HomeMy WebLinkAbout09-4004y
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK (USA),NA
Plaintiff No: ?io / 9w
vs.
COMPLAINT IN CIVIL ACTION
RANDALL E ALLEMAN
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
07265005 C N Pit KMJ
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK (USA),NA
Plaintiff
VS. Civil Action No
RANDALL E ALLEMAN
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 E ALLEMAN
191 CHAMBERLIN RD
SHIPPENSBURG, PA 17257
3. Defendant applied for and received a credit card bearing the
account number XXXXXXXXXXXX6674 .
4. Defendant made use of said credit card and has a current balance
due of $2746.09 , as of May 01, 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
24.900% per annum on the unpaid balance from May 01, 2009 . A copy of
Plaintiff's STATEMENT OF ACCO UNT 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 E ALLEMAN , INDIVIDUALLY , in the amount
of $2746.09 with continuing interest thereon at the rate of 24.900%
per annum from May 01, 2009 plus costs.
James Wa ro t,42524
WEL WEINBERG & REIS CO., L.P.A.
436 a enth Avenue, Suite 1400
Pit rgh, PA 15219
(41 ) 434-7955
F 412-338-7130
07 5005 C N Pit KMJ
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.
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7265005
PROTHONOTARY CUMBERLAND CO
CAPITAL ONE BANK (USA), N.A.,
Plaintiff,
V.
RANDALL E ALLEMAN
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 tnie and
correct to the best of his/her knowledge, information and belief.
Dated:
Ottis Coward
A049
WELTMAN, WEINBERG & REIS CO., L.P.A.
OF TRLF
I,1", v I r- 2009 gtj 15 P .,'l 1* 35
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S,
Sheriffs Office of Cumberland County
R Thomas Kline tia of L?r?ro6rrf Edward L Schorpp
Sheriff Solicitor
iE=r ? ?J w r?
Ronny R Anderson Jody S Smith
Chief Deputy MiC6 nF E ISHERIFF Civil Process Sergeant
Capital One Bank (U.S.A.) N.A.
vs.
Randall E. Alleman
Case Number
2009-4004
SHERIFF'S RETURN OF SERVICE
06/18/2009 05:35 PM - Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on June 18,
2009 at 1735 hours, he served a true copy of the within Complaint and Notice, upon the within named
defendant, to wit: Randall E. Alleman, by making known unto himself personally, defendant at 191
Chamberlin Road Shippensburg, Cumberland County, Pennsylvania 17257 its contents and at the same
time handing to him personally the said true and correct copy of the same.
SHERIFF COST: $46.00
June 19, 2009
SO ANSWERS,
R THOMAS KLIN'E, SHERIFF
De uty Sheri f
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