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Home My WebLink About09-0687 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff No: (R- &,qq &vtl Iem vs. COMPLAINT IN CIVIL ACTION JAMES A ORRIS 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 06508489 C N Pit IAS IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff VS. Civil Action No JAMES A ORRIS 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: JAMES A ORRIS 800 ROSEMONT AVE NEW CUMBERLAND, PA 17070 3. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXX0132 . 4. Defendant made use of said credit card and has a current balance due of $1136.13 , as of November 19, 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 28.990% per annum on the unpaid balance from November 19, 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 , JAMES A ORRIS , INDIVIDUALLY , in the amount of $1136.13 with continuing interest thereon at the rate of 28.990% per annum from November 19, 2008 plus costs. James c. WELTMAN, 436 Seven Pittsburg (412) 43 FAX: 412 0650848 This law firm is a debt collector attempti our client and any information obtained wi rodt,42524 ERG & REIS CO., L.P.A. enue, Suite 1400 A 15219 5 -7130 Pit IAS 'to collect this debt for be used for that purpose. $ g? x= 0 a oA K F d FL'? as v g o V S ER ?y N S as ?' $$8 CW,7 008?? IRA 8888 11 M w ? j I hat 11114 it 1 v lit 1 HA it o a ilia c ? a,??' g ••?? fig. •? C"Fii zFd Q.? "t R° fold W88L8 10 A ti N N O 0 0 N 0 0 ti ? N 0 r ? 'a N a M r H a 3 30 M a Mo m N z 10 r M N a pip z s a o a o v O ? O ? o 8 V L ? o o- ? n - a = ,, w a S ? m W CtiU ? o W I?' ? ?I I?I smsoo N 0 _ CN _ n 0 o N 5 1 - . qnm - ?m o a u - ao z r CAPITAL ONE BANK (USA), N.A., Plaintiff, V. JAMES A ORRIS 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: 12, 12 --- ! Darious Nelson A049 WELTMAN, WEINBERG & REIS CO., L.P.A. 00 00 wo c q N a ?n m Co G '1c N C'+ --n .?j Y SHERIFF'S RETURN - REGULAR CASE NO: 2009-00687 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CAPITAL ONE BANK USA N A VS ORRIS JAMES A STEVE BENDER Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE ORRIS JAMES A DEFENDANT the , at 0013:50 HOURS, on the 12th day of February , 2009 at 800 ROSEMONT AVE NEW CUMBERLAND, PA 17070 JAMES ORRIS DEFENDANT was served upon 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: So Answers: Docketing Service 18.00 15.30 Affidavit ,00 Surcharge 10.00 n R. Thomas Kline 43.30 02/13/2009 WELTMAN WEINBERG & REIS Sworn and Subscibed to By: before me this day Deputy Sheriff of A.D. ? 4_ .? ? ? w? ?^c'S ...?' ,,,, _ - ..+"' ?' ? r H ? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff vs. JAMES A ORRIS Defendant(s) No. 09-687 CIVIL TERM PRAECIPE TO SETTLE, DISCONTINUE AND END WITH PREJUL)ICE TO REFILE FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD (JF THIS PARTY: James C. Warmbrodt, Esquire PA LD. #42524 WELTMAN, WEINBERG & REIS CO., L.P.A 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 1521.9 (412)434-7955 WWR#6508489 CFR IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DNISION CAPITAL ONE BANK (USA),NA Plaintiff vs. Civil Action No. 09-687 CIVIL TERM JAMES A ORRIS Defendant(s) PRAECIPE TO SETTLE DISCONTINUE AND END WITH PREJUDICE TO REFILE TO THE PROTHONOTARY OF COUNTY: Settle, Discontinue and End With 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 mbrodt, Esquire PA I.D. #4 5 4 WELTM WEINBERG & REIS CO., L.P.A 1400 Ko pe s Building 436 Se nt Avenue Pittsb , PA 1.521.9 (412) -7955 W 6508489 Sworn to and subscribed Before me the f Day of Oo TA UBL ~Ge~~'~~",~sr+tltlsf ;4' Te-! ~ ~n` t3E~~P~:;i a '•~,=~s' Neu2riai deal 1r'7zdvn+~ A..Canes, ~Jatary Puf<!! Gity of t=ittshurgh, Allegk~eny Caunty ~Ey Canan~issian expires Juna 29, . '! 0 *,:2<:..,,~ ~~ , F ~nnsylver ita A^ saci~iian a'+ ~~dalt;~rie 1009 JUL 22 Pty 2= S 3