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Home My WebLink About09-8097a IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff No: 8a47 OVS. COMPLAINT IN CIVIL ACTION ANN M CLIFFORD 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 07397862 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 ANN M CLIFFORD 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: ANN M CLIFFORD 15 HOGESTOWN RD MECHANICSBURG, PA 17050 3. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXX8342 . 4. Defendant made use of said credit card and has a current balance due of $1455.93 , 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 15.600. 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 , ANN M CLIFFORD , individually , in the amount of $1455.93 with continuing interest thereon at the rate of 15.600% per annum from November 06, 2009 plus costs. namVclr armnroat, 42524 WELEINBE RG & REIS CO., L.P.A. 436 h Avenue, Suite 1400 Pit, PA 15219 (417955 FAX38-7130 073 N Pit KMJ This law firm is a debt collector atteTAI!?ting 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 C$1,107.94 - $0.00 + $14.84 + $39.00 = $1,161.78 $198.00 OCt. 25, 2008 Aug. 26, 2008 - Sep. 25, 2008 Page 1 of 1 Mnll er and PladmNn Account 51711-0S7=1111118i41 Your Acoount Information TOTAL CREDIT LINE $75000 TOTAL AVAILABLE CREDIT $0.00 GREDIT LINE FOR CASH $300.00 AVAILABLE CREDIT FOR CASH $0.00 You're behind by sR payments If we charge of your account due to Lute or mid payments, km charges will contnu a to amru Ad rrnv to prevent this from happening Please pay the minimum pa)mr_nt amount on your statement or We us a cal at 1 600 955 65M We're here to h* Take control of your credit with Capital One Payments, Credits & A ustments Transactions 1 25 SEP' PAST DUE FEE $3900 -11 Frialtee Charges (Please sae averse for important mfomation) Yam account has gore over ft oath limit To and add" overlent fees, Please pay enough to burg your balance below your credit limit immediately, and make sure you remain below your aedl Lund Bahncs rate Periodic Corresponding FINANCE Please be sure to account for any fume purchases, fees, and finance charges wphw to race APR CHARGE You were assessed a past due fee because your mnmrm payment was not rammed by the Is date To Purchases 51,116.35 004288% Fl 15.65% 514.84 avoid this fee n the future, we recommend that you allow at least 7 business days for your minmum cash 50.00 0.04580% P 1674% SOX payment b rah Gapdai One ANNUAL PERCENTAGE RATE applied tMs period: 1&65% Q At YourServke-GbbY*wxwbbwxmbmargayour wwut, a cat 140119033637 b report a bsi or d 3hn cad or speck to c,sbner Rebiars ® PayOraneatwnw.ceoimbnraoomormaryupaym•ato: Capital One Be* (USA). NA - P 0 Bak TOB84 - Gubae, NC 26272-0884 A Scud NquNes to: Capital Onr P 0. Bak 302%- Set Lah• Cky, Ur 84130 M I? Han a question abort a charge on yew swemertt Please refer to the Boling Rights Summary on the heck d your statement or visit www.candalomoorritdisouto • PLEASE RETURN PORTION BELOW WITH PAYMENT OR LOG ON TO WWW.CAPITALONE.COM TO MAKE YOUR PAYMENT ONLINE ale° whar,,nyour v.-IkW" 0 5178057281888342 25 1161780030000198006 New Balance Minimum Payment Due Date C$1,161.78 $198.00 Oct. 25, 2008 PLEASE PAY AT LEW THISAMOINtT Amount Endosed E? Capital One Bank (USA), N.A. P.O. Box 70664 Charlotte, NC 26272-0664 7397862 1i11Puul,hIlllhlllltPlhlllhlliulllldIuPluthtl Account Number. 517"572-8188-9342 Please print address or phone number dartges below using blue or bladk ink Addiers Home Phone ARemutc P71" E-maAad&esr a #9027089991652960# MAIL ID NUMBER ANN M CLIFFORD 15 14 0 ESTOWN RD MECHANICSBURG, PA 17050-3163 II""IllllaIll'Illlillllalal'PI'll'P 111111IrI'111'1111l'1• Please write your aaount number on your payment made payable to Capital One Bank (USA), NA and mail with this coupon in the enclosed envelope. w PROTHONOTARY CUMBERLAND CO CAPITAL ONE BANK (USA), N.A., Plaintiff, V. ANN M CLIFFORD 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: *?N Sierra Fenner A049 WELTMAN, WEINBERG & REIS CO., L.P.A. 0 R LED- c 1--F I.w OF THE F O1-i("NOTARY 2009 NOV 23 AM S: 4 7 8 . ?o Pp A7r( c?,? ??35a W+ aa3a4(o