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Home My WebLink About09-7992 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff No: vs. COMPLAINT IN CIVIL ACTION JESSE E STRAITIFF Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt,42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 175 South Third Street Ste 900 Columbus, OH 43215 (614) 801-2600 FAX: 614-801-2601 07582849 C N Gro KMJ IN TUE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff VS. Civil Action No JESSE E STRAITIFF 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: JESSE E STRAITIFF 3 BARD RD SHIPPENSBURG, PA 17257 3. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXX4107 . 4. Defendant made use of said credit card and has a current balance due of $3631.61 , as of October 13, 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 15.800% per annum on the unpaid balance from October 13, 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 , JESSE E STRAITIFF , individually , in the amount of $3631.61 with continuing interest thereon at the rate of 15.800% per annum from October 13, 2009 plus costs. James C. ro t42524 WELTMAN, INBERG & REIS CO., L.P.A. 175 Sout ird Street Ste 900 Columbu , 43215 (614) 1- 600 FAX: 6 4-8 1-2601 07582 49 N Gro KMJ This law firm is a debt collector attemp i to collect this debt for our client and any information obtained inbe used for that purpose. FINANCE Pre"6ous Balance Payments 8 Credits CHARGE Transactions New Balance MhwntRn Payment Due Dale $3,142.40 - $0.00 * $42.59 + $39.00 = $3,223.99 $671.00 Feb. 21, 2009 Dec. 28, 2008 - Jan. 27, 2009 Page 1 of 1 ^'• MatbrrCSrd Pll6man A court 5178.05>Mt36T•1107 Your Account Information TOTAL CREDIT LINE $3,500.00 TOTAL AVAILABLE CREDIT $276.01 CREDIT LINE FOR CASH $3,500.00 AVAILABLE CREDIT FOR CASH $276,01 REAM PAY AT LE451 TIaSAMDUNr Yofre behnd by m payments if we dwW off your eC.YJUrt die bDlala a massed payments, franca charges wiloontraie to aocYUe Act now b pvmt On from happening Pleese pay the mrhnrun payment armrrt on your statement or yve us a cal at 1 BOO 955 650D We're here to help Take control of your crack with Capital One Payments, Credits & Amlustinents Transactions 1 21 JAN PAST DUE FEE $38.00 FnrI1Ge ChafQeS (Fiore see eve se for 'P" h hfamatoni You were assessed a pest de fee bem your mranam pWmet was not rxerved by the de dMe To scud this fee n the Tatra, we re=mr nd that you abw at least 7 hairless days for your mnmum Ba6nce rate Parodic Carespondng FlMNCE payment b reach Capital One appla b rate APR CHARGE purchases 358081 0.04332°% L 15.81% $798 Cash $2,580.89 0.043&% L 1541% $34.00 ANMNIL PERCENTAGE RATE MOW Bit period: 15JI19: e AtYoirService -Gobgm gombmoupyarazous, or Od 1-0D0.903" b mpoR a bat or eaten cad or Wook b Onbner Retaoms ® Pay Orineatmymy or modyarPWWtb Qyfal Ore Bait (USA), NA • P 0 B. TIM- Oabtle, NC 26272-1053 Send lirgrtrtas to: capital OrsPD Buc30285•Set Ldb00,Ur8413MM ® Have a grKweon about a charge on your staremNtCf Please refer to to Burg Rgrb Summary on the beck dyour statement or vist PLEASE RETURN PORTION BELOW WITH PAYMENT OR LOG ON TO MNVW.CAPITALONE.COM TO MAKE YOUIt PAYMENT ONLINE 1 5178052683874107 27 3223990081000671007 Account Number. 5178-05268387.4107 Lend a hand Save the land Due Date New Balance Minimum Payment Amount Enclosed . . Mans your account online today- (( Feb. 21, 2009 $3,223.99 $671.00 it's fast, easy and secure. \ e Pay online anytime-no more checks, stamps or clutter PLEASE PAY AT LEAST THISAMOIINT ® Moving? Change your address online or on the hack ® Hop save the planet Go paperless #9002879464013891# sign up at www caprtalone corn JESSE E SrRAITIFF 436 E KING ST Capital One Bank (USA), N.A. SHIPPENSBURG, PA 17257-1502 P.O. Box 71883 1iI?'11111'111'I?I?I?rl?rlll"I'rllll?rl?lr?r??lll???ll?llll?l?l Charlotte, NC 26272-1063 Il????lgllrrllll?'ll'?I??Illrr??llllu??rlr???rl?rr???l??l?'?Ii? 7582849 Please rnake dtedks payable to Capital One Bank (USA), NA and mar with this coupon in the endosed envelope. PROTHONOTARY CUMBERLAND CO CAPITAL ONE BANK (USA), N.A., Plaintiff, V. JESSE E STRAITIFF 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 fore oing omplaint in Civil Action are true and his/her knowledge, infvrmati n and b 'e£ correct to the best ofqe? Dated: A049WELTMAN, WEINBERG & REIS CO., L.P.A. } c 20 36 cum r -?,YlasolLau, r7 7 cKWI tiY3s9c) A*- a,aa&ys