaa, adsiaq lpalaaYS. Plere dD not we staples, paper der, sic. when prapeapp your payment CAPITAL ONE BANK (USA), N.A., Plaintiff, V. BRYAN H EDWARDS Defendant(s). VERIFICATION 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 an authorized agent of Capital One Services, Inc., an affiliate of and service provider to CAPITAL ONE BANK (USA), N.A., Plaintiff herein, and that he/she is duly authorized to make this Verification, 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. Dated: 4hoti A049 WELTMAN, WEINBERG & REIS CO., L.P.A. 401. 6t+ t ? ? ?U 7{?!7 QQ b . 00 n, W , 6 SHERIFF'S RETURN - REGULAR CASE NO: 2008-05352 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CAPITAL ONE BANK USA N A VS EDWARDS BRYAN H KENNETH GOSSERT Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE Was served upon EDWARDS BRYAN H the DEFENDANT at 0756:00 HOURS, on the 4th day of October , 2008 at 13 W MAIN STREET APT 3 MECHANICSBURG, PA 17055 by handing to BRYAN EDWARDS a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 16.00 Affidavit .00 Surcharge 10.00 n I 0lb91w 00 44.00 Sworn and Subscibed to before me this day So Answers:' r R. Thomas Kline 10/07/2008 WELTMAN WEINBERG REIS By: of A. D. 1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA), NA Plaintiff No. Cg - 535a (2;y 1-lim vs. BRYAN H EDWARDS Defendant PRAECIPE FOR ENTRY OF JUDGMENT BY CONSENT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: MATTHEW D. URBAN PA I.D. #90963 WELTMEN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#6807927 TIC IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA), NA Plaintiff vs. Civil Action No. 08-5352 CIVIL TERM BRYAN H EDWARDS Defendant PRAECIPE FOR JUDGMENT BY CONSENT TO THE PROTHONOTARY: Kindly enter Judgment against Defendant, BRYAN H EDWARDS, in the amount of $2019.65 plus costs, based t pon the consent of the parties. CONSENTED TO: `VELTMAN, WEINBERG & REIS CO., L.P.A., 13y: ,kttorney for Plaintiff BRYAN H EDWARDS, By: Defendant 'WWR#6807927 I. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA), NA Plaintiff VS. Civil Action No. BRYAN H EDWARDS 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, BRYAN H EDWARDS, above-named, in the amount of $2019.65 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 $2019.65 with continuing interest thereon at a rate of 6% per annum plus costs from February 24, 2009. 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, BRYAN H EDWARDS, in the amount of $2019.65 plus continuing interest thereon at the rate of 6% per annum from February 24, 2009 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) $50.00 due by FEBRUARY 27,2009; (b) $50.00 due on the 27TH day of each consecutive month thereafter until the Judgment amount plus accrued interest and costs are paid in full. -A 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., P. O. BOX 5430, CLEVELAND, OH 44101. 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. /Gh 9. Intending to be legally bound, the parties set their hands and seals this' 'day of 20 0'( WELTMAN, WEINBERG & REIS CO., L.P.A. By: _ kA-rHEW D. URBAN PA I.D. #90963 WELTMEN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR No. 6807927 alrzw I3y: Defe dant, BRYAN H EDWARDS 81 ?? j 4. oo PAD AT" CIL-`o S%(#%g9 ?a4 aa3 i o4 Ookes. )A? ._ • a. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA), NA Plaintiff VS. Civil Action No. BRYAN H EDWARDS Defendant NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the following Order or judgment was entered against you on p (xx) Assumpsit Judgment in the amount of $2019.65 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 BRYAN H EDWARDS 161 E MULBERRY AVE CARLISLE, PA 17043 By: PR ON DEPUTY) 1400 Koppers Building 9 436 Seventh Avenue 9 Pittsburgh, Pennsylvania 15219 9 412.434.7955 9 www.weltman.com IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA), NA Plaintiff vs. No. 08-5352 CIVIL TERM ACCEPTANCE OF SERVICE BRYAN H EDWARDS Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: Matthew D. Urban, Esquire PA I. D. #90963 WELTMEN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 FAX: 412-338-7130 WWR#06807927 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA), NA Plaintiff vs. Civil Action No. 08-5352 CIVIL TERM BRYAN H EDWARDS Defendant ACCEPTANCE OF SERVICE I, BRYAN H EDWARDS, do hereby accept service of the Complaint in Civil Action. n ?L v DATE: Defe ant or ivoovw no An '2 `AN * 59 Ww `r