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Home My WebLink About09-8095% IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff No: Oq_ SOg5 elvi1TerrA vs. MAGARO DOMMINICK 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 07500566 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 MAGARO DOMMINICK 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: MAGARO DOMMINICK 29 ESSEX RD CAMP HILL, PA 17011 3. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXX9692 . 4. Defendant made use of said credit card and has a current balance due of $1330.37 , 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 24.9000 per annum on the unpaid balance from November 06, 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 , MAGARO DOMMINICK , individually , in the amount of $1330.37 with continuing interest thereon at the rate of 24.9000 per annum from November 06, 2009 plus costs. James C. ar ro t,42524 WELTMAN EINBERG & REIS CO., L.P.A. 436 Se en h Avenue, Suite 1400 Pittsb rg , PA 15219 (412) 43 -7955 FAX: 412 338-7130 0750 5 C N Pit KMJ This law firm is a debt collector attembl!?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 $867.37 ,- $0.00 :D + $18.67 + $29.00 $915.04 ( $415.04 Jul. 08, 2008 May. 14, 2008 - Jun. 13, 2008 Page 1 of 1 Yna Flatiron Account 4862M140094M Your Account Information TOTAL REVOLVING CREDIT LINE $500.00 TOTAL AVAILABLE REVOLVING CREDIT $000 CREDIT LINE FOR CASH $50000 AVAILABLE CREDIT FOR CASH $000 FnanCe Changes (Please see reverse for important Information) Balance rate Parodic Corresponding FRANCE applied to rile APR CHARGE Purchases $714.87 005822°% D 2490% $1512 Cash $167.99 0.058M D 2490% $3.55 ANNUAL PERCENTAGE RATE applied lids period: 24.90%. Q At Your Service 14008033837 To CialQb$nB Ra6tvs orb report a kst or sbtri mad ® Send paymerta to: Capital Ono 341SA),NA • P O Bw 70884 • Charbae, NC 28D2aM A Sand Inquirbs to: Ceptil Orr PD Boo 30285• Sak Lure City. In 84130M ® Have a questbn about a charge on your stateinon a Phrase refer to the Bong Rights Summary on the back of your statement or vast www.ceoitabne.oan/cisoutes KEPSE PAY AT L AA THIS AhVUW Yatre belwYd try m payments If we charge off your account due, to Iste or missed payments, fiance ch3FWs win contrsue to aoaue Ad raw to prevent this from happening Please pay the mnnnm payment amount on your statement or give us a cal at 1 BO0.955 %M We're here to he¢ Take control of your credit with catou One °Inrporhnt Notice' Urder the tennis we previously doolooed to you, your account v wN *I* for an Increase an Annual Percentage Rates (APRs) effecWe Immediately However, CSI One has elected not to rase your APRs at this time Planes be advised that if you fad to keep your account n good starding, Capdal One reserves the right b rase your APRs in the futre Payments, Credits 6 A(Sustments Transactions 1 07 JUN PAST DUE FEE $2)00 Your account is 90 days past due ant you Payment Protection coverage has been susponxiad. As stated an your Payment Protecborm agreement, your coverage and mor" charge wall be reinstated once your account is no lager 90 days past due You may std be ekgble for benefits to be paid to your account far loss events described in yam Payment Protection agreement Cal Stmcbxidge Beneff Services at 1 04 to see if your situalon qual fns for benefits Your amount has Bona wor its aecit limit To avoid addhonal mw*W fees, please pay enough to brag your balance below your aecid land unmedaty, and mdse we you remain below your aeon hnf Free be sue to accout for any future purchases, fees, and fnan ce charges You were assessed a past do fee because your narmw payment was not roomed by the due date To avoid this fee in the tAae, we recommend ttet you allow at least 7 business days for your minimum payment to reach Ctlpital One PUEASE RETURN PORTION BELOW WITH PAYMENT OR LAG ON TO WW W.CAPITALONE.COM TO MAKE YOUR PAYMENT ONLINE 11C4121WOne" what't n , wr kit New Balance Minimum Payment Due Date $915.04 C$415.04 Jul. OB, 2008 rLFASE PAY AT LRST THISAMOUNT Amount Enclosed C? 0 4862367149089692 13 0915040099000415047 Capital One Bk(USA),NA P.O. Box 70664 Charlotte, NC 26272-0664 7500566 'nits llN?hih?r??rri?Nlin?rih?hrla?iilN?rinii?ihlih??hirn Account Number- 4862-3671.4908-9692 Please pmt address or phone number dmanges below using blue or black ink Home Phone A?eir»te Phone f1m.1R1&d rrss #9016603904058660# MAIL ID NUMBER MAGARO DOMMINICK 29 ESSEX RD CAMP HILL, PA 17011-6624 III Hill 111111 It 1111111111111 fill I flail 11111 1111 1111111111 Please write your account number on your shed( or money miler made payable to Capital One Bk(USA),NA and mail with this coupon in the enclosed envelope. PROTHONOTARY CUMBERLAND CO CAPITAL ONE BANK (USA), N.A., Plaintiff, V. MAGARO DOMMINICK 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: 6M% _ LSierra Fenner A049 WELTMAN, WEINBERG & REIS CO., L.P.A. Q FILED- ?E-IC E 2009 NOV 23 6: 4 4 ?S . 5o PA RTTl 344 4163 13a9 qq