HomeMy WebLinkAbout08-7535
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK (USA),NA
Plaintiff No: 09 - 17535 0-,4-
V it ter''
vs.
TAMMY L DAMRON
Defendant
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
07019795 C N Pit REA
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK (USA),NA
Plaintiff
VS.
TAMMY L DAMRON
Defendant
COMPLAINT
You have been sued in cou
claims set forth in the follow
twenty (20) days after this co
a written appearance personall
with the court your defenses o
against you. You are warned t
proceed without you and a judg
court without further notice f
for any other claim or relief
money or property or other rig
Civil Action No
NOTICE TO DEFEND
vk-7S35 oz/d
t. If you wish to defend against the
ng pages, you must take action within
plaint and notice are served, by entering
or by an attorney and filing in writing
objections to the claims set forth
at if you fail to do so the case may
ent may be entered against you by the
r any money claimed in the complaint or
equested by the plaintiff. You may lose
is 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 INFORMATIO ABOUT AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS A A REDUCED FEE OR NO FEE.
LAWYER
CUMBERLAND
32 SOU
(71
EFERRAL SERVICE
UNTY BAR ASSOCIATION
BEDFORD STREET
SLE, PA 17013
7) 249-3166
1. Plaintiff, CAPITAL ONE BAN (USA),NA is a corporation with offices
at 15000 CAPITAL ONE DRIVE RICHMOND , VA 23238 .
2. Defendant is adult individ al(s) residing at the address listed
below:
TAMMY L DAMRON
5337 OXFORD CIR APT 66
MECHANICSBURG, PA 17055
3. Defendant applied for and
account number XXXXXXXXXXXX681
eceived a credit card bearing the
4. Defendant made use of said credit card and has a current balance
due of $1246.44 , as of Octobe 28, 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 t
27.100W per annum on the unpai
of Plaintiff's STATEMENT is at
made a part hereof.
e addition of interest at the rate of
balance from October 28, 2008 . A copy
ached hereto, marked as Exhibit 111" and
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, TAMMY L AMRON, INDIVIDUALLY, in the amount of
$1246.44 with continuing interest thereon at the rate of 27.100° per
annual from OCTOBER 28, 2008 plus costs.
JaWarmbrodt, 42524
WEWEINBERG & REIS CO., L.P.A
43th Avenue, Suite 1400
Pih, PA 15219
(4-7955
FA 338-7130
WW/)070219795
This law firm is a debt colle?tor attempting to collect this debt for
our client and any information obtained will be used for that purpose.
FINANCE
Previous Balance Payments & Credits CHARGE
C$901 24 - $0 00 + $20 70
Nov 06, 2007 - Dec 05, 2007 Page 1 of 1
Via Platinum Account
488Y-3672-07"12
Your Account Information
TOTAL CREDIT LINE $50000
TOTAL AVAILABLE CREDIT $000
CREDIT LINE FOR CASH $50000
AVAILABLE CREDIT FOR CASH $000
Finance Charges (Please see reverse for Imppoorttan?t Information)
applied ied ote when AP R ing CIH?AARGE
plp
Purchases $911193 007507%D 27.40% $2070
Cash $0 00 0 07507% D 27.40% $000
ANNUAL PERCENTAGE RATE applied this period. 27.40%
® At Your Service 141110,00034W
Tocal Customer Rolsbons or lo report a lost or stolen cad
0 Send payments to.
Capital One Bank P 0 Bar 70884 Chamona. NC 28272MM
e Send irgtdrles to.
Capital Ore P 0 Box 30295 See Lake City, UT 841 30-02 9 5
® Have a question about a charge on your statement?
Please refer to the Billing Rights Summary on to back of
your statement or wail
You were assessed a pet due fee because your mmnan payment was not received by the due date To avoid
this fee in the from, we recommend That you allow at least 7 business days for your mrnlmum payment to reach
Capital One
7019795
6056 506 1 07 5 071205
PLEASE RETURN PORTION BELOW WITH i
Caplworv I what's in your wallet?"
New Balance Minimum Payment Due a
$960 94 $460 94 Dec 31,
PLEASE PAY AT LEAST
THIS AMOUNT
Amount Endosed
Transactions New Balance MlnMnum Payment Due Data
)+ $39 00 = $960 94 $460 94 Dec 31, 2007
PLEASE MY AT (FAST THIS AMOIMT
Your account is sox payments behind If we charge off yaw account due to late payments, we roil report the
charged-off status to several national credit bureaus, and too Purchase APR a receded on this statement will
be applied to all your outstanding balances Act now to prevent the from happening Please pay the amount due
on your statement or give us a call at 1800 965.6800 Wool work voith you so you can take control of your
account and start rebuilding your credit with Capitol One
"Important Notice" Under the terms we previously dsdgsed to you, your account is now eligible for an increase
in Annual Percentage Rates (APRs) effective Immediately Fbwever, Captal One has elected not to rase your
APRs at this hme Please be advised that it you fad to keep your account or good standing, Capital One reserves
the right to raise your APRs in the future
Payments, Credits & Adlustments
Transactions
1 30 NOV PAST DUE FEE $3900
Your account is 90 days past due and your Payment Protection coverage has lean suspended As stated in
your Payment Protection agreement, your coverage end monthly charge eil be rensUded once your account is
no longer 90 days pest due You may fill be eligible for haneEts to be pad to your account for loss events
described or your Payment Protection agreement. Call Stonebridge Benefit Services at I-SW5274904 to see 4
your situation qualfies for benefits
1 of 1 OlDM6056
OR LOG ON TO W W W CARTALONE COM TO MAKE YOUR PAYMENT ONLINE
014862367207996812 05 0960940045000460942
Account Number. 4862-3672-0799-6812
Capital One Bank
P.O. Box 70864
Charlotte. NC 26272-U664
Please print address or plane number changes below using blue or black ink
Address
Home Plane A#emate Phone
E-until address @
#9034050049852367# MAIL ID NUMBER
TAMMY L DAMRON
5337 OXFORD CIR APT 66
MECHANICSBURG, PA 17665-4425
II I IIIrOIIIETar111111T1u1re111U1loll IIIIIra11Ullloll Irir
Please write your account number on your check or money order made payable to Capital One Bank and mad with this coupon in the enclosed envelope
EXHIBIT
CAPITAL ONE BANK (USA), N.A.,
Plaintiff,
V.
TAMMY L DAMRON
Defendant(s).
The undersigned does hereby verify subject to the penalties of 18 Pa.C.S. Section 4904 relating
to unworn falsification to authorities, th t he/she is an authorized agent of CAPITAL ONE
BANK (USA), N.A., Plaintiff herein, anthat he/she is duly authorized to make this
Verification, and that the facts set forth ' the foregoing Complaint in Civil Action are true and
correct to the best of his/her knowledge, information and belief. _
Dated: ? I rc?A 1QQc--)K
?1-2 - ? ;?
Stephanie Si ore
A049
WELTMAN, WEINBERG & REIS CO., I,.P.A.
c?
C`J
` b
S - i'71
SHERIFF'S RETURN - NOT FOUND
CASE NO: 2008-07535 P
COMMONTWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
CAPITAL ONE BANK USA NA
VS
DAMRON TAMMY L
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
DAMRON TAMMY L
but was
unable to locate Her in his bailiwick. He therefore returns the
COMPLAINT & NOTICE
the within named DEFENDANT , DAMRON TAMMY L
5337 OXFORD CIRCLE APT 66
NOT FOUND , as to
MECHANICSBURG, PA 17055
PER POST OFFICE, DEFENDANT LIVES IN VIRGINIA.
Sheriff's Costs: So answe.
Docketing 18.00 !i
Service 9.00
Not Found 5.00 R. o as Kline
Surcharge 10.00 Sheriff of C mberland County
.00
42.00 WELTMAN WEINBERG REIS
01/07/2009
Sworn and Subscribed to before
me this day of
A. D.
4C *j
)
C
c
CA-
LIJ
tV
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK (USA),NA
Plaintiff
VS.
TAMMY L DAMRON
Defendant(s)
No. 08-7535 CIVIL TERM
PRAECIPE TO SETTLE, DISCONTINUE
AND END WITHOUT PREJUDICE TO REFILE
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#7019795 REA
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK (USA),NA
Plaintiff
VS. Civil Action No. 08-7535 CIVIL TERM
TAMMY L DAMRON
Defendant(s)
PRAECIPE TO SETTLE, DISCONTINUE
AND END WITHOUT PREJUDICE TO REFILE
TO THE PROTHONOTARY OF Cumberland COUNTY:
SIR:
Kindly settle, discontinue and end without prejudice to refile the above-captioned matter upon the records
of the Court and mark the costs paid.
WELTMAN, WEINBERG & REIS CO., L.P.A.
By:
James C.
PA I.D. i
WELTU
1400 Ko
436 Se?
(412)
SWORN TO AND SUBSCRIBED
before me this day
of 009
OT Y PUB
brodt, Esquire
`N WEINBERG & REIS CO., L.P.A.
s Building
Avenue
, PA 15219
7955
F1LED-OrFICE
OF THE FOOTH(CINJOTARY
209 JUL 20 PH 2: 4 5
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