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Home My WebLink About09-0482M IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff VS. DOUGLAS C DISBROW No : DQ 60? L Q7&n 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 15219 (412) 434-7955 FAX: 412-338-7130 07029565 C N Pit REA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff vs. DOUGLAS C DISBROW 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: DOUGLAS C DISBROW 6 DOGWOOD DR MOUNT HOLLY SPR, PA 17065 3. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXX1447 . 4. Defendant made use of said credit card and has a current balance due of $1385.89 , as of December 02, 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 28.100% per annum on the unpaid balance from December 02, 2008 . A copy of Plaintiff's STATEMENT is attached hereto, marked as Exhibit 111" 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 , DOUGLAS C DISBROW , INDIVIDUALLY , in the amount of $1385.89 with continuing interest thereon at the rate of 28.100 per annum from December 02, 2008 plus costs. James C. ar rodt,42524 WELTMAN EINBERG & REIS CO., L.P.A. 436 Se en h Avenue, Suite 1400 Pitts r PA 15219 (412) 43 -7955 FAX: 41 -338-7130 0702 5 C N Pit REA This law firm is a debt collector attem?t ng to collect this debt for our client and any information obtained ill be used for that purpose. FINANCE Previous Balance Payments & Credits CHARGE Transactions New Balance Minknum Payment Due Date $847 63 - $0 00 + $19 85 + $29 00 = $896 48 $39648 Jun 07, 2007 Apr 08, 2007 -May 07, 2007 Page 1 of 1 PtEAq MY AT LMST THS AWKIAT Your account is sic payments behind t we charge off your sanurA due to Iate payments, we will report the MasterCard Platinum Account charged-off status to several national credit bureals, and the Purchase APR as receded on this statemerd will 51 T&052}8512.1417 be applied to aN your outstanding balances Act now to prevent the from happening Please pay the amount due our statement or give us a cell at 1500 955.6600 Well wort with you so you can lake cods of your on Your Account Information y account and start rebuilding your creM w lh Capital One TOTAL CREDIT LINE $500 00 TOTAL AVAILABLE CREDIT $0 00 "important Noticee• Under the tennis we previously disclosed to you, your account is now eligible for an increase CREDIT LINE FOR CASH $'00 00 in Annual Percentage galas (APRs) effective immediately However, Caphfal One has elided not to rase your AVAILABLE CREDIT FOR CASH $$000000 APRs at this t ne Please be advised that it you fad to keep your account in good standing, Capital One reserves the right to raise your APRs in the future information) Finance Charges (Please see reverse for important ptn rate emce g CHARGE Payments Cladit8 & Ad?ustments add 10ra APR Purchases $655144 0 07712% D 2615% $1985 Transactions $2900 Cash $000 0 07712% D 2815% $000 1 07 MAY PAST DUE FEE ANNUAL PERCENTAGE RATE applied this period. 26.15% You were assessed a past due fee because your mmmwn payment was not received by the dire data To avoid At Yaw Service IMC-203.3537 this fee in to "re, we recommend shat you allow at least 7 bunuhess days for your mrmmrin payment to reach To oar customer Reletons or to report a lost a slden card ® Capital One ® Serd payments to. Capital One Banc P 0 Box 70864 Chaldte. NC 28272-0884 Send pital Inquiries I P 0 Bah 30285 Sao Lake City. UT 841 W-0285 A Ca 6056 506 1 7 7 070507 PAGE 1 of 1 OIBC6056 PLEASE RETURN PORTION BELOW WITH PAYMENT _ 0 5178052385421447 07 0896480015000396480 ?` what's in yourwalkV Account Number. 5178-0523-8542-1447 New Balance Minimum Payment Due Date Please print address or phone number changes below using blue or black ink Address C$896 48 $39648 Jun 07, 2007 PLEASE PAY AT LEAST Name Phone Akemare Plane THIS AMOUNT E-mail address Amount Endosed #9012076421731191# NAIL ID NUMBER DOUGLAS C DISBROW h DOGWOOD DR MOUNT HOLLY SPRINGS, PA 17D65-1138 Capital One Bank P.O. Box 70884 Charlotte, NC 28272-0884 n1114111111111111111111111111111111111 7029565 Please write your account number on your check or money order made payable to Capital One Bank and mad with this coupon in the enclosed envelope PROTHONOTARY CUMBERLAND CO CAPITAL ONE BANK (USA), N.A., Plaintiff, V. DOUGLAS C DISBROW 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: Edward Piotrowski A049 WELTMAN, WEINBERG & REIS CO., L.P.A. "6CL \VJ' - 1 p C_.7 "i"9 COO SHERIFF'S RETURN - REGULAR CASE NO: 2009-00482 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CAPITAL ONE BANK (USA) NA VS DISBROW DOUGLAS C 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 DISBROW DOUGLAS C the DEFENDANT , at 2109:00 HOURS, on the 3rd day of February-, 2009 at 6 DOGWOOD DR MT HOLLY SPRINGS, PA 17065 by handing to 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 So Answers: 18.00 5.40 , 00 10.00 R. Thomas Kline .00 33.40 02/04/2009 WELTMAN WEINBEREI Sworn and Subscibed to C before me this day of , By: ty-Sheriff A. D. r- uj y:? 4 f LLI co a• EE LAJ LZ 1-D LL CIQ t, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff vs. No. 09-482 CIVIL TERM PRAECIPE TO SETTLE, DISCONTINUE & END WITH PREJUDICE DOUGLAS C DISBROW Defendants FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: Matthew D. Urban, Esquire Pa. I. D. No. 90963 Weltman, Weinberg & Reis, Co, LLC 1400 Koppers Building 436 7`h Avenue Pittsburgh, PA 15219 WWR#7029565 k IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff vs. Civil Action No. 09-482 CIVIL TERM DOUGLAS C DISBROW Defendants PRAECIPE TO SETTLE DISCONTINUE AND END WITH PREJUDICE TO THE PROTHONOTARY OF COUNTY: Please kindly Settle Discontinue and End the above captioned matter with Prejudice upon the records of the Court and mark the cost paid. WELT AN, WEINBERG & REIS CO., L.P.A. By: Ma hew D. Urban, Esquire Pa. I.D. No. 90963 Weltman, Weinberg & Reis, Co, LLC 1400 Koppers Building 436 7'i' Avenue Pittsburgh, PA 15219 WWR#7029565 Sworn to and subscr Before me the Day of MARCH, 20 N ARY PU COMMONWEALTH OF PENNSYLVANIA Notarial Seal Wayne A. Jones, Notary Public City of Pittsburgh, Allegheny County My Commission Expires June 29, 2010 Member, Pennsylvania assn^„iation of Notaries RLER4*'Q%, OF THE PROT "MOTARY 2009 APR -3 PM 1: 49 Ctl;f jj??