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Home My WebLink About09-0981IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff No: bq - q$I O,W4 (P.X`14 vs. COMPLAINT IN CIVIL ACTION CHRISTINA M CARLSON 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 07093550 C N Pit REA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff vs. CHRISTINA M CARLSON Defendant Civil Action No 6 / , 1.91 cjv, I 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: CHRISTINA M CARLSON 19 SEDARHUSRT LN CAMPHILL, PA 17011 3. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXX8834 . 4. Defendant made use of said credit card and has a current balance due of $1500.34 , as of December 05, 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 December 05, 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 , CHRISTINA M CARLSON , INDIVIDUALLY , in the amount of $1500.34 with continuing interest thereon at the rate of 25.900% per annum from December 05, 2008 plus costs. i James C. armbrodt,42524 WELTMAN EINBERG & REIS CO., L.P.A. 436 Se e h Avenue, Suite 1400 Pitts r , PA 15219 (412) 4 4-7955 FAX: 4 -338-7130 070 0 C N Pit REA This law firm is a debt collector attem]Kting to collect this debt for our client and any information obtained will be used for that purpose. Account Previous Valance $820.36 Payments, Credits and Adjustments $120.00 Transactions $.00 Finance Charges $16.79 New Balarim $717.15 Minimum Amount Due $217.15 Payment Due Date June 07, 2006 Total Credit Line $500 Total Available Credit $.00 Credit Line far Cash $500 Availabae Credit for Cash 5.00 Atyourservice To all Comma Rdrims or a report a last or sWm aril: 1-800-903-3637 send U C,?an One Rlme B Ban=a:k Smdmqumta Prooaung c?ntoae P.O. Bor 790216 P.O. Box 30285 St Lows, MO 63179-0216 SLC, UT 84130-0285 EXHIBIT s i PLATINUM MASIERCARD ACCOUNT 5178-0523-73348834 APR 08 - MAY 07, 2006 Page 1 of 1 Payments, Credits and Adjustments 1 28 APR DIRECT DEBIT PAYMENT $120.00- Your request to close your w== bas been reowvd. Your account will be closed when it reaches a $0 balance. Until then, you will confame to receive statements and must condone to make payments All terms and conditions of the aocwmt will y while a balance remains Please remember to cis yoxw cads and cancel all charges which witomatically ' to your account Finance Charges Pkaurarmffsenrkfirrnrfortmrt,n? xmmahon Balernfdf eeffirlte A m& C^r^?+ d fair ? I:Yl W PURCHASES $367.04 . CASH $421.68 . 07096% 25.90% 0709696 25.90% $7481 $&98 ANNUAL PERCENTAGE RATE applied this Period 25.90% ? PLEASE RETURN PORTION BELOW WITH PAYMENT cR 0000000 0 5178052373348834 07 0717150120000217154 New Balance $717.15 Minimum Amoura Due $217.15 Payment Due Date June 07, 2006 Total enclosed $ Account Number. 5178-0523-7334-8834 Capital One Bank P.O. Box 790216 1111111111111111111111 St. Louis, MO 63179-0216 FtemrprmJ mmlm6ai?tumd?orrm?d?Gor6rs lxlam urmgdlww blacF ink Stmt Ape # Qty Sue ZIP Home Pb.. Alemue Plume #9012705880104006# MAIL ID NUMBER CHRISTINA M CARLSON r 19 SEDARHUSRT LN e CAMPHILL PA 17011 m _ r 193550 Placeswiteyorwawmwnwndsronyowdwhorm my orderma*pw kto 0yWdOruBankandmalintheend"demvA fc. PROTHONOTARY CUMBERLAND CO CAPITAL ONE BANK (USA), N.A., Plaintiff, V. CHRISTINA M CARLSON 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. r 1 Dated: f 2. ` C? I r ^ Edward Piotrowski A049 WELTMAN, WEINBERG & REIS CO., L.P.A. Sty 00'' O W p Cal b -? SHERIFF'S RETURN - NOT FOUND CASE NO: 2009-00981 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CAPITAL ONE BANK USA N A VS CARLSON CHRISTINA M 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 CARLSON CHRISTINA M but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT & NOTICE , the within named DEFENDANT 19 CEDARHURST LANE NOT FOUND as to CARLSON CHRISTINA M CAMP HILL, PA 17011 CURRENT RESIDENT HAS LIVED AT THIS ADDRESS FOR OVER 2 YEARS; POST OFFICE WILL NO LONGER HAVE ANY INFORMATION ON FILE. Sheriff's Costs: So answer Docketing 18.00 Service 14 .4 0 Affidavit .00 R. Thomas Kline Surcharge 10.00 Sheriff of Cumberland County Not Found 5.00 47.40 WELTMAN WEINBERG & REIS 03/23/2009 Sworn and Subscribed to before me this day of , A. D. ce) 0-1 c:yl