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Home My WebLink About08-7545 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff No: OB ` ?15?ts 04V ?atr'w i VS. COMPLAINT IN CIVIL ACTION DEVON J RICHCREEK 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 07006490 C N Pit REA v IN THE COURT OF COMMON PLEAS CAPITAL ONE BANK (USA),NA VS. Plaintiff DEVON J RICHCREEK Defendant OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION III I Civil Action No COMPLAINT AND NOTICE TO DEFEND You have been sued in count. 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 NE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE Y U 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 R FERRAL SERVICE CUMBERLAND CO TY BAR ASSOCIATION 32 SOUTHIBEDFORD STREET CARLI LE, PA 17013 (71) 249-3166 I IIII I 16 COMPLAINT 1. Plaintiff, CAPITAL ONE BAN (USA),NA is a corporation with offices at 15000 CAPITAL ONE DRIVE RIC OND VA 23238 . Ili 2. Defendant is adult individual(s) residing at the address listed below: DEVON J RICHCREEK 7779 WERTZVILLE RD CARLISLE, PA 17013 3. Defendant applied for and eived a credit card bearing the account number XXXXXXXXXXXX9886I,. 4. Defendant made use of said credit card and has a current balance due of $1310.44 , as of October28, 2008 . 5. Defendant is in default by failing to make monthly payments when due. As such, the entire balanc is immediately due and payable to Plaintiff. 6. Plaintiff is entitled to the addition of interest at the rate of 25.9009. per annum on the unpaid balance from October 28, 2008 . A copy of Plaintiff's STATEMENT is attached hereto, marked as Exhibit "1" and made a part hereof. r 7. Although repeatedly Defendant has willfully failed to Plaintiff. requested to do so by Plaintiff, and/or refused to pay the balance due Wherefore, the Plaintiff prays for judgment in its favor and against Defendant, DEVON J RICHCREEK, INDIVIDUALLY, in the amount of $1310.44 with continuing interest thereon at the rate of 25.900% per annum from OCTOBER 28, 2008 plug costs. IIII I James armbrodt, 42524 WELTM N, EINBRG & REIS CO., L.P.A 436 eve h Avenue, Suite 1400 Pit bur h, PA 15219 (41 ) 4 4-7955 FAX 2-338-7130 WWR 006490 This law firm is a debt collector attempting to collect this debt for our client and any information 'obtained will be used for that purpose. Xmi8iT FINANCE ! Previous Balance Payments & Credits i CHARGE Transactions Now Balana Minimum Payment Due Date $670 79 - $85 50 + $14 03 + $5 93 = $605 25 $105 25 Jun 19, 2007 Apr 20, 2007 - May 19, 2007 Page 1 of 1 Visa Platinlmt Account RIME PAY AT LT TMS AMOIMT Payments, Credits 8 Adlustments 4MU72.12464M 1 25 APR DIRECT DEBIT PAYMENT $8550- Your Account Information Transactions TOTAL CREDIT LINE $50000 2 19 MAY PAYMENT PROTECTION 1.868-527-6 $593 TOTAL AVAILABLE CREDIT $000 CREDIT LINE FOR CASH $50000 Under terms previously disclosed to you, some or all of your Annual Percentage Rates (APRs) have been AVAILABLE CREDIT FOR CASH $000 increased since your account was past due bvice in the pa#t 12 tiling cydea If your rates have alread y increased sub ant der dm th Finance Charges (Please see reverse for important in abon) Balance rate Periodic Corre?onding FINANCE applied to rate APR CHARGE Purchases $368.45 0 07712% D 2815% $852 Cash $237 97 0 07712% D 2815% $551 ANNUAL PERCENTAGE RATE applied this period. 28.15% ® At Your Service 1.800.201.3637 To Call Customer Relations or to report a lost a stater card ® Send payments to. Capital One Bank P.0 Box 708M Charlotte, NC 26272.0681 A Send Inquiries, to. Capitol One Po Bar 30285 Safi Lake City, UT 8413D-0285 6056 506 1 7 19 070519 Q11~()W I what's in yourwallet? I nquenoes extan a duretio0 of the increased rates Remember If we receive your mnimum mon2lly payment on time for 12 consecutive filling cycles, this account wd be reviewed for a possible return to your Non-Introductory APR P E 1 of 1 PLEASE R URN PORTION BELOW WITH PAYMENT 0 4862367212489886 19 New Balance Minimum Payment Due Date C$605 25 $105 25 Jun 19, 200 PLEASE PAY AT LEAST THIS AMOUNT Amount Enclosed Capital One Bank P.O. Box 76864 Charlotte, NC 26272-6864 ?n?d?n?ur1111ndn1d11nJedl1ldu1ulilt 1n1u11lull 01BC6056 0605250085500105252 Account Number: 4862-3672-1248-9886 Please print address or phone number changes below using blue or black ink Address Home Phone Aapmate Phone E-mad adakess #9014040481211788# MAIL ID NDMBER DEVON J RICHCREEK 34 RICHCREEK RIDGE LN LANDISBURG, PA 1,7040 r 111 I IE O it l14111'81110E 7006490 Please write your account number on our check or mom orde made your money ? payable to Capital One Bank and mad with this coupon in the enclosed envelope CAPITAL ONE BANK (USA), N.A., Plaintiff, V. DEVON J RICHCREEK 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 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: ! *?Z ?t C 1 0 r Nichole Reid A049 WELTMAN, WEINBERG & REIS CO., L.P.A. 00 00 ?k Q c'xa ?'7 f_?1 7 Lo -3 SHERIFF'S RETURN - NOT FOUND CASE NO: 2008-07545 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CAPITAL ONE BANK USA NA VS RICHCREEK DEVON J 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 RICHCREEK DEVON J but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT & NOTICE the within named DEFENDANT 7779 WERTZVILLE ROAD NOT FOUND , as to RICHCREEK DEVON J CARLISLE, PA 17013 PER STEPFATHER, DEFENDANT MOVED OUT. PER POST OFFICE, MAIL IS STILL DELIVERED THERE. Sheriff's Costs: So answers- Docketing 18.00 Service 4.50 Affidavit .00 R. Thomas Kline Surcharge 10.00 Sheriff of Cumberland County Not Found 5.00 37.50 WELTMAN WEINBERG & REIS 01/15/2009 Sworn and Subscribed to before me this day of , A.D. t T ra ?'"? ? -:' ? ?5 t'. z ?y `?•" ? 4 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA) N.A. Plaintiff vs. DEVON J RICHCREEK Defendant No. 08-7545-CIVIL TERM PRAECIPE TO DISCONTINUE AND END WITHOUT PREJUDICE TO REFILE FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan, Esquire PA I . D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#7006490 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA) N.A. Plaintiff vs. Civil Action No. 08-7545-CIVIL TERM DEVON J RICHCREEK Defendant PRAECIPE TO DISCONTINUE AND END WITHOUT PREJUDICE TO REFILE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: SIR: Discontinue and End the above-captioned matter upon the records of the Court without prejudice to refile and mark the costs paid. WELTMAN, WEINBERG & REIS CO., L.P.A. By: T Attorney for Plaintiff 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#7006490 SWORN TO AND SUBSCRIBED before me this 28T" day of AUGUST, 2009 N ARY PUB com VANW NSy ??NOtl?rf?I il??? W A' Jom? h" cou* ? 2P, x010 ota a M.mW enm PiLE)-z,YH:SCE OF THE P?ROT?1?Cf4CTARY 2009 SEP -8 PM f : 2 7 PENNSYLVANIA