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Home My WebLink About09-8037 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff vs. LEE Y RICHWINE Defendant No: 69 -8637 C1 U i ` ? I COMPLAINT IN CIVIL ACTION 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 07425013 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 LEE Y RICHWINE 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: LEE Y RICHWINE 347 STUMPSTOWN RD MECHANICSBURG, PA 17055 3. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXX1585 . 4. Defendant made use of said credit card and has a current balance due of $1496.36 , as of October 26, 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 29.200% per annum on the unpaid balance from October 26, 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 , LEE Y RICHWINE , individually , in the amount of $1496.36 with continuing interest thereon at the rate of 29.2000 per annum from October 26, 2009 plus costs. fames u.p rmnroau,4zbz4 WELTMAN, W INBERG & REIS CO., L.P.A. 436 Sev nt Avenue, Suite 1400 Pittsb g , PA 15219 (412) 34 7955 FAX: 12 338-7130 07425 1 C N Pit KMJ This law firm is a debt collector attempliig to collect this debt for our client and any information obtained ll be used for that purpose. FINANCE Previous Balance Payments S Credits CHARGE Transactions New Balance Minimum Payment Due Date $786 48 - $0 00 + $19 93 + $29 00 $835 4 t $335 41 Sep 07, 2007 Jul 14, 2007 - Aug 13, 2007 Page 1 of 1 aLEASE MY AT I %T Ti AA40UAT Visa Platinum Account 4862.3625.8648.1585 Your Account Information TOTAL CREDIT LINE $50000 TOTAL AVAILABLE CREDIT $000 CREDIT LINE FOR CASH $50000 AVAILABLE CREDIT FOR CASH $000 Finance Charges (Please see reverse for Important information) Balance rate Periodic Corresponding FINANCE applied to rate APR CHARGE Purchases $802,56 0 08011% P 2924% $1993 Cash $000 008011%P 2924% $000 ANNUAL PERCENTAGE RATE applied this period. 29.24% Q At Your Service 1.800.903.3637 To call Custaner Relations or to report a lost or stolen card ® Send inquiries to. Capital One P 0 Box 30285 Safi Lake City, UT 84130-0285 ® Send payments to. Capital One Bank P.0 Box 708M charlotte, NC 28272-0884 M? lih 7425013 CB/?f!3/Qfq?' I what's in your wallet' Your account is six payments behind If we charge off your account due to late payments, we wll report the 6056 506 1 07 13 070813 PAGE 1 of 1 011)M6056 PLEASE RETURN PORTION BELOW WITH PAYMENT OR LOG ONTO W Ww CAPITALONE COM TO MAKE YOUR PAYMENT ONLINE 0 4862362586481585 13 0835410019850335416 charged-off status to several national credit bureaus, and the Purchase APR as reflected on this statement will be applied to all your outstandng balances Act now to prevent this from happening Please pay the amount due on your statement or give us a call at 1900 955 6600 We'll work with you so you can take control of your account and start reb0ding your credit with Capital One "Important Notice" Under the terms we previously disclosed to you, your account is now eligible for ar 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 fad to keep your account n good standing, Capital One reserves the nghl to raise your APRs n the future Pavments. Credits $ Adiustments Transactions 07 AUG PAST DUE FEE $2900 You were assessed a past due 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 react Capital One Account Number: 4862-3625-8648-1585 New Balance Minimum Payment Due Date Please pant address or phone number changes below using blue or black ink $835 41 $335 41 Sep 07, 2007 Address PLEASE PAY AT LEAST THIS AMOUNT Home Phone Attemate Phone f-mail address @ Amount Enclosed 09022602792102517# MAIL ID NUMBER LEE Y RICHWINE 347 STU11PSTOWN RD Capital One Bank MECHANICSBURG, PA 17055-9602 P.O. Box 70884 It 1n11nr1111oil Charlotte, NC 28272-0884 ?n?r??n?ur?r??nr?n?r???nr?n?r?nluln?ln?nln??rn?? Please write your account number on your check or money order made payable to Capital One Bank and mall with this coupon in the enclosed envelope PROTHONOTARY CUMBERLAND CO CAPITAL ONE BANK (USA), N.A., Plaintiff, V. LEE Y RICHWINE 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 true and correct to the best of his/her knowledge; information and belief. Dated: qJa?::l Cf=A Wandi Glover A049 WELTMAN, WEINBERG & REIS CO., L.P.A. Fl FFI? OF THE 2049 Nov 19 AM 8: 3 3 ClJ! Se "t VE.i L {.J Li Y 1 Yys. s'o-;k Al? CK-4- 4331;t'/3 jZ*- oU 'a 7p I SHERIFF'S OFFICE OF CUMBERLAND COUNTY RThomas Kline ~~it=i-% '~% `-~`~r Sheriff H ~ _ ~/ `f ~~~~.,~,•, nt ~`utrril,,~~,j~~~~ Ronny R Anderson i~~~~ ~~~., ' i ` ~i ~ 2. ~t Chief Deputy - Jody S Smith Gvlt _' _ ' ', ;y ,` Civil Process Sergeant ~F ~-` ~`~~~~ Edward L Schorpp Solicitor Capital One Bank (U.S.A.) N.A. Case Number vs. Lee Y. Richwine 2009-8037 SHERIFF'S RETURN OF SERVICE 11/23/2009 09:29 PM -Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on November 23, 2009 at 2129 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Lee Y. Richwine, by making known unto himself personally, at 347 Stumpstown Road, Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $37.00 November 25, 2009 SO ANSWERS, ~i5~r'a'K /~,I~ (c!. i.;eun?yS~Lte Sne-'f. iei~c :oft. In;; R THOMAS KLINE, SHERIFF