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Home My WebLink About09-1461 4 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff vs. PAULA A WILLIAMS Defendant No . ~q - f'f(D ~ ~V ~ ~ l P.1'M1 COMPLAINT IN CIVIL ACTION FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: V Kelly Mulholland,69978 WELTMAN, WEINBERG & REIS CO., 325 CHESTNUT STREET SUITE 501 PHILADELPHIA, PA 19106-2614 215-599-1500 FAX: 215-599-1505 07070879 C N Jer SPE L.P.A. 4 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff vs. Civil Action No PAULA A WILLIAMS 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 1. 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: PAULA A WILLIAMS 461 LEWISBERRY RD NEW CUMBERLAND, PA 17070 3. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXX4803 . 4. Defendant made use of said credit card and has a current balance due of $1115.93 as of January 14, 2009 . 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 15.600 per annum on the unpaid balance from January 14, 2009 A copy of Plaintiff's STATEMENT is attached hereto, marked 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 in its favor and against Defendant PAULA A WILLIAMS INDIVIDUALLY in the amount of $1115.93 with continuing interest thereon at the rate of 15.600 per annum from January 14, 2009 plus costs. ~ `, ~.."' _ V e y Mu o an 69978 WELTMAN, WEINBERG & REIS CO., L.P.A. 325 CHESTNUT STR T SUITE 501 PHILADELPHIA, PA 19106-2614 215-599-1500 FAX: 215-599-1505 07070879 C N Jer SPE This law firm is a debt collector attempting to collect this debt for our client and any information obtained will be used for that purpose. .~. FINANCE Prevbus Balance Paymelt~ E Cndils CHARGE Transactions New Balam:s Minimum Paymsrlt Dw, Date $788 00 - $0 00 + $12 28 + $29 00 = $829 28 $329 28 Mar 23, 2007 Jan 24, 2007 -Feb 23, 2007 Page 1 of 1 PLEASE IAY AT (FACT 1185 AM(ILx~T Vln Platptlen Atxount 362644909 Your Account Informatbn TOTAL CREDIT LINE $500 00 TOTAL AVAILABLE CREDIT $000 CREDIT LINE FOR CASK $500 00 AVAILABLE CREDIT FOR CASH $000 FBtallcaC6a[gss (Please aee rreverse for rrrpoAarlt mfarmahon) ~edt~o ~ra6ee APR g CHARGE Purcfiases 539725 0 04288% P 1565% ;528 Cash ;39760 O OS6B2% P 20 74% ;T 00 ANNUAL PERCENTAGE RATE applied ttds period. 18.51% ® At Your Service 1.6049013837 To eel Cuetorrier Rekaors or to repot a knR or s4ian eerd ® Send payments to. Captd One Boric P 0 Bac 70884 Chandra, NC 28272-0881 A Send irtquiries to. Capxel One P O Boz 30285 Sdt Lake City. UT 84130-0285 Your acmunt is slx payments behnd R we dTarye oB your acxolatt due to hle payments, we NMI report the dlarged~oN statrsb severd national aedd bureaus, and the PuMuse APR as r~etded on Sus statement tvL be appled b aN yes outslaTdng balencxs Act norr b preverd the tram tapperang Pkap pay the amount due on your statement or glue us a caN at 11100956.8800 Yde11 srork ra91 you SD you can take contrd of your accuunt and start rebuddng your credd wdh Capdal One Payments, Cta>~ts 8 Ad1utdtnents Trannactbns 1 23 FEB PAST DUE FEE 52900 Your acmuM s 90 days pad due and your Payment Prokchon caerape has bean suspended As stabd m your Payment Proteckon agreement, your coverage and mon6dy charge wrl ba reltstaled arxe your acxaxd Is no bnper 90 days past due You may ste be ehplua for hers9ls b be pad b your u;coLlM for loss events desaibed n your Paymerd Prateckon agroemstt Call Stabkvidge BeneBl Servaes a< 1.888-627404 b see d your arbrason glraf6es fa benetils You vrere assessed a past dts fee because year rtwvrtxrm payment tyres rot recarved by 918 due dab. To avdd this fee In rie future, xre recommend that you a9ow at least 7 busrtess days for yoca mmanum'paymenl b reach Capital One ••• Please Note "' Some of the ~mis of your account are changing Please read the enclosed nos6cabon ¢_ ,.:, ~~r ~~ 6056 506 1 7 23 070223 ~~' what'smyourwaaM~ PAGE 1 of 2 O1HC6056 PLEASE RETURN PORTION BELOW WITH PAYMENT 0 4862362662604803 23 0829280030000329283 Account Number. 4862-3626-6260-4803 New Balance Minimum PaymetK Dtte fete $829 28 $329 28 Mar 23, 2007 PLEASE PAY AT LEAST THIS AMOUNT AmoUM EtKIOSefI , Capital Ono Bank P.O. Box 70684 ~r~n~~~nr~n~ur~r~~ Charlotte. NC 24272-0684 u~l~~n~ul~l~~nl~n~r~~~nr~u~s~u~u~u~~a~n~n~~nr~~ Please pant address or phone camber changes bebw usrrg blue or black mk Address Home Mane Ahemate Mani Emar7 address s9D05525b21331354s MAIL ID NUnBER PAULA A YILLIAfIS 463 LEYISBERRY RD NEY CUMBERLAND, PA 1707D-2309 nr~~~ns~~~nr~us~~~uns~r~n~~r~~nF~r~ru~~nnr~~r~u 17~~7 `~ Please write your account number on your check or money order made payable to Capital One Bank and mad Wlth this coupon In the enclosed envelope ,,... PROTHONOTARY CUMBERLAND CO CAPITAL ONE BANK (USA), N.A., Plaintiff, v. PAULA A WILLIAMS 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 Co aint in Civil Action are true and correct to the best of his/her knowledge, information and b ief. t ~~ Dated: 2 (~ Edward Piotrowski A049 WELTMAN, WEINBERG & REIS CO., L.P.A. ~ ''. ~ ~ ~_: .sa ~ ~ . G ~~_.'• O f~ ~ ` ~' ~ , :~7 ~~ ~~ ~ ~ ~ r ~ ~ . !~+ a ~ ~ _ : ,;; ~.t ~~r'tn U w v 0