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Home My WebLink About09-5802 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),,NA Plaintiff No: Dq _ 580a 0"Va Tem vs. COMPLAINT IN CIVIL ACTION JENNIFER R COBB 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 05975184 C N Pit. SJS IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),.NA Plaintiff vs. JENNIFER R COBB Defendant 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 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: JENNIFER R COBB 1124 THREE SQUARE HOLLOW NEWBURG, PA 17240 3. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXX7226 . 4. Defendant made use of said credit card and has a current balance due of $1848.37 , as of July 29, 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 8.900% per annum on the unpaid balance from July 29, 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 , JENNIFER R COBB , individually , in the amount of $1848.37 with continuing interest thereon at the rate of 8.9000W per annum from July 29, 2009 plus costs. James C. /vvVLrr=roat,,,4 WELTMANINBERG & REIS CO., L.P.A. 436 Sev Avenue, Suite 1400 Pittsb PA 15219 (412) 3)47955 FAX: 8-7130 05975 8 N Pit SJS This law firm is a debt collector attemptVng to collect this debt for our client and any information obtained will be used for that purpose. FREE Accelerator for the that 12 months'-a $60 rah$e 97 a month for flat 3 months; $9.XVmo. thereafter SM UP TODAY: 1-888-587-9669 Menton Offer Code: PEARL Or visit www.peoplope.com/go/pearl Account Summary Previous Baiaaee, $1,386.20 Payments, Credos and Adjustments $.00 Transactions $35.00 Finance Charges $1533 New Balance $1,43653 Minimum Amount Due $1,436.53 Payment Due Date March 04, 2006 Total Credit Line $1,000 Total Available Credit $.00 Credit Line for Cash $500 Available Credit for Cash $.00 At your service To can Customer Relation or to report a lost or stolen card: 1-800-955-7070 Sind paymau to: Sad i up=I to: Attn: R-.tt nce Processing Capihl0-Bask CapiulOne P.O. Box 790216 P.O. Box 30285 St Ink, MO 63179-0216 SLC, Ur $4130-0285 PLATINUM VISA ACCOUNT 4862-3625-0530-7226 JAN o6 - FEB 05, 2006 Page 1 of 1 Payments, Credits and Adjustments Transactions 1 05 FEB PAST DUE FEE $35.00 As a valued Capital One customer, you are eligible to receive a free Year-End Summary for this spedfrc account that recaps your 2005 charges, provided your account is in good standing and you have made tra actions during the calendar year. Please go to www.capiWone.com and access your account to request your Year-End Summary online or call 1-877-794-4487 before March 31, 2006, to reserve your copy. Orders will be mailed out by the end of April 2006. You were assessed a past due fee of $35.00 on 02/05/2006 because your minimum payment was not received by the due date of 02/04/2006. To avoid this fee in the fit re, we recommend that you allow at least 7 business days for your payment to reach Capital One. EXHIBIT F-mane Chatges a Pk" m" reverre sidefor imtertant waim farr iin - Bdawr+ayf t w + ?, y . l P C- P afp!vdm r 11 l;tlAlCl*r. R >? ro PURCHASES $875.64 n CASH $517.95 .02438% 8.9016 $6.62 .05425% 19.80% $8.71 ANNUAL PERCENTAGE RATE applied this period 12.95% PLEASE RETURN PORTION BELOW WITH PAYMENT om, 0000000 0 4862362505307226 05 1436530029001436533 Nev, Balance $1,436.53 Minimum Amount Doe-- $1,436.53 Payment Due Date March 04, 2006 Total enclosed $ Account Number. 4862-3625-0530-7226 ak?p.;ara rge?rAmdi r?tr?,?r.ser?.a;,?a? arw?ar? Sueet Apt # 07 S_ ZIP ft? #9003695935744487# MAIL ID NUMBER Capital One Bank , RRN4IBOX 4166BB P.O. Box 790216 IIII /II II IIIIIIIIIIIII St. Louis, MO 63179-0216 WYALUSING PA 18853-9511 r _ Igill II1111111IIIIIIIIIIgill 11bill 11111 IIIIIIgill II1II11111111 Pk-e vmteyom ar wt nwxh r om yon dwl or money order madepgakk ro C4aa/ 0ncBax.4 -d mail - r& a 1-ed -41p, 008 peoplepc„ online u A better way to Internet. PeoplePC Online offers all the features you would expect from higher-priced Internet Service Providers, including: ® Virus Protection Powered by Symamec- ® Pop-Up Blockert" ?j Spam Controls ® 41 Smarter Smart Dialer Technology ® zW More Emall Addresses ® % Internet Call Waiting r CAPITAL ONE BANK (USA), N.A., Plaintiff, V. JENNIFER R COBB Defendant(s). VERIFICATION The undersigned does hereby verify subject to the penalties of 18 Pa.C.S. Section 4904 relating to unswom 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/herknowledge, information and belief. Dated: Ottis Coward A049 WELTMAN, WEINBERG & REIS CO., L.P.A. ?LLI.i"'t. :sL ,4?'8.50 Po ATN cx--V 4(6"or7 gT* aagt.a5 Sheriffs Office of Cumberland County Sheriff Kline F ,l E- ? tiIV of 4111g4rr? ?t OF THIS' ???? Ronny R Anderson Chief Deputy 2009 AUU3 28 PM 12:51 Jody S Smith Civil Process Sergeant OFFICE OF T - E SrERIFF w l Edward L Schorpp Solicitor Capital One Bank (U.S.A.) N.A. vs. Case Number Jennifer R. Cobb 2009-5802 SHERIFF'S RETURN OF SERVICE 08/25/2009 06:05 PM - Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on August 25, 2009 at 1805 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Jennifer R. Cobb, by making known unto Michael Ursitz, Adult in charge at 1124 Three Square Hollow Road Newburg, Cumberland County, Pennsylvania 17240 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $46.00 August 26, 2009 SO ANSWERS, R THOMAS KLINE, SHERIFF By? ? Zl"? De ty Sheriff