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Home My WebLink About09-2754 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff No: C'9 ? IUt, vs RANDALL L MEAGHER COMPLAINT IN CIVIL ACTION 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 07160091 C N Pit CFR IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff VS. Civil Action No RANDALL L MEAGHER 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: RANDALL L MEAGHER 229 WALTON ST LEMOYNE, PA 17043 3. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXX6689 . 4. Defendant made use of said credit card and has a current balance due of $2311.64 , as of March 19, 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 28.100% per annum on the unpaid balance from March 19, 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 , RANDALL L MEAGHER , INDIVIDUALLY , in the amount of $2311.64 with continuing interest thereon at the rate of 28.100 per annum from March 19, 2009 plus costs. WELTMAN WEINBERG & REIS CO., L.P.A. 436 Se th Avenue, Suite 1400 Pitts r h, PA 15219 (412 4 -7955 FAX 4 -338-7130 07 0 1 C N Pit CFR 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. ez?isir _ f FINANCE Previous Balance Payments 8 Credits CHARGE Transactions Now Balance Minimum Payment Due Date $1,451 44 - $0 00 + $33 99 + $39 00 $1,524 43 $524 43 Aug 20, 2007 Jun 20, 2007 - Jul 19, 2007 Page 1 of 1 PLEASE PAY AT (FAST THIS AMniIKT MasterCard Platinum Account 517&0528.8988.8689 Your Account Information TOTAL CREDIT LINE $1,00000 TOTAL AVAILABLE CREDIT $000 CREDIT LINE FOR CASH $1,00000 AVAILABLE CREDIT FOR CASH $0 00 Finance Charges (Please see reverse for important information) Balance to Pirate Comesporiding CHARGE Purchases $1,46908 0077`12%D 2815% $3399 Cash $000 007712%D 2815% $000 ANNUAL PERCENTAGE RATE applied this period. 28.15% Q4 At Your Service 1400.903-3637 To cal Customer Relations orto report a lost or stolen card ® Send payments to. Capital Ore Bank P 0 Boc 70884 Chadolte, NC 28272-0884 A Send inquiries to. Capital One PO Box 30285 Salt Lake City, UT 84130-0285 Your account is six payments behind If we charge oft your account due to late payments, we will report the charged-off status to several national credit bureaus, and the Purchase APR as reflected on this statement will be applied to all your outstanding balances Act now to prevent this from happening Please pay the amount due on your statement or give us a call at 1 800 955.6600 Well work with you so you can take Control of your account and start rebuilding your credit with Capital One "Important Notice" Under the terms we previously disclosed to you, your account is now eligible for an increase in Annual Percentage Rates (APRs) effective immediately However, Capital One has elected not to raise your APRs at this time Please be advised that if you fat to keep your account in good standing, Capital One reserves the right to raise your APRs in the future Payments, Credits & Adjustments Transactions 1 19 JUL PAST DUE FEE $3900 You were assessed a past die fee because your minimum payment was not received by the due date, To avoid this fee in the future, we recommend that you allow at least 7 business days for your minimum payment to reach Capital One 6056 506 1 07 19 070719 PAGE 1 of 1 OlDM6056 PLEASE RETURN PORTION BELOW WITH PAYMENT OR LOG ONTO WWW CAPITALONE COM TO MAKE YOUR PAYMENT ON LINE ?.?aa,???1,,.? 0 5178052669866689 19 1524430100000524439 "oe?•?Vrl("' what'smyourwallelT Account Number. 5178-0526-6986-6689 New Balance Minimum Payment Due Date C$1,524 43 C:$524 43 Aug 20, 2007 PLEASE PAY AT LEAST THIS AMOUNT Amount Enclosed Capital One Bank P.O. Box 70884 ?r?rr?rr?r?rsjjsrr?r?? Charlotte, NC 26272-0664 Please print address or phone number changes below using blue or black ink Hone Phone Alternate Phone E-rwll address #9020122270228744# MAIL ID ig? NUMBER RANDALL L MEAGHER 224 WALTON ST LEMOYNE, PA 17043-2025 60091 Please write your account number on your check or money order made payable to Capital One Bank and mail with this coupon in the enclosed envelope PROTHONOTARY CUMBERLAND CO CAPITAL ONE BANK (USA), N.A., Plaintiff, V. RANDALL L MEAGHER 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 Complai n Civil Action are true and correct to the best of his/her knowledge, information and belief. Dated: 2 Z 1b P?Edward Piotrowski A049 WELTMAN, WEINBERG & REIS CO., L.P.A. (:i) 2C ?? i aAy I 7T 4le - C-6 ?U- lo 1 Sheriffs Office of Cumberland County R Thomas Kline ptr of CutnbCr?? Edward L Schorpp Sheriff Solicitor Ronny R Anderson Jody S Smith Chief Deputy OFCCE "-r a"atiFF Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 05/05/2009 05:57 PM - Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on May 5, 2009 at 1757 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Randall L. Meagher, by making known unto himself personally, defendant at 229 Walton Street Lemoyne, Cumberland County, Pennsylvania 17043 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $42.40 May 06, 2009 2009-2754 Capital One Bank, NA CIS Randall L. Meagher SO ANSWERS, R THOMAS KLINE, SHERIFF By A Deputy Sheriff c- ° o A •ry -D rT7 ` j J co