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Home My WebLink About09-0144.t IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK {USA),NA Plaintiff vs. SCOTT A FOX Defendant COMPLAINT IN CIVIL ACTION FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: Samantha T. Estevez,89204 WELTMAN, WEINBERG & REIS CO., 325 CHESTNUT STREET SUITE 501 PHILADELPHIA, PA 19106-2614 215-599-1500 FAX: 215-599-1505 06889014 C N Jer SNS L.P.A. 1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff vs. SCOTT A FOX Defendant Civil Action No 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 .~ COMPLAINT 1. Plaintiff, CAPITAL ONE BANK (USA),NA 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: SCOTT A FOX 150 GETTYSBURG PIKE MECHANICSBURG, PA 17055 3. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXX1004 . 4. Defendant made use of said credit card and has a current balance due of $3280.25 as of November 06, 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 27.100% per annum on the unpaid balance from November 06, 2008 A copy of Plaintiff's STATMENT is attached hereto, marked as Exhibit "1" and made a part hereof. ~f 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 SCOTT A FOX INDIVIDUALLY in the amount of $3280.25 with continuing interest thereon at the rye of 27.100% per annum from November 06, 2008 plus costs. ~" - Samant a T. Estevez,89204 WELTMAN, WEINBERG & REIS CO., L.P.A. 325 CHESTNUT STREET SUITE 501 PHILADELPHIA, PA 19106-2614 215-599-1500 FAX: 215-599-1505 06889014 C N Jer SNS 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. ~HIBI~ Pntvfous Balana $2,591 15 FINANCE Paymetlte ti CredNs CHARGE Tmroactbns - $11700 + $59 42 + $39 00 = New 8alanu Minimum Payment Dua DaU $2,572 57 $572 57 Dt3c 28, 2007 .•:•. Nov D3, 2007 - Dec 03, 2007 Page 1 of 1 vtrASE rAr Ai IEAST TIK AuanT Vfea Pbtlnlan Aeoourn ~~ 4182-~T4~SIZ•tODi REWARDS Your Account Information TOTAL CREDIT LINE $2•~ ~ TOTAL AVAILABLE CREDIT $0 00 CREDIT LINE FOR CASH $2.000 ~ AVAILABLE CREDR FOR CASH $0 00 Finance Chtfrgea {Please see reverse fa urponeM nfamabort) ~appG~ b P ~ Car APR ng CHARGE purchases $2,55134 007507°,6 D 21.4096 $59.42 Cash $000 0 0750796 D 21.4096 5000 ANNUAL PERCENTAGE RATE applied tNs period. 27.40% ® At Youraenlal•800.9095837 TO Cal Cwvriar Relaaafa or to repot abd oreldM cad ® Send prymeMs to. Cepitd One Beds P O Bor 70884 ChedAte, NC 7a2T2-0884 Bend Inqulrla to Cepitd One P.0 Bac 30785 Sea Lab Cey. UT 81130-0285 For more Irdametion on your RaaeNs. ® Vhir vrre aplakne.cmJpokrbraxanls Cal 1$00.228J007 Your account is 9k pBymerds behnd Rvre charge OII your account dus t0late pryments, We var repot ria charged-oR stabs b several nayaiel oTedd burows, and #te Purdiess APR as re8eded on ria statement vril hs appYed b dl yar ouldendrp beleitces Ad nor b prevent ria from happenng Please WY on your stateniertt a give us a rob at 1800955.8800 We9 vrork ari you so you can take caTtrol at your account and alert rebutting your aedrl xTri Cephl One „IrrrEadant NoYc.° under ria terms we proxoudy dadosad b you, your ~ ha elec0ad rrot to rase yaease m Annul Percatbge Reba (APRs) eftecave rmnedietdy Fbwever ~Capul ood startdk+9. Ceptd Orw reserves APRs at the 4me Please hs advaad tltet d you brl b keep You the ngM b roue your APRs n the tirAire Summa as7 Prexous avdeble balance 0 Eemed riia pedal (nMda trereedlaxpoeted mdnp sae tear cycle) 887 Avadeble Balance Paytntmts, Credits & Adluatments ~ ~ 1 14 NOV LATE PAYAENT FEE ADJUSTM E78 00- 2 14 NOV LATE PAYI~NT FEE ADJl1STM Trensadlons $3900 3 27 NOV PAST Dl1E FEE ® Have a questan about a dtarge an your shtanenfl vras nd reoerved by ria due data TD oval Pl~se refer b the BiMrq fLpMs Slrrmery on the beck of Yau vrere assessed a pact due fee trecause yow mrnwan paymerd your datement a xsd #xs tee n ria future, we recammertd riot you e8ow al least 7 busabss days fat your rNnenum payment b naedt Capdal One O1DM6056 6056 506 1 D7 2 071203 PAGE 1 of 1 PLEASE RETURN PORTION BELOW WITH PAYMENT OR LOG ON TO W W W CAPITALONE COM TO MAID: YOUR PAYMENT ONLINE 0 4862362445421004 02 2572570120000572571 ~~/~~' I what's rn your walktr" New Balance Minimum Payment Due Date $2,572 57 $572 57 Dec 28, 2007 PLEASE PAY AT LEAST THIS AMOUNT Amount Enclosed Capital Ono Bank Ir~rr~rr~~rr~~srrr~l~~ P.O. Box 70884 Charlotte, NC 24272-0884. u~r~~n~ur~r~~ar~n~r~~~nr~n~a~rr~u~u~~rr~u~u~~ar~~ Account Number. 4862-3624-4542-1004 Meese prat addressor phone number clvnges behw using blue or black ink address Home Phox A#emare PMre E-maa address ~ #9033051722155601# MAIL ID NOMBER SCOTT A FO% 490 DARTMOUTH ST APT a6 HARRISBURG, PA 17109-6439 nr~~~as~m~~~~nr~r~ur~~ru~u~u~~r~r~rsu~r~r~~nu~r~~ 6889014 Please write your account number on your check or money order made payable tD Capital One Bank and mall with this coupon In the encbsed envelope '1 CAPITAL ONE BANK (USA), N.A., Plaintiff, v. SCOTT A FOX 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 aze true and correct to the best of his/her knowledge, information and belief. , (~ ~ l~ Dated: ~ 2 ~ Edwazd Piotrowski A049 WELTMAN, WEINBERG & REIS CO., L.P.A. ~ ~ ~ 3~ ~ ~"-r+~ ~' _, ~ ~ ~::: ~!'~ ~ ` , -~C ,.: W ~ a ~ ~. ut ~:~ ,_. oho ~ °~ ~ ~~ s~"s ~C ~ N ...~ ~ ..~. cry b