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Home My WebLink About09-0688IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff vs. RACHEL OHARA Defendant No. aq _ X88 Civil Terw, COMPLAINT IN CIVIL ACTION FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: JAMES C. WARMBRODT, Esquire PA LD. #42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#7050011 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff vs. RACHEL OHARA Defendant Civil Action No. COMPLAINT IN CIVIL ACTION 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 COLUMBIA COUNTY SUSQUEHANN VALLEY LEAL SERVICES 168 EAST FIFTH STREET BLOOMSBURG, PA 17815 (717) 784-8760 COMPLAINT 1. Plaintiff is a corporation with offices in 15000 CAPITAL ONE DRIVE RICHMOND, VA 23238. 2. Defendant is an adult individual residing at 69 PROSPECT RD CARLISLE,PA 17015 . 3. Defendant applied for and received a credit card issued by Plaintiff bearing the account number :4862362599946350. 4. Defendant made use of said credit card and has currently a balance due and owing to Plaintiff, as of DECEMBER 23, 2008, in the amount of $ 1,182.46. A true and correct copy of Plaintiff's Statement of Account is attached hereto, marked as Exhibit "1" and made a part hereof. 5. Defendant is in default of the terms of the cardholder Agreement having not made monthly payments to Plaintiff thereby rendering the entire balance immediately due and payable. 6. Plaintiff avers that the Cardholder Agreement between the parties provides that Plaintiff is entitled to the addition of finance charges at the rate of 27.10% per annum on the unpaid balance. 7. .Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed and/or refused to pay the principal balance, finance charges or any part thereof to Plaintiff. WHEREFORE, Plaintiff demands Judgment in its favor and against Defendant, RACHEL OHARA individually, in the amount of $ 1,182.46 with continuing finance charges thereon at the rate of 27.10% per annum from DECEMBER 23, 2008 plus costs. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED SHALL BE USED FOR THAT PURPOSE. WELTMAN, WEINBERG & REIS, CO., L.P.A. JAMES C ARMBRODT, Esquire PA I.D. # 2 24 WELT A , WEINBERG & REIS CO., L.P.A. 1400 pp rs Building 436 S ve h Avenue Pitts ur , PA 15219 (412/j ~4-7955 WWR#:7050011 4 FINANCE Proviou: Balantro PaymeEts 6 CledRs CHARGE Transactions New Balanu Minimum PaymaM Due Date $506 26 - $20 00 + $12 02 + $5 gg = $504 27 $15 00 Mar 27, 2007 Jan 28, 2007 -Feb 27, 2007 Page 1 of 1 PLEASE q4Y 41 IEAST llllt AEA(aIAT Visa Platinum Account 4862.3825.9984.80 Your Account Irrfonnation TOTAL CREDIT LINE $500 00 TOTAL AVAILABLE CREDIT $0 00 CREDIT LINE FOR CASH $500 00 AVAILABLE CREDIT FOR CASH $0 00 Finance Charges (Please see reverse to unportant mfamauon) Balance rate PedodLC CortecponduLp FINANCE appled to rate APR CHARGE Purchases $490.84 0 07712% D 2B 15% $11 73 Cash 511 95 0 07712% D 2815% $029 ANNUAL PERCENTAGE RATE applied this period. 28.15% ® AtYOUrSenieel•800.803.3837 To cal CEatamw Robtlorie v to repLxt a brt or stden card ® ~'~ Pai7neMs to. Ceptel One 9enk P.0 Box 70664 Cherbtte, NC 215272-0684 A Send inquiries to. Caper) One P 0 cox 3028.5 Sea Lela qty, UT 84130-0285 Payments. Credits 6 Adiustmerda 1 10 FEB PAYMENT =~ ~, Transactions 2 i6 FEB ROSS STORESp689CARLISLEPA 5599 "' Please Note'•' Some or the terms of your account ere chanpmp Please read the endosad nohfirYihon i/~1 IJ:i~ 6056 506 1 7 27 070227 PAGE 1 of 2 O1BC6056 PLEASE RETURN PORTION BELOW V1eTH PAYMENT 0 4862362599946350 27 0504270020000015009 Ch1e• I what's.nyourwalkKT New Balance Minimum Payment Due Date $504 27 $15 00 Mar 27, 2007 PLEASE PAY AT IEAST THIS AMOUNT Amount Endosed Capital One Bank P.O. Box 70864 rErEErrr"'~rErErrrrEr Charlotte. NC 28272-0884 r ErrrurrrEE ErruEEErnrErnrE Er EErEr rr rrErrruErrnrrrnEEEu Account Number. 4!862-3625-99946350 Please print address or phone number changes bebw using blue or black ink Address Home Phone Altemafe Plane E-mail address Q •9005984947773173a NAIL ID NUMBER RACHEL OHARA 69 PROSPECT RD CARLISLE. PA 17815-9789 urrrlrnrrronurrErErErErnruErrnrrrrrnErrrrrErurr Err 7050011 p~Ly~ write your account number on your chL~ck 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. RACHEL OHARA 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: ~ S C~ ~ ~ ~./~. Edward Piotrowski A049 WELTMAN, WEINBERG & REIS CO., L.P.A. ~~C~jCO~~ - ~~ ~ . g, ~ 0 R~ ~] `~ ~ ~ ~_ C? !~ _ ~ ~ -r' ~'R Q _ -; ~ ~ _ ..ai.~ ~ ~.} ~ ` ^ b J t l 4 1 q J J I q ~ l W ~-- { ~~ J .~ SHERIFF'S RETURN - REGULAR CASE NO: 2009-00688 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CAPITAL ONE BANK USA N A VS OHARA RACHEL KENNETH E GOSSERT Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, wha being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon OHARA RACHEL the DEFENDANT at 0014:30 HOURS, on the 11th day of February 2009 at 69 PROSPECT RD CARLISLE, PA 17015 TAMMY OHARA by handing to MOTHER OF DEFENDANT a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge Postage So Answers: 18.00 4 . 5 0 .r~~ .00 10.00 R. homas Kline .42 32.92 02/11/2009 WELTMAN WEINBERG & REIS Sworn and Subscibed to By: before me this day of A.D. £`7 r.,, ~ +~ t~~ Ct7 ~ ~. ~_ - v --{~ `~G _ ~Zy ''j ~`~, "+' :~, ~7 ...~ ~ ~!