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Home My WebLink About08-6230IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA), NA Plaintiff VS. LISA L RAMBLER JEFFREY RAMBLER Defendants No. 08 - W150 0,; viI Tww, COMPLAINT IN CIVIL ACTION FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: JAMES C. WARMBRODT, Esquire PA I.D. #42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#6549336 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA), NA Plaintiff VS. LISA L RAMBLER JEFFREY RAMBLER Defendants Civil Action No. COMPLAINT IN CIVIL ACTION 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 CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 COMPLAINT 1. Plaintiff is a corporation with offices in 15000 CAPITAL ONE DRIVE RICHMOND, VA 23238. 2. Defendants are adult individuals residing at 345 OXFORD RD GARDNERS, PA 17324 . 3. Defendants applied for and received a credit card issued by Plaintiff bearing the account number : 5291491927747624. 4. Defendants made use of said credit card and has currently a balance due and owing to Plaintiff, as of OCTOBER 13, 2008, in the amount of $ 9,157.59. A true and correct copy of Plaintiff's Statement of Account is attached hereto, marked as Exhibit "1" and made a part hereof. 5. Defendants are in default of the terms of the cardholder Agreement having not made monthly payments to Plaintiff thereby rendering the entire balance immediately due and payable. 6. Plaintiff avers that the Cardholder Agreement between the parties provides that Plaintiff is entitled to the addition of finance charges at the rate of 19.90 % per annum on the unpaid balance. 7. Although repeatedly requested to do so by Plaintiff, Defendants have willfully failed and/or refused to pay the principal balance, finance charges or any part thereof to Plaintiff. WHEREFORE, Plaintiff demands Judgment in its favor and against Defendants, LISA L RAMBLER and JEFFREY RAMBLER jointly and severally, in the amount of $ 9,157.59 with continuing finance charges thereon at the rate of 19.90 % per annum from OCTOBER 13, 2008 plus costs. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED SHALL BE USED FOR THAT PURPOSE. WELTMAN, WEINBERG & REIS, CO., L.P.A. JAMES C. W BRODT, Esquire PA I.D. #42 4 WELTM EINBERG & REIS CO., L.P.A. 1400 Kop ers uildin 436 Sev th venue Pittsb h, A 15219 (412) 434Z7955 WWR#:6549336 N O O N P a ? V W W P ? NN gU 3 c?e MP 9 u g .? -81 o0 3 3 H N R 4 rizzi bb a U -He a ha w ? z a - ?FUa Q t- w Fw Z; 4 10 0 0 N O M O O O O O N O ? O N ~ O u a N 10 H ? 3 ? 3 ti O N m ? r O 01 r d N Zv% Li 0 oe o C11 o 9 o a o0 ? °o 6 L 8 ? f M # o o ? m - a ` a `? ? r a o . + - Ma a _ ? N ? a a a ? oa?o a s o' @@ ? ykmwu? 3 ? ahMcn I? II'I III Z""O x M ~ ., m O ? r m O ?0 5 g 3 rom0 _ u •a .'a z bC?_ „ uaw . r c VERIFICATION CAPITAL ONE BANK (USA), N.A., successor-in-interest to Capital One Bank vs RAMBLER, LISA L 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, TRACY TAYLOR, 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. TRACY TAYLOR Notary Public 5291491927747624 A049 WELTMAN, WEINBERG & REIS CO., L.P.A. NIA?SUIN NO I'A ? s pUF -S "Al 'jJS m -fil- f`V 1741 n 00 " " Sb . ? 0 { L ca iz /* C CC) SHERIFF'S RETURN - REGULAR 4 ?CASE NO: 2008-06230 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CAPITAL ONE BANK USA N A VS RAMBLER LISA L ET AL GERALD WORTHINGTON Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE RAMRT.RR T,ISA L was served upon the DEFENDANT , at 0020:51 HOURS, on the 28th day of October 2008 at 345 OXFORD RD GARDNERS, PA 17324 JEFFREY RAMBLER by handing to HUSBAND OF DEFENDANT 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 10.00 Affidavit .00 Surcharge 10.00 .00 )d/3alb?C?, 38.00 Sworn and Subscibed to before me this day So Answers: R. Thomas in 10/29/2008 WELTMAN WEINBERG & REIS By: Deputy S iff of A. D. SHERIFF'S RETURN - REGULAR E - 1CASE NO: 2008-06230 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CAPITAL ONE BANK USA N A VS RAMBLER LISA L ET AL GERALD WORTHINGTON Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon RAMBLER JEFFREY the DEFENDANT , at 0020:51 HOURS, on the 28th day of October , 2008 at 345 OXFORD RD GARDNERS, PA 17324 JEFFREY RAMBLER by handing to 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: So Answers: Docketing 6.00 Service 00 polo, a,0__00_01r 103 Affidavit .00 _1? Surcharge 10.00 R. Thomas Kline _ .00 10/30/0 16.00 10/29/2008 WELTMAN WEINBERG & REIS Sworn and Subscibed to By: before me this day Deputy Sh ?fff of A.D. DEFENDANT ` r I 16 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA) N.A. Plaintiff vs. No. 08-6230 CIVIL TERM ACCEPTANCE OF SERVICE LISA L RAMBLER Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: JAMES C. WARMBRODT, ESQUIRE PA I.D. #42524 Weltman, Weinberg & Reis Co., L.P.A. 1400 Koppers Building 436 7th Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#06549336 4 ? IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA) N.A. Plaintiff vs. Civil Action No. 08-6230 CIVIL TERM LISA L RAMBLER Defendant ACCEPTANCE OF SERVICE I, LISA L RAMBLER, do hereby accept service of the Complaint in Civil Action. DATE: ? -CSI-y ci 03 . cl-? gwyrt?vuA) Defendant C` c=:> r3 e7 C 'T7 rri -a co ,?. : r^ai ?.:w {. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA), NA Plaintiff VS. No.08-6230 CIVIL TERM PRAECIPE FOR ENTRY OF JUDGMENT BY CONSENT LISA L RAMBLER 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#06549336 $8,056.76 w IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA), NA Plaintiff VS. LISA L RAMBLER Defendant PRAECIPE FOR JUDGMENT BY CONSENT TO THE PROTHONOTARY: upon the consent of the parties. CONSENTED TO: Kindly enter Judgment against Defendant, LISA L RAMBLER, in the amount of $8056.76 plus costs, based Civil Action No. 08-6230 CIVIL TERM WELTMAtj, WEINBERG & REIS CO., L.P.A., LISA L RAMBLER, By: By: Defen ant for Plaintiff WWR#06549336 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA), NA Plaintiff VS. Civil Action No. 08-6230 CIVIL TERM LISA L RAMBLER 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, LISA L RAMBLER, above-named, in the amount of $8056.76 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 $8056.76 with continuing interest thereon at a rate of 6% per annum plus costs from DATE OF JUDGEMENT. 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, LISA L RAMBLER, in the amount of $8056.76 plus continuing interest thereon at the rate of 6% per annum from DATE OF JUDGEMENT and costs. 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) $800.00 due by NOVEMBER 18, 2008; (b) $350.00 due on the 30T" day of each consecutive month thereafter until the Judgment amount plus accrued interest and costs are paid in full. (c) REMAINING OUTSTANDING BALANCE DUE ON OR BEFORE 3/30/09, UNLESS OTHERWISE MUTALLY AGREED UPON BY THE PARTIES. 4. All payments are to be made payable to the order of "CAPITAL ONE BANK (USA), NA." 5. 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. (?Q 9. Intending to be legally bound, the parties set their hands and seals thisv/ -day of rkf- - 1 20 ? 0? . WELT , WEINBERG & REIS CO., L.P.A. By: 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 No. 06549336 By-. (?Way &rttzC -515 '0 , 15 0 C 5 -- n r ?? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA), NA Plaintiff VS. Civil Action No. 08-6230 CIVIL TERM LISA L RAMBLER Defendant NOTICE OF TUDGMENT OR ORDER TO: ( ) Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the following Order or Jud ment was entered against you on 01 (xx) Assumpsit Judgment in the amount of $8056.76 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 LISA L RAMBLER 345 OXFORD RD GARDNERS, PA 17324 By: PRO HONOTAR DE TY) WELTMAN, WEINBERG & REIS CO., L.P.A. BY: Sarah Ehasz, Esquire I.D. No.86469 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 Phone: 412.434.7955 Fax: 412.434.7959 File # 6549336 NPE Attorney for Plaintiff(s) CAPITAL ONE BANK (USA),NA vs. Cumberland County Court of Common Pleas LISA L RAMBLER JEFFREY RAMBLER NO. 08-6230 CIVIL TERM PRAECIPE FOR SATISFACTION OF JUDGMENT TO THE PROTHONOTARY: c 2? ?" m = r r -urn -< > r- --ta -v 3 -n =-n =p :z -C rn Please kindly Satisfy the Judgment of the above-captioned matter upon the records of the Court and mark the cost paid. WELTMAN, WEINBERG & REIS CO., L.P.A. By Sarah Ehasz, Attorney for Sworn to and subscribed Before me the µ ? day of March, 2011 NOTARY PUBLIC ? M 1tAN NOW41$01 S ?. lM?Y#n, NQ%1Y Publk 'fYtp„ N?MIh r" Nw. t? 014 MY TION OF NOTARIES MEMBE&PENN SYLY IA