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Home My WebLink About04-2268IN THE COtRT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAl. ONE B,\NK Plaintiff VS. CHRISTINE L. BI,ASS Defendant COMPLAINT 1N CIVIL ACTION FILED ON BEHALF OF Plaintiff COUNSEl. OF RECORD OF THIS PARTY: William T. Molczan, Esquire PA I.D. #47437 Gerianne Hmmibal, Esquire WELTMAN~ WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#03128069 IN THE ('()[JRT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA C1VIL DIVISION CAPITAL ONE BANK Plaintiff VS, CHRISTINE L. BI_ASS Civil Action No. ~. -~.~k~ COMPLAINT IN CIVIL ACTION AND NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claims set tbrth 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 tbrth against you. You are warned that if you tTail to do so the case may proceed withoul you and a judg,nnent may be entered against you by the court without further notice for any money claimed ii] the complaint or for any other claim or relief requested by the plaintifl~ 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 FORT}I BELOW 1'0 FIND OUT WHERE YOU CAN GET LEGAL HELP LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 COMPLAINT Plaintiff is a corporation with offices in 6851 Jericho Turnpike #190, Syosset, NY 11791. 2. Det~ndam is residing at 40 NAUGLE ROAD, SH[PPENSBURG, PA 17257. 3. Del'entire3/ applied tbr and received a credit card issued by Plaintiff bearing the account nmnber 4388641430429832. 4. Def'endant made use of said credit card and bas currently a balance due and owing to Plaintiff; as of August 23, 2003, in the mnount ors 1,745.53. 5. Defendant is in default of the terms of the cardholder Agreement having not made monthly payments to PlaintitVthereby rendering the entire balance immediately due and payable. 6. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed and/or refused to pay. WHEREFOICE, Plain'tiff demands Judgment in its IZavor m~d against Defendant, Christine L. Blass individually, in thc amount orS1,745.53 with additional interest at the legal interest rate of 6% per annum fi;om the date of judgment, phis costs. THIS IS AN ATTEMPT TO COLI,ECT A DEBT AND ANY INFORMATION OBTAINED SHALL BE USED FOR THAT PURPOSE. WELTMAN, WEINBERG & REIS, CO., L.P.A. PA I.D. #47437 Gerianne Hamfibal, Esquire WELTMAN, WE1NBERG &REIS CO., L,P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#:03128069 VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA. C.S. 4904 relating to unswom falsifications to authorities, that he/she is Melissa Lattimer (NAME) agent_ of .Capital One Bank (TITLE) (COMPANY) he/she is duly author/zed to make this verification, and that the facts set forth in the foregoing Complaint are true and correct to the best of his/her knowledge, information and belief. , plaintiffherein, that WWR# SHERIFF'S RETURN CASE NO: 2004-02268 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CAPITAL ONE BANK VS BLASS CHRISTINE L CPL. MICHAEL BARRICK , Cumberland County, Pennsylvania, says, - REGULAR Sheriff or Deputy Sheriff of who being duly sworn according to the within COMPLAINT & NOTICE was served upon BLASS CHRISTINE L DEFENDANT , at 2039:00 HOURS, at 40 NAUGLE ROAD SHIPPENSBURG, PA 17257 the law, on the 21st day of May , 2004 by handing to together with BOB BILGER, FIANCEE ADULT IN CHARGE a true and attested copy of COMPLAINT & NOTICE and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 10.35 Affidavit .00 Surcharge 10.00 38.35 Sworn and Subscribed to before me this ~& ~ day of ~ , ~J30~ A.D. So Answers: R. Thomas Kline 05/24/2004 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAP{TAL ONE BANK Plaintiff VS. CHRISTINE L. BLASS Defendant No. 04~2268 - CI PRAECIPE FOR DEFAULT JUDGMENT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan, Esquire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#03128069 Judgment Amount $1,745.53 THIS LAW FIRM IS ATTEMPTING TO COLLECT THIS DEBT FOR ITS CLIENT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff VS. CHRISTINE L. BLASS Defendant Civil Action No. 04-2268 - CI PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter Judgment against the Defendant, Christine L. Blass, above named, in the default of an Answer, in the amount of $1,745.53 computed as follows: Amount claimed in Complaint $1,745.53 Interest from date of judgment at the legal interest rate of 6% per annum Attorney's fees $ TOTAL $'1,745.53 I hereby certify that appropriate Notices of Default, as attached have been mailed in accordance with PA R.C.P. 237.1 on the dates indicated on the Notices. WELTMAN, WEINBERG & REIS CO., L.P.A. WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412 ) 434-7955 WWR#03128069 th Plaintiff's address is: cio Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7 Avenue, Pittsburgh, PA 15219 And that the last known address of the Defendant is: 40 Naugle Road, Shippensburg, PA 17257 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff VS. CHRISTINE L BLASS Defendant Civil Action No. -04-2268 Cl IMPORTANT NOTICE TO: Christine L Blass 40 Naugle Road Shippensburg, PA 17257 Date of Notice: ~_~,_~t~ YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WiTHiN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FiND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 WELTMAN, WEINBERG & REIS CO., L.P.A. By: ~ William T. Molczan ~' PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR #3128069 VERIFICATION The undersigned does hereby verify subject to the penalties of 18 Pa.C.S, Section 4904 relating to unsworn falsification to authorities, that the parties against whom Judgment is to be entered according to the Praecipe attached are not members of the Armed Forces of the United States or any other military or non-military service covered by the Soldiers and Sailors Civil Relief Act of 1940. The undersigned further states that the information is true and correct to the best of the undersigned's knowledge and belief and upon information received from others. WELTMAN, WEINBERG & REIS CO., L.P.A. Wil)iam T.M~lczan, Esa~e PA I.D, #47437 ~ WELTMAN, WEINBERG & REIS CO. L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#03128069