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Home My WebLink About08-6400NAN15225 THIS IS AN ARBITRATION MATTER. ASSESSMENT OF DAMAGES HEARING REQUIRED. Goldman & Warshaw, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 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. CORY ADAMS 224 S HIGH ST MECHANICSBURG PA 17055-6344 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : a$ - &400 awa (,errk 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 and/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 as of October 7, 2008 there remains a balance due in the amount of $3,551.71. 5. Plaintiff has made demand upon the defendant(s)for payment of the balance due of $3,551.71 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 August 19, 2006. WHEREFORE, plaintiff claims of the defendant(s) the sum of $3,551.71 plus applicable costs, interest and attorney's fees. Goldman & Warshaw, P.C. BY: Frederic I. Weinber Es ire Attorney for Plaintif 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, Frederic I. Weinberg 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: Frederic I. ei erg, Esquire Attorney for aintiff EXHIBIT "A" NAN15225 CAPITAL ONE BANK (USA), N.A. CORY ADAMS 14 t?aMA CAvis 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. 1 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 result of said breach; 5. After allowing for all offsets and credits, a balance remains on the subject account having account number D914 in the amount of $2,716.34; 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 of my kn dge, information and belief. (Name of Affiant) Sworn to and Subscribed before me this _ day of 2008 JUN 16 20no Uvonda S. Brooks Notary Public Douglas County, Georgia Notary Public My Commission Expires February 29, 2012 CAD Fri lt7 , Co { SHERIFF'S RETURN - NOT FOUND • CASE NO: 2008-06400 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CAPITAL ONE BANK USA N A VS ADAMS CORY R. Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT ADAMS CORY but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT & NOTICE , NOT FOUND , as to the within named DEFENDANT ADAMS CORY 224 S HIGH ST MECHANICSBURG, PA 17055-6344 PER PARENTS, HE NO LONGER LIVES THERE. Sheriff's Costs: Docketing 18.00 Service 10.00 Not Found 5.00 Surcharge 10.00 % ./!r/Q i ()-, .00 43.00 So answers: s R. Thpm,as Kline Sheriff of Cum`, berland County GOLDMAN & WARSHAW 12/03/2008 Sworn and Subscribed to before me this day of A. D. NAN15225 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. CORY ADAMS 440 BERNHEISEL BRIDGE RD CARLISLE PA 17015-9003 'FILED-OFFICE OF THE PROTHONOTARY 2019 DEC -2 PM 1:00 CUMBERLAND COUNTY PENNSYLVANIA COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO.: 08-6400 PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Kindly reinstate the Plaintiffs' Complaint in Civil Action in the above-captioned matter for an additional thirty (30) days. Goldman & Warshaw, P.C. BY: BARRY A. ROSEN, ESQUIRE Attorney for Plaintiff(s) a? c? asig3S SHERIFF'S OFFICE OF CUMBERLAI RCOUNTY Ronny R Anderson ; Sheriff Jody S Smith Chief Deputy Richard W Stewart a .t.? n??4o? Solicitor Capital One Bank vs Case Number . Cory Adams 2008-6400 SHERIFF'S RETURN OF SERVICE 01/14/2011 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Cory Adams, but was unable to locate him in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant Cory Adams. Request for service at 440 Bernheisel Bridge Road, Carlisle, Pennsylvania 17013 the defendant was not found. To date The Mechanicsburg Postmaster has been unable to provide a good address for Cory Adams. SHERIFF COST: $56.40 SO ANSWERS, January 14, 2011 RONW R ANDERSON, SHERIFF ILED-OFFICF c; i'HE PROTHONOTAR 2011 JUL 18 Pty 2: Sts NAN15225 Goldman & Warshaw, P.C. Barry A. Rosen, Esqui.-MMERLAND COUNTY PA Identification No: 4?5HNSYLVANIA 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 COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. CORY ADAMS DOCKET NO. : 08-6400 PRAECIPE FOR ENTRY OF JUDGMENT 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 Interest from @ 19.8% Costs (Complaint Total: $2,716.34 10/07/2008 $2,304.49 & Service) $5,020.83 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 that the last known address of defendant, CORY ADAMS, 204- B S. High Street, Mechanicsburg PA 17055. G(MA $I1. oo Pd 01E Ck,*- 41 Sg3 V,*a4D I qf;; Nom NVLOea 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 _ i0 day of t A, 2011 Judgment is entered in favor of the plaintiff(s) and gainst defendant(s) by default for want of an answer and damages as essed at the um of , $5,020.83 as per the above certifi d o Prothono A"010 Goldman & Warsh , P.C. BY: BARRY A. Rg?bftN, ESQUIRE Attorney for Plaintiff padj/scar, Goldman & Warshaw, P.C. BY: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 COURT OF COMMON PLEAS CUMBERLAND COUNTY VS. CORY ADAMS CORY ADAMS 204- B S. High Street Mechanicsburg PA 17055 DOCKET NO.: 08-6400 NOTICE OF INTENTION TO TAKE DEFAULT TO/PARA: CORY ADAMS DATE OF NOTICE/FECHA DEL AVISO: June 17, 2011 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY AN ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES 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 INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 S BEDFORD STREET CARLISLE, PA 17013 717-249-3166 Goldman & Warshaw, P.C. BY: BARRY A. R S , ESQUIRE 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. P10D:NAN15225 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 NAN15225 CAPITAL ONE BANK (USA), N.A., successor in interest to CAPITAL ONE BANK VS. CORY ADAMS TO: CORY ADAMS 204- B S. High Street Mechanicsburg PA 17055 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 08-6400 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. ZXZ Judgment by Default $5,020.83 ?L Money Judgment $ ?L Judgment on Award of Arbitrators$ L1 Judgment on Verdict$ IF YOU HAVE ANY QUESTIONS CONCERNING T S NOTICE, PLEASE CALL THE LAW FIRM OF GOLDMAN & WARSHAW, P.C. AT THIS % ELE NE BER: 267-r3-9730 Vg/// PROTHON padj /scan