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Home My WebLink About09-0682 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff No : Oq - Wol vs. COMPLAINT IN C MICHAEL D GRANT Defendant FILED ON BEHALF Plaintiff COUNSEL OF RE THIS PARTY: James C. Warmbrc WELTMAN,-WEINBER 436 Seventh Aver. Pittsburgh, PA (412) 434-7955 FAX: 412-338-713 06993577 C N Pit PENNSYLVANIA { ( -61-1- ACTION OF t, 42524 & REIS CO., L.P.A. e, Suite 1400 5219 IAS IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff vs. MICHAEL D GRANT Defendant Civil Action No COMPLAINT AND NOTICE TO DEFEND You have been sued in court. If you wish to claims set forth in the following pages, you must twenty (20) days after this complaint and notice a written appearance personally or by an attorney with the court your defenses or objections to the against you. You are warned that if you fail to c proceed without you and a judgment may be entered court without further notice for any money claimec for any other claim or relief requested by the plz money or property or other rights important to yoi YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELE: FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL H: IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS 1 TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES TH. SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIA 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 PENNSYLVANIA iefend against the :ake action within :e served, by entering ind filing in writing :laims set forth so the case may igainst you by the in the complaint or Lntiff. You may lose ONCE. IF YOU DO NOT HONE THE OFFICE SET LP. FFICE MAY BE ABLE T MAY OFFER LEGAL O FEE. COMPLAINT 1. Plaintiff, CAPITAL ONE BANK (USA),NA is a corp ration with offices at 15000 CAPITAL ONE DRIVE RICHMOND , VA 23238 . 2. Defendant is adult individual(s) residing at tae address listed below: MICHAEL D GRANT 6 FOX HOLLOW LN CARLISLE, PA 17015 3. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXX7458 . 4. Defendant made use of said credit card and has a current balance due of $1217.72 , as of October 14, 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 25.900% per annum on the unpaid balance from October 14, 2008 . A copy of Plaintiff's STATEMENT is attached hereto, mark d 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 i its favor and against Defendant , MICHAEL D GRANT , INDIVIDUALLY , in the amount of $1217.72 with continuing interest thereon at the rate of 25.900% per annum from October 14, 2008 plus costs. t,42524 James C. lwl? rmbro WELTMAN, W INB RG & REIS CO., L.P.A. 436 Sev t Avenue, Suite 1400 Pittsbu g , P 15219 (412) 34 7955 FAX- 4 2- 38-7130 06993 77 C N Pit IAS This law firm is a debt collector attempIx-l g to cllect this debt for our client and any information obtained be used for that purpose. FINANCE Previous Balance Paymetda 6 Credb CHARGE $930.61 - $0.00 + $21.14 Jan. 03, 2008 - Feb. 01, 2008 Page 1 of 1 Visa Pi tinm A cimit 4802 3l28A7W409 Your Amount Ilhm adon TOTAL CREDIT LINE $500.00 TOTAL AVAILABLE CREDIT EO.OD CREDIT UNE FOR CASH $600.00 AVAILABLE CREDIT FOR CASH $0.00 Fina= Charges (Please see worse for Important intimat Balance rate Peno* Corespondrcg FRANCE applied to rate APR CHARGE Purchases 394742 007438%D 2716% $2114 Cash $0 00 0.07438% D 27196 $0.00 AtNUAL PERCENTAGE RATE tppNad fhH psllod: 27.19/. ZM1 At YourServln 1MMIKIMN To cal Cwlnter fi?vsarbreput a bstor ? cad ® Send payMKb b: Clip 1W 0rs Bank • P D Brno 10884.Oablm, IJC 26272-0Bed Sorel knisdrin to: (ApiDal Ow reP PO 0 Buz 30285 • Set Lalaa Cry, LR 8k1311-0186 ® Ham it questimabout achaWonyewI t rind? Please refer to the Biting Rghte Summary on the back of your statement or visit www.capitaloneicom/chisoutes; 1'11ASE RErURN PORTION BELOW WITH PAYMEI Q42"Dj` what': in your walla?" 0 48 New Balance Minimum Payment Due Date C$990.95 $490.95 Feb. 26, 2008 PLEASE PAY AT LEA5T THISAMOUNT Amount Enclosed Capital One Bank P.O. Box 70664 Charlotte, NC 26272-0664 111 11 1111 1111 11 11111 111 11 111111111 11111 111 111 11,1111 1 11 11111 11 6993 577 Please write your aauurR number on your diedk or money order r II Tramacdons New Balance M inimum Payment Due Date I+ $38.00 = $990.95 $490.95 Feb. 26, 2006 r FAS PM AT LEAS "N6 A40' N7 Your accent is sN Dayments WNW If we charge off =Mmt diem LIDS oeY'nerns, wo oil repot the cargKWff status to several rational credit bureaus the Purchase APR as reflected on this statement will be aroked to al your outstanding baWM now to orwent this ham 'apoenng Plasm oW the amount due on your statement or give us a cat at eM 9%M We'll work will you so you can lake ccm;ul of your auDJd and start retulk iq you u wdh Gap" One `Important Notrod° Lkdar the terms we piemusly to you, your account is row dgt:la for an Increase in Amyl PBIcen age Rates (APRs) dfecbve m H waver, Capital Ors has elected rot to mis@ your APRs at this time. Please be adnsed that i you fad to keep your account n grad stand g, Ca al One reserves the right to rase your APR in the future, Paymerift. Credits 8 usbrlents TransKWM 1 28,AN PAST DUE FEE $30.00 Youwere aesesseda past dse fee tXtmm your mlfl wn payment was not racaned by the due date To mood the fee n the fubxe, we recommend that you albw least 7 business dads lbr your mrwnun payment to reach Capital One. EXHIBIT IT OR LOG ON TO YWWY.CAPITALONEiCOM TO MAKE OUR PAYMENT ONLINE 62362663457458 01 099095 0020000490957 Account Number: 4862-3626-634 5-7459 Please print address or phone number changm Addgw below using blue or blade it* / HOW F/WM 57NO Ph" E.meBaddvrss 99003327867835535 6 MAIL ID NUMBER RICHAEL D GRANT h FOX HOLLOW LN CARLISLE, PA 7"iit ?ur???ur???uunIIaIrIrIurIIrIr rurI lade payable to Capital One Bank and mail with t is wupwt in the enclosed envelope. CAPITAL ONE BANK (USA), N.A., 'Plaintiff, v. MICHAEL D GRANT Defendant(s). VERIFICATION The undersigned does hereby verify subject to the penalties of 18 Pa.C. to unworn falsification to authorities, that he/she is an authorized agen BANK (USA), N.A., Plaintiff herein, and that he/she is duly authorize Verification, and that the facts set forth in the foregoing Complaint in correct to the best of his/her knowledge, information and belief. Dated: Z44 'a d A049 WELTMAN, WEINBERG & REIS CO., L.P.A. Ottis Coward Section 4904 relating of CAPITAL ONE to make this ivil Action are true and t, qq `:? i l r rv O Tif }? f'*i U S b i - Fn ?? ++ p .+. V.•rtl ti J ? ' c.n c SHERIFF'S RETURN - NOT FOUND CASE NO: 2009-00682 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CAPITAL ONE BANK USA N A VS GRANT MICHAEL D 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 GRANT MICHAEL D but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT & NOTICE the within named DEFENDANT , GRANT MICHAEL D 6 FOX HOLLOW ROAD NOT FOUND , as to CARLISLE, PA 17015 PER EX-WIFE, DEFENDANT LIVES AT 468 HIGH STREET, STEELTON, PA. Sheriff's Costs: Docketing Service Affidavit Surcharge Not Found So answers: --A 18.00 4.50 .00 R. Thomas K1 ne 10.00 Sheriff of Cumberland County 5.00 37.50 WELTMAN WEINBERG & REIS 02/13/2009 Sworn and Subscribed to before me this day of A. D. ?i ...' ,-Y1 i'? ? t ?;`.? r ..t°? fi r" ??? ?? ?; M1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff vs. MICHAEL D GRANT Defendant(s) No. 09-682 CIVIL TERM PRAECIPE TO SETTLE, DISCONTINUE AND END WITHOUT PREJUDICE TO REFILE 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) 434-7955 WWR#6993577 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff vs. Civil Action No. 09-682 CIVIL TERM MICHAEL D GRANT Defendant(s) PRAECIPE TO SETTLE, DISCONTINUE AND END WITHOUT PREJUDICE TO REFILE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: SIR Kindly settle, discontinue and end without prejudice to refile the above-captioned matter upon the records of the Court and mark the costs paid. WELTMAN, WEINBERG & REIS CO., L.P.A. By: James C. W PA I.D. #42 WELTMA Esquire RG & REIS CO., L.P.A. 1400 Kop ers uilding 436 Seve th venue Pittsburg A 15219 (412)434-7955 SWORN TO AND SUBSCRIBED before me this ? ` day Member, Pennsyivania A ...Ultio . of Notaries RLED -OHFICE OF THE PR(OTHONDTARY' 2009 JUN -S FM 3: Q4 Gllm6- /U?f' P EN - jA?.y LW,