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Home My WebLink About09-8089IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA t Plaintiff No: 69 --'eoe? VS. GOLDA IDAN Defendant 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 07547875 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 GOLDA IDAN 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: GOLDA IDAN 3 W MAIN ST # 4 WALNUT BOTTOM, PA 17266 3. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXX7464 . 4. Defendant made use of said credit card and has a current balance due of $1372.34 , as of November 06, 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 25.1006 per annum on the unpaid balance from November 06, 2009 . A copy of Plaintiff's Statement is attached hereto, marked as Exhibit 111" 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 , GOLDA IDAN , individually , in the amount of $1372.34 with continuing interest thereon at the rate of 25.100% per annum from November 06, 2009 plus costs. James C. WarmbroUt,42524 WELTMAN, EINBERG & REIS CO., L.P.A. 436 Sev th Avenue, Suite 1400 Pittsb r h, PA 15219 (412) A-V4-795S FAX: -338-7130 0754 f885 C N Pit KMJ This law firm is a debt collector attem ing to collect this debt for our client and any information obtained will be used for that purpose. FINANCE Previous Balance Payments & Credits CHARGE Transactions New Balance Minimum Payment Due Date $720 41 - $0 00 + $16 42 + $39 00 = $775 83 $275 83 Feb 18, 2008 Dec 25, 2007 - Jan 23, 2008 Page 1 of 1 PLEA%E PAY Al LEAST i ; AMOUNT Visa Platinum Account 4862.3671.9170.7464 Your Account Information TOTAL CREDIT LINE $50000 TOTAL AVAILABLE CREDIT $000 CREDIT LINE FOR CASH $30000 AVAILABLE CREDIT FOR CASH $C 00 Finance Charges (Please see reverse for important Information) Balance rate Periodic Conesp riding FINANCE applied to rate APR CHARGE Purchases $736,04 007438%D 2715% $1642 Cash $0 DO 0 07438% D 27151/6 $000 ANNUAL PERCENTAGE RATE applied this period. 27.15% Q At Your Service 1.800.903.3637 To call Cus4xnar Relations a to report a lost or stolen card ® Sendpaymentsto. Capnal One Bank P.0 B=70894 Charlotte, NC 28272-0684 e Send inquiriesto. Capital One P 0 Box 30285 Salt Lake City, UT 84130-0285 G Have a question about a charge on your statement? Please refer to the Billing Rights Summary on the back of your statement or visit www candalon com/disoutes. You're behind by three payments That means you are temporarHy unable to make new purchases or get cash advances. But you can regain your Capital One charging privileges and bang your account back into good standing by paying the amount due on your statement. If you're having financial difficulties and you're feeling overwhelmed - we want to help, Give one of our associates a call at 1 800 955 6600 You'd be surprised what we can do together to work this out Payments Credits & Adjustments Transactions 1 18 JAN PAST DUE FEE $3900 Under terms previously disclosed to you, some or all of your Annual Percentage Rates (APRs) have been increased since your account was past due twice in the past 12 tilling cycles, If your rates have already increased, subsequent deinquenaes extended the duration of the increased rates Remember If we receive your mnimum monthly payment on time for 12 consecutive billing cycles, this account will be reviewed for a possible return to your Non-Introductory APR 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 minxrum payment to reach Capital One WIN I 6056 506 1 07 23 080123 PAGE 1 of 1 OlDM6056 PLEASE RETURN PORTION BELOW WITH PAYMENT OR LOG ONTO WWW CAPITALONE COM TO MAKE YOUR PAYMENT ONLINE Capitaii I what's in your wallet?" New Balance Minimum Payment Due Date $775 83 $275 83 Feb 18, 2008 4862367191707464 23 0775830050000275830 PLEASE PAY AT LEAST THIS AMOUNT Amount Enclosed Capital One Bank P.O. Box 70884 Ii Ii Pllli rrilrrll Pl iii Charlotte, NC 2&272-08&4 7547875 11511111111111111110111111111111 iillll llllll l?I IIIIIIII?I tllll Account Number. 4862-3671-9170-7464 Please print address or phone number changes below using blue or black ink Home Phone Alternate Phone E-mail address @ #90024424534797044 MAIL ID NUMBER GOLDA IDAN 3 U MAIN ST # 4 WALNUT BOTTOM, PA 17266-9716 Please write your account number on your check of 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. GOLDA IDAN Defendant(s). VERIFICATION The undersigned does hereby verify subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn 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: i ?`? Sierra Fenner A049 WELTMAN, WEINBERG & REIS CO., L.P.A. OS7 ED;- 2 099 N,TY 20 P t 3: 40 V`i?io? i ?rr.Ja1 rrys. sv ?1. i??a a 3Qas