HomeMy WebLinkAbout09-0148
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK (USA),NA
Plaintiff No: ~~ - p~t~g ~VcI ~~~
vs.
COMPLAINT IN CIVIL ACTION
JOHN E BEVINS
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
06860241 C N Pit REA
1
IN THE COURT OF COMMON PLEASCIVIL~DBIVIS ON COUNTY, PENNSYLVANIA
CAPITAL ONE BANK (USA),NA
Plaintiff
vs.
JOHN E BEVINS
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:
JOHN E BEVINS
102 W. HIGH ST., #405
CARLISLE, PA 17013
3. Defendant applied for and received a credit card bearing the
account number XXXXXXXXXXXX4247 .
4. Defendant made use of said credit card and has a current balance
due of $1859.34 as of October 24, 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
16.400 per annum on the unpaid balance from October 24, 2008 A copy
of Plaintiff's STATEMENT is attached hereto, marked as Exhibit "1" and
made a part hereof.
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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 JOHN E BEVINS INDIVIDUALLY in the amount of
$1859.34 with continuing interest thereon at the rate of 16.400$s per
annum from October 24, 2008 plus costs.
James c.
WELTMAN,
436 Seve
Pittsbu
(412) _
FAX: 4
06860 ~
This law firm is a debt collector attemp
our client and any information obtained
ro t,42524
NBERG & REIS CO., L.P.A.
Avenue, Suite 1400
PA 15219
955
8-7130
N Pit REA
to collect this debt for
be used for that purpose.
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CAPITAL ONE BANK (USA), N.A.,
Plaintiff.,
v.
JOHN E BEVINS
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: ~ ~~~~~~
Courtney Sto e
A049
WELTMAN, WEINBERG & REIS CO., L.P.A.
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