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Home My WebLink About09-0344IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff VS. MICHELLE N ROUP AKA MICHELLE KIM AKA MICHELLE NICOLE ROUP Defendant No: cR- 344 O'ly1) (P-?a, 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 07006690 C N Pit REA . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA VS. Plaintiff Civil Action No MICHELLE N ROUP AKA MICHELLE KIM AKA MICHELLE NICOLE ROUP 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 .. 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: MICHELLE N ROUP 505 RITTENHOUSE SQ MECHANICSBURG, PA 17050 3. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXX2162 . 4. Defendant made use of said credit card and has a current balance due of $1360.80 , as of November 10, 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 29.200% per annum on the unpaid balance from November 10, 2008 . A copy of Plaintiff's STATEMENT is attached hereto, marked as Exhibit 111" and made a part hereof. 1 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 , MICHELLE N ROUP , INDIVIDUALLY , in the amount of $1360.80 with continuing interest thereon at the rate of 29.200% per annum from November 10, 2008 plus costs. James Wa ro t,42524 WELT WEINBERG & REIS CO., L.P.A. 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 (412) 434-7955 FAX: 412-338-7130 07006690 C N Pit REA 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. FINANCE Previous Balance Payments & Credits CHARGE Transactions New Balance Minimum Payment Due Date 2007 $366 69 Mar 11 $825 95 - $29 00 + $40 74 , + $29 00 = C$666 69 Dec 13, 2006 - Feb 12, 2007 Page 1 of 1 PLEASE MY AT (FAST TW AMOUKT Your account is six payments behind N we charge dF your account due to late payments, we will report the and the Purchase APR as reflected on the statement will onal oredd bureaus t l Visa Platinum Account 4662.3625-0495.2162 , i na charged-oft status to severa be applied to all your outstanding balancers Act now to prevent the train happening Please pay the amount due on your statement or give us a cal at 1800 955, 6600 well work wdh you so you can take control of your Your Account Information account and start rebuilding your credit with Capital One TOTAL CREDIT LINE $50000 TOTAL AVAILABLE CREDIT $000 "Important Notice" Under the terms we prevausly disclosed to you, your account is now eligible for an increase CREDIT LINE FOR CASH $50000 in Annual Percentage Races (APRs) effective immediately However, Capital One has elected not to rase your AVAILABLE CREDIT FOR CASH $0 00 APRs at this tme Please be advesd that if you fad to keep your account in good standing, Capital One reserves the right to rase your APRs in the future Finance Charges (Please see reverse for unpwtant inform an Periodic t. C°nespa dog CFIARGE Balance rate 4 APit Bill -- Payments, Credits 8 Adjustments ad 1 19 DEC Hardship Courtesy Fee Wa ver Purchases $62014 0 08011 % P 29 24% $4074 Cash $000 008011% P 29 24% $000 Transactions $29 00 ANNUAL PERCENTAGE RATE applied this period. 29.24X 2 12 FEB PAST DUE FEE ® At Your Service 14100.903.M37 You were assessed a past due fee because your minimum payment was not received by the due data To avoid our minimum payment to reach s for ss da 7 b l To col Custmw Relearns a m report a oust our atden cad y y usine east this fee in the future, we recommend that you allow at Capital One ® Sand payments to. CapRel One Bank PO erns 70864 Charlotte. NC 292720184 A Send inquiries to. Capital One P 0 Box 30285 Salt Lake City, UT 6 41 3 0-0215 17 6056 506 1 7 11 070212 PAGE 1 of 1 01BC6056 PLEASE RETURN PORTION BELOW WITH PAYMENT 0 4862362504952162 11 0866690025000366698 capma elJra4%" I what's in your wailetT Account Number. 4862-3625-0495-2162 New Balance Minimum Payment Due Date C$866 69 $366 69 Mar 11, 2007 PLEASE PAY AT LEAST THIS AMOUNT Amount Enclosed Capital One Bank IE'Er??'E,nIESP'I' re,? P.O. Box 70884 Charlotte, NC 28272-0884 1u1E11n1ndr11ndn1r111ndn111n18E1u[loll uluIIloll Please print address w phone number changes below using blue or black ink Address Home Phone Aremate Plane E-mail address a a900440726427363a HAIL ID NUMBER MICHELLE N ROUP 505 RITTENHOUSE SA MECHANICSBURG, PA 17050-1650 I III?IIIIIII'llll'III?IIIIIIII'I11?11'II I?IIII?I En111'Elu'EI 7006690 Please write your account number on your check or money order made payable to Capital One Bank and mall with this coupon in the enclosed envelope i CAPITAL ONE BANK (USA), N.A., Plaintiff, V. MICHELLE N ROUP 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 ' Civil Action are true and correct to the best of his/her knowledge, information and belief. Dated: 2 I ?' Edward Piotrowski A049 WELTMAN, WEINBERG & REIS CO., L.P.A. 44- n 3 00 00 fill, SHERIFF'S RETURN - NOT FOUND CASE NO: 2009-00344 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CAPITAL ONE BANK (USA) NA VS ROUP MICHELLE N AKA MICHELLE K 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 ROUP MICHELLE N AKA MICHELLE KIM AKA MICHELLE NICOLE ROUP but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT & NOTICE , NOT FOUND , as to the within named DEFENDANT ROUP MICHELLE N AKA MICHELLE KIM AKA MICHELLE NICOLE ROUP , 505 RITTENHOUSE MECHANICSBURG, PA 17050 DEFENDANT CALLED AND STATED THAT HER PHONE/ADDRESS IS: 106 FOXTROT DR. EIGHTY-FOUR, PA 15330 (724-941-3837) Sheriff's Costs: So answe Docketing 18.00 Service 9.00 Not Found 5.00 R. Thomas Kline Surcharge 10.00 Sheriff of Cumberland County .00 42.00 WELTMAN WEINBERG REIS 01/30/2009 Sworn and Subscribed to before me this day of , A. D. C 1 :01 WV 9- 83J 6001 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA), NA Plaintiff vs. MICHELLE N ROUP AKA MICHELLE KIM AKA MICHELLE NICOLE ROUP Defendant No. 09-344 CIVIL TERM PRAECIPE TO REINSTATE COMPLAINT 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) 434-79555 WWR#7006690 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA), NA Plaintiff vs. Civil Action No. 09-344 CIVIL TERM MICHELLE N ROUP AKA MICHELLE KIM AKA MICHELLE NICOLE ROUP Defendant PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. WELTMAN, WEINBERG & REIS CO., L.P.A. By: James C PA I.D. ; brodt, Esquire WELT W, WEINBERG & REIS CO., L.P.A. 1400 K ers Building 436S nth Avenue Pittsb gh, PA 15219 (412) 434-79555 WWR #7006690 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff No: vs. MICHELLE N ROUP AKA MICHELLE KIM AKA MICHELLE NICOLE ROUP COMPLAINT IN CIVIL ACTION 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 1523.9 (412) 434-7955 FAX: 412-338-7130 07006690 C N Pit REP., IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff vs. Civil Action No MICHELLE N ROUP AKA MICHELLE KIM AKA MICHELLE NICOLE ROUP 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 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: MICHELLE N ROUP 505 RITTENHOUSE SQ MECHANICSBURG, PA 17050 3. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXX2162 . 4. Defendant made use of said credit card and has a current balance due of $1360.80 , as of November 10, 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 29.200 per annum on the unpaid balance from November 10, 2008 . A copy of Plaintiff's STATEMENT is attached hereto, marked as Exhibit "1" and made a p*tEt 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 , MICHELLE N ROUP , INDIVIDUALLY , in the amount of $1360.80 with continuing interest thereon at the rate: of 29.200%° per annum from November 10, 2008 plus costs. t,42524 & REIS CO., L.P.A. 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 (412) 434-7955 FAX: 412-338-7130 07006690 C N Pit REA James Wa ro WELT WEINBERG 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. sy FINAAICE Previous BaWnm P msrds & Ctedib CHARGE Transactions New Balance Minimum Payment Due Date $825 95 - $29 00 + $40 74 + $2g 00 $gB6 fig -??Mar ,7 Dec 13, 2006 - Feb 12, 2007 Page 1 of 1 - PEPM Aw AT tsoT Ali AW"T Via Platinum Account /D625W9S-2162 Your Account Information TOTAL CREDIT LINE 5500 o0 TOTAL AVAILABLE CREDIT go 00 CREDIT LINE FOR CASH $500 oo AVAILABLE CREDIF FOR CASH $000 Finance Charges (Pram see reverse, to, npoAam adanaam) Balance fete PCbffv ME applied to APR krdnms :8W 14 O P 2924% 340 74 (?sli 00 02924% $0 fp ANNUAL PERCENTATE spplted 1Ns period. 28.24% AM At Your Servin 1.fttga 34657 0 Tocaa4abrtr n,4brw abraport aroAwskkn ad Sandpaymentsto, Cepsa.eam P08070881 Cbl"k NC21M- 6s Sand inqukks te. CepadOM POSM30M Saetsq Oty,UT8H3MM YouracmontissupayraeMsbeland RrrsdurpeoffWamowtduetolalepWmMs,wexirepr " dtaoedbRstri sou severY (06001110161111011011111, end to Pudpsa APR as ref odd onto stalemmt xa be applied loour yomoulHandog balances Ad now a prevent the tom happNrg Roam pay the annwrl due my0urat UNMOrgiveusadlIf18009516W Well work whtrwsoyouantake oywdWyr 2COMM and shit n 6oedng yW oodt with Cep W One "ImporhM Nbea° tkder the tmms we prewouely disdosd to you, your avour t a nowetgdk for an atcreem nAnnlydPeroanfepeRetu(APRs?eRecYvewwnadatdy tawerer,CsphOOnetysoladedrgtararmyour APRs It Bss line Plem be advised that it you W a keep your accowl n good ehndmg, Caphl One reserves this ngN a ram your APRs n to td re PaYmetfs, CredtEs & Adjustments 1 19 DEC Hmdshp Cmwtesy Pee War vet $29 ON Transactions 2 12 FEB PAST DUE FEE $2900 You were assessed a put due fee because yarmawmro payment was ad retard by the due dale To avmd this In at tie fWws, wa rwwmvd tat you allow at le" 7 bhaness days for your me ma papneM b reach Caplw Oat 6056 506 1 7 11 070212 C-Piwo w I -'s in your VA*d7 PAGE 1 of 1 OlDC6056 PLFJI6E FITURN PGRTION 88JOW YNTH PAYMENT 0 4862362504952162 11 0866690025000366696 New Balance Minimum Payment Due Date C$866 89 $366 fig Mar f 1, 2007 PLEASE PAY AT LEAST THIS AMOUNT Amount Enclosed C= Capital Onw Bank P.O. Box 711884 1r1n111u.I.b111,u1 Charlotte, NC 28272-0664 11,1111.a1,I'll 11,1111.1.1111., 111191111a111$11911ItItlll„711 Account Number. 41862-3625-0495-2162 Meese pmt address or phone number charges below uung blue or black ink Address Home Pfxm Alternate Phone f-madaddross e917U4460728427363a NAIL ID NUneEM MICHELLE N ROUP 405 RITTENHOUSE Sit MECHANICSBURG, PA 17050-1850 In,IIL,.Ill. Mill. ilr.,..1111.III tlJ.11mil..111 7006690 Please write your account number on your check or money order made trey payable to capital One Bank and mad with this coupon in the enclosed emeiope CAPITAL ONE BANK (USA), N.A., Plaintiff, V. MICHELLE N ROUP 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, Und 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' Civil Action are true and correct to the best of his/her knowledge, information and belief. I ?-J 1 6 Dated: { 2 U Edward Piotrowski A049 WELTMAN, WEINBERG & REIS CO., L.P.A. OS FL r_ r O TH, t` T 4'ui? +42 Pi f5 PJ. o#,d"f /-#] y eW f d-7a 76 AA? It