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Home My WebLink About09-0270IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff No: pQ a276 VS. COMPLAINT IN CIVIL ACTION KAREN L MAUGER 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 06667996 C N Pit REA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff VS. Civil Action No KAREN L MAUGER Defendant 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 COMPLAIN'T' 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: KAREN L MAUGER 1702 LOCUST ST NEW CUMBERLAND, PA 17070 3. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXX9971 . 4. Defendant made use of said credit card and has a current balance due of $1306.47 , 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 28.1001 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. 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 , KAREN L MAUGER , INDIVIDUALLY , in the amount of $1306.47 with continuing interest thereon at the rate of 28.100$ per annum from October 24, 2008 plus costs. James C. ro t,42524 WELTMAN, W INBERG & REIS CO., L.P.A. 436 Sev th Avenue, Suite 1400 Pittsbu gh, PA 15219 (412) 4-7 55 FAX: 4 2-3 8-7130 06667 96 N Pit REA This law firm is a debt collector attemp in to collect this debt for our client and any information obtained i be used for that purpose. EXHIBIT NO-Amw Previous Balance p FINANCE aymerds & Credits CHARGE Transactions New Balance Minimum Payment Due Data $1,083 40 - $0 00 + $25 37 + $35 00 $1,143 77 $443 77 Nov 27, 2006 Sep 28, 2006 - Oct 27, 2006 Page 1 of 1 nEASE MY AT LFAST TM AWAT MasterCard Platinum Account 5176-0525.7188.9071 Your Account Information TOTAL CREDIT LINE $70000 TOTAL AVAILABLE CREDIT $000 CREDIT LINE FOR CASH $70000 AVAILABLE CREDIT FOR CASH $000 Finance Charges (Please see reverse for rryortand nformakon) Balance rats Periodic Comanding FINANCE appiedto rate APR CHARGE Purchases $1,096 77 0 07712% D 2815% $2537 Cash $0 00 0 07712% D 2815% 50 D0 ANNUAL PERCENTAGE RATE applied this period. 28.15% ® At Your Service 1.8W 9W 3637 To cap Custmla Relelion, orlo report a kxa or stolen cad 0 Sand paymerds to. taped Ore Bank P 0 Bas 70881 Charlotte. NO 28272-OW A Send Inquiries to. Capital Ore P 0 Bic 30285 Salt Lake CRY, UT 80130-0285 6056 506 1 7 27 061027 CWHaachv I what'smyourwatletT Your account us sox payments behind If we charge off your account due to late payments, we will report the d arpeddF status to sever i naharhel O'sk bureaus Act now to prevent this tom happening Reese pay the amount due on your statement or give us a call at 1 BW 955 8800 Well work with you so you can take control of your account and start rebuilding your credit with Capital One Payment% Credits 8 Adlustments Transactions 1 27 OCT PAST DUE FEE $3500 Your account is 90 days peat due and your Payment piceaction coverage has been suspended As stated in Your Payment Probw on agreement, your coverage end monWy dwrge val be rsnsta0ed once your account is no longer 90 days past due You may sit be ekgble fa benefits to be paid to your account in cases of dilabliy, unemployment and death Call Slonebridge Benefit Servants at 1. 1968.5276904 tog" d your sduakon qualifies for a benefit acevabm You were assessed a past due fee because your minimum payment was not received by the due data To avoid this fee in to fuWre, we recommend that you allow at least 7 business days fa your minmum payment to reach Capital One PAGE 1 of 1 COLR233B 01BC6056 PLEASE RETURN PORTION BELOW WITH PAYMENT 0 5178052571689971 27 1143770017000443778 New Balance Minimum Payment Due Date C$1,143 77 $443 77 Nov 27, 2006 PLEASE PAY AT LEAST THIS AMOUNT Amount Endosed Capital One Bank 11111111111111111111 P.O. Box 70884 Charlotte, NC 28272-0884 11111111111111 III 1111111 11111111111181 1111111111 1111111111111 Account Number: 5178-0525-7168-9971 Please Print address or phone number changes below using blue or black ink Address Horne Phone Alremare Phone E-mat! address @ e9030161831405621e MAIL ID NUMBER KAREN L MAUGER 3,702 LOCUST Sr NEY CUMBERLAND, PA 17070-1458 1111111111111111a11111111sill 111111111111111111111111I111111 6667996 please write your account number on your check or money order made Y payable to Capital One Bank and marl with this coupon in the enclosed envelope CAPITAL ONE BANK (USA), N.A., Plaintiff, V. KAREN L MAUGER Defendant(s). VERIFICATION The undersigned does hereby verify subject to the penalties of 18 Pa.C.S. Section 4904 relating to unworn 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: j al 11 4 0,1, ? '-? Courtney e A049 WELTMAN, WEINBERG & REIS CO., L.P.A. f? Y N roe. c n C' { `l N N f'Il T p.7 ?r? o(j) SHERIFF'S RETURN - REGULAR CASE NO: 2009-00270 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CAPITAL ONE BANK (USA) NA VS MAULER KAREN L SHAWN HARRISON , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon MAULER KAREN L the DEFENDANT , at 2116:00 HOURS, on the 23rd day of January , 2009 at 1702 LOCUST ST NEW CUMBERLAND, PA 17070 by handing to DONALD MAULER, HUSBAND a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof Sheriff's Costs: Docketing Service Affidavit Surcharge Sworn and Subscibed to before me this of 18.00 14.40 .00 10.00 .00 42.40 day So Answers: R. Thomas Kline 01/26/2009 I w By: WELTMAN WEINB R A. D. -y Sheriff pu`F u.M. arr+ 71 GO IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA) N.A. Plaintiff vs. No. 09-270 CIVIL TERM PRAECIPE TO DISCONTINUE AND END WITHOUT PREJUDICE TO REFILE KAREN L MAUGER Defendant 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#6667996 k . r IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA) N.A. Plaintiff vs. Civil Action No. 09-270 CIVIL TERM KAREN L MAUGER 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: Attorney for Plaintiff 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#6667996 SWORN TO AND SUBSCRIBED LT_ I C1 _ Y VANIq Had Nola?lal Seal J. K* Nowy pW* Cky OfP ?M DommNNon E06i NOV. 4,2009 Member, P ""00"Me Assoaedon of N~04 before me this 4T" day f`? r„? «7..: ? ?-_ _ w^4i _ i ?.. ? 3? C5 > ,.i S ??. rr? ?.?3 .?-„