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Home My WebLink About09-1221 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff No : (A - faU I O-A'v;l -FerP- vs. COMPLAINT IN CIVIL ACTION L R ROSER CHRISTOPH S ROSER Defendants 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 07029419 C N Pit IAS IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff VS. L R ROSER CHRISTOPH S ROSER Defendants 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 t COMPLAINT 1. Plaintiff, CAPITAL ONE BANK (USA),NA is a corporation with offices at 15000 CAPITAL ONE DRIVE RICHMOND , VA 23238 . 2. Defendants are adult individual(s) residing at the address listed below: L R ROSER 147 FIELDSTONE DR CARLISLE, PA 17015 CHRISTOPH S ROSER 147 FIELDSTONE DR CARLISLE, PA 17015 3. Defendants applied for and received a credit card bearing the account number XXXXXXXXXXXX8717 . 4. Defendants made use of said credit card and has a current balance due of $1422.26 , as of November 18, 2008 . 5. Defendants are 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 28.1001 per annum on the unpaid balance from November 18, 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, Defendants have willfully failed and/or refused to pay the balance due to Plaintiff. Wherefore, the Plaintiff prays for judgment in its favor and against Defendants , L R ROSER AND CHRISTOPH S ROSER , JOINTLY AND SEVERALLY , in the amount of $1422.26 with continuing interest thereon at the rate of 28.1009o- per annum from November 18, 2008 plus costs. James WELTM 436 S Pitts (412) FAX• 070• This law firm is a debt collector att our client and any information obtain rodt,42524 N INBERG & REIS CO., L.P.A. t Avenue, Suite 1400 PA 15219 7955 338-7130 C N Pit IAS ping to collect this debt for ill be used for that purpose. FINANCE ow Data Previous Balance Payments rE Credits CHARGE Transactions Now Balance Minknmn Payment $879 39 - $0 00 + $20 60 * $29 00 = $928 99 $37899 Jun 07, 2007 PLEASE e>r AT FAR hat nuo x T Apr 08, 2007 - May 07, 2007 Page 1 of 1 Yha platinum Account 4121.7413-KT74717 Your Account Information TOTAL CREDIT LINE $55000 TOTAL AVAILABLE CREDIT $000 CREDIT LINE FOR CASH $55000 AVAILABLE CREDIT FOR CASH $000 Finance Charges (Plcese see reverse for umportart Information) ?epood 10 Periodic rate Ctxr APondng CKA EE rate Purchases $890.26 0 07712% D 2815% $20 60 Cash $000 0 07712% D 2815% $0 00 ANNUAL PERCENTAGE RATE appliedtts perod. 28.15% ® At Yov service 1141100-91137 To calC skim RNeaas arm nIPon a lost 0rsUW Card ® Send psymerds to. Caged One Berk P 0 Box 70084 Clwdott, NC 28272-0884 A S ices loc. CepIW pad One One P O Bat 3D2115 Sett teas dial. UT 0930-0285 Win'or I 1 7 7 070507 PAGE 1 Of 1 OlEC6056 6056 506 PLEASE RETURN PORTION BELOW WITH PAYMENT 0 4121741398778717 07 0928990050000378996 ?!^'°`Vrui.I what'slnyourwalkt? Account Number. 4121-7413-9877-8717 New Balance Minimum Payment Due Date C$928 99 $378 99 Jun 07, 2007 PLEASE PAY AT LEAST TFtS AMOUNT Amount Endosed Capital One Bank P.O. 60K 70664 Charlotte, NC 26272-0664 Your ww nt a ox payments behind I we charge off your acmurt due to Is* P%Wwft, we wA report tie chagada6 stakes to severd national crest bureaus, and the Purchase APR a won pay ? amount swill us be applied b all your outstanding balances Ad now b prevent to from happening on your sletmrt or give us a all a 1800 955.8600 Well work with you so you can lace control of your account and star rebuilding your credit wan Capital One 'Important Nokce- under to terns we prewoualy disclosed to you. your account is now skgmle for an ncrease in Annual Percentage Rats (APRs) effective i m odkslely However. Capdal one has dected not to raise Your APRs at the lime Please be advised teat r you far b keep your account in good standing, Copilot One reserves the right to race your APRs in the fukure Payments, Credits 8 Adjustments Transactions $2900 1 07 MAY PAST DUE FEE You were assessed a pest due fee because your mnmum payment was not received by the due dale. To avoid loss fee in to future, via recommend that you allow at least 7 lousiness days for your mnwnuxn payment to reach Captd One Please print address or phone number changes below using blue or black ink Address Home Phone Alternate Phone address E-mail #9012836540040395# MAIL ID NUMBER L R ROSCR CHRISTOPH S ROSER 1,47 FIELDSTONE DR CARLISLE, PA 37015-'m54 7029419 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 A . CAPITAL ONE BANK (USA), N.A., Plaintiff, V. L R ROSER 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. Darious Nelson A049 WELTMAN, WEINBERG & REIS CO., L.P.A. +i C? ? f? J w r ? ' ? f? 3 f 7? ? ?; ...? 1 w; ? ?.?? -?f"3? "?: ?._ < Sheriffs Office of Cumberland County R Thomas Kline qtr of Cumbrr Edward L Schorpp Sheriff '+ Solicitor Ronny R Anderson Jody S Smith Chief Deputy OFFICE OF T "E $HERIFF Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 03/10/2009 06:39 PM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on March 10, 2009 at 1839 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: L.R. Roser, by making known unto Jackie White, mother of defendant, at 147 Fieldstone Drive, Carlisle, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. 03/10/2009 06:39 PM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on March 10, 2009 at 1839 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Christoph S. Roser, by making known unto Jackie White person in charge, at 147 Fieldstone Drive, Carlisle, Cumberland County, Pennsylvania its contents and at the same time handing tc her personally the said true and correct copy of the same. SHERIFF COST: $48.50 (PAID) SO ANSWERS, March 14, 2009 R THOMAS KLINE, SHERIFF tySe Docket No. 2009-1221 Capital One Bank (USA), NA v L.R. Roser and. Christoph S. Roser r R4 .? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA) NA Plaintiff vs. L R ROSER CHRISTOPHER S ROSER Defendants No. 09-1221-CIVIL TERM PRAECIPE FOR SATISFACTION OF JUDGMENT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt PA I . D #42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#7029419 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA) NA Plaintiff vs. L R ROSER CHRISTOPHER S ROSER Defendants Civil Action No. 09-1221-CIVIL TERM PRAECIPE FOR SATISFACTION OF JUDGMENT At the request of the undersigned attorneys for the Plaintiff, you are directed to satisfy the above-captioned Judgment. WELTMAN, WEINBERG & REIS CO., L.P.A. rmbrodt WELT AN, EINBERG & REIS CO., L.P.A. 1400 op rs Building 436 S v nth Avenue Pitts gh, PA 15219 (412) 434-7955 By: James C PA I. D WWR #7029419 Sworn to and subscribed ' before me this day of Jup 9 NO TA PUB COMMONWEALTH OF PENNSYLVANIA Notarial Seal Jennifer M. Borowel i, Notary Publi City of PRWxn9h, Allegheny County My Commisebn Expires Feb. 22, 2012 Member, Pennsylvania Assodation of Notaries F LIE OF Tt rF 20 R9 J U ' 114 Ali H: U;li