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Home My WebLink About09-8090 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA ?p j? Plaintiff No: oQ 7 '-gv[v vs. BRENDA SABOFF COMPLAINT IN CIVIL ACTION 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 07698052 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 BRENDA SABOFF 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: BRENDA SABOFF 631 WALTON ST LEMOYNE, PA 17043 3. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXX9320 . 4. Defendant made use of said credit card and has a current balance due of $11437.54 , 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 24.400% 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 , BRENDA SABOFF , individually , in the amount of $11437.54 with continuing interest thereon at the rate of 24.400% per annum from November 06, 2009 plus costs. James C. WELTMAN, 436 Sev Pittsb (412) 3 FAX: 2 07698 5? W rmnroau,42524 W INBERG & REIS CO., L.P.A. t Avenue, Suite 1400 PA 15219 -7955 338-7130 C N Pit KMJ This law firm is a debt collector attempting 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 $8,475.45 - $0.00 + ( $181.27 + $39.00 = $8,695.72 $1,461.00 Aug. 02, 2008 - Sep. 01, 2008 Page 1 of 1 PLEASE PAY AT LEA Sr TMS M1DUM Due Date Sep. 26, 2008 Visa Platinum Account 430642258955320 Your Account Information TOTAL CREDIT LINE TOTAL AVAILABLE CREDIT CREDIT LINE FOR GASH AVAILABLE CREDIT FOR CASH Yo(f•e behind by five payments We've per:uanenRy revoked you charging privileges If you continue to miss payments your account is at risk of being charged off Plea don't Let this happen If you're f-brig overwhelmed, at us at 1 &70 955 6?00 Wei work with you to res'oln_ this matter °Imoa tant Notice Under the terms we previously disclosed to you, your account s new *ble- for an increase in Annual Percent Rates (APRs) effective Immediately However, Capital One has elected rot to ram your APRs at this time Please be advised that if yew fail to keep Your account in good standing, Capital One reserves the right to raise your APRs in tie future inane Charges (Please see reverse for important information) Balance rate Periodic Correspondrg FINANCE applied to rate APR CHARGE Purchases S7,35332 0.06822°/. D 2490% 515672 Cash S1,M.23 OC 622%D 2490% 575,5.55 ANNUAL PERCENTAGE RATE applied this period: 24.90°/6 d2h At Your Service - Go lo wnw.caoitabre.com to mange you amount, = or CA t800.95.5,707J to report a lost or sb)6, cad or speck to Customer Rebtons 0 Pay OnYne et www.cwtalxo n or coal yar payment b: capital one Bank (USA), NA • P 0 Bar 70884 • Qabtb, NC 28272-0884 Send Inquiries to: Capital Ore- P 0 Bois 3025 • Sat Lake City, UT 84130-YM Q Have a question about a charge on your statement? Please refer tote Billing Rights Summary on the beck of your statement a visit wv w.caoitalone oom/dr»utes PLEASE RETURN PORTION BELOW WITH PAYMENT OR LOG ON TO WWW.CAPITALONE.COM TO MAKE YOUR PAYMENT ONLINE 0 4305722589559320 01 369572030DO014-61003 New Balance Minimum Payment Due Date $8,695.72 $1,461.00 Sep. 26, 2008 PLEASE PAY AT L EW THISAMOUNT Amount Enclosed CaIpffa/Ot1e nor s r ?r »Ti?r Payments, Credits & Adjustments Transactions 1 26AUG PAST DUE FEE 53900 Your account has gone aver ids credit limit To avoid additional overlemt fees, please pay enough to trig your balance below your credit limit immedaley, and make sure you remain below your credit limit Please be sue to account fa arty future purchases, fees, and finance charges You were assessed a past due fee beause 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 twress days for your minimum payment to reach Capital One Account Number. 4305-7225-8955-9320 Please print address or phone number changes below using blue or black ink Add? Home Thom Aftercare Krone f-maffaddrecr #90246899467447714 MAIL ID NUMBER BRENDA SABOFF 631 WALTON ST LEMOYNE, PA 17043-2033 Irllr.Illnllplr,Iglllrrrp,I,rgll.^Il?minllrrl°Irlppq Capital One Bank (USA), N•A- P•O. Box 70664 Charlotte, NC 26272-0864 7698052 I'IlPnntrlrllhlrllll?Plhlllhnlnlllhd?lrulllrutlrq Please write your account number on your payment made payable to Capital One Bank (USA), NA. and mail with this coupon in the enclosed envelope. PROTHONOTARY CUMBERLAND CO CAPITAL ONE BANK (USA), N.A., Plaintiff, V. BRENDA SABOFF 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: \kv-111 &ym?? Sierra Fenner A049 WELTMAN, WEINBERG & REIS CO., L.P.A. OS Fiji r'-C'17,".U ..`, C,- Ti.it,,inFA RY 2009 NiO 20 Pry 3 38 Tv x`78.50 ?IiL 449 CK'd 'v-3w3S6 R-'4' a3.? `j3,3 SHERIFF'S OFFICE OF CUMBERLAND COUNTY R Thomas Kline Sheriff Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor u~ti~~til,, vt ~a+iat;~~.~~~d Capital One Bank (U.S.A.) N.A. vs. Brenda Saboff Case Number 2009-8090 SHERIFF'S RETURN OF SERVICE 11/24/2009 08:09 PM -Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on November 24, 2009 at 2009 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Brenda Saboff, by making known unto Bonnie Saboff, mother of defendant at 631 Walton Street, Lemoyne, Cumberland County, Pennsylvania 17043 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $42.40 SO ANSWERS, November 25, 2009 ~t THOMAS KLII~`~SHERIFF gY Sh ~dc, _ , •~ ~~I. Ec. ! 1 n2 l2.03 ~~ Co~.c ire SeE f. Tec~a`a. inc.