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HomeMy WebLinkAbout09-8262J M% IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff No. Slgua- Or vs. COMPLAINT IN CIVIL ACTION DOUGLAS C DISBROW 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 07061579 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 DOUGLAS C DISBROW Defendant COMPLAINT AND NOTICE TO DEFEND You have been sued in court. If you wish to claims set forth in the following pages, you must twenty (20) days after this complaint and notice a written appearance personally or by an attorney with the court your defenses or objections to the t defend against the take action within are served, by entering and filing in writing claims set forth -gains 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: DOUGLAS C DISBROW 6 DOGWOOD DR MOUNT HOLLY SPR, PA 17065 3. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXX6946 . 4. Defendant made use of said credit card and has a current balance due of $1532.58 , 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 28.1006 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 , DOUGLAS C DISBROW , individually , in the amount of $1532.58 with continuing interest thereon at the rate of 28.100% per annum from November 06, 2009 plus costs. James War rodt,42524 WELT , WEINBERG & REIS CO., L.P.A. 436 S enth Avenue, Suite 1400 Pitt rgh, PA 15219 (412 434-7955 FAX 412-338-7130 07 579 C N Pit KMJ This law firm is a debt collector att pting to collect this debt for our client and any information obtain d will be used for that purpose. FINANCE Previous Balance Payments & Credits CHARGE Transactions New Balance Minimum Payment Due Date C1761 - $0 00 ?+ $17 25 + $29 00 = $808 18 C $308 18 Jun 150 Apr 17, 2007 - May 15, 2007 Page 1 of 1 '4 862-3625-6082-6946 ccount Information [AVAILABLE atinum Account CREDIT LINE $500 00 AVAILABLE CREDIT $0 00 T LINE FOR CASH $50000 CREDIT FOR CASH $000 FFFinanceCharges (Please see reverse for rrrportant infor mation) ce rate Period Conesmiling FINANCE lied to ratAPR CHARGE 77121 007712%D 2815% $1725 $000 0 07712% D 2815% $000 ,,AGE RATE applied this period. 28.15% i PLEASE PAY AT LEAST THK AMMiAT Your account is six payments behind If we charge off your account due to late payments, we YAP report the charged-off status to several national credit bureaus, and the Purchase APR as reflected on this statement will be applied to all your outstanding balances Act now to prevent this from happening Please pay the amount due on your statement or give us a call at 1800 955.6600 Well work with you so you can take control of your account and start rebuilding your credit with Capital One "Important Nobce'• Under the terms we previously disclosed to you, your account is now eligible for an increase in Annual Percentage Rates (APRs) effective immediately However, Capital One has elected not to raise your APRs at this bone Please be advised that if you fail to keep your account in good standing, Capital One reserves the night to raise your APRs in the future Payments, Credits & Adjustments _ Transactions 1 15 MAY PAST DUE FEE -- $2900 Q At Your Service 1.800.903.3637 To call Customer Relations or to report a b;t or stdsn card ® Send payments to. Capital One Bade P 0 Bn 70884 Charlotte, NC 28272-0684 A Send inquiries to. Capital One P.0 Box 30285 Sa8 Lake City, UT 84130-0285 6056 506 1 7 15 070515 PAGE 1 cf 1 O1BC6056 PLEASE RETURN PORTION BELOW WITH PAYMENT //?a.?p?&?. ??,"I1L:?` I what's in yourwalkR) 0 4862362560826946 15 0808180015000308186 ?°Ye??V New Balance Minimum Payment Due Date C$808 18 $308 18 Jun 15, 2007 PLEASE PAY AT LEAST THIS AMOUNT Amount Enclosed Capital One Bank P.O. Box 70684 1 L 11 A i r r I l i I Its i 11 111 Charlotte, NC 26272-06&4 11111119111 If if III III11I1111tlr101111111Rill 011111111111101911 You were assessed a past due fee because your minimum payment was not received by the due data 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: 4862-3625-6082-6946 Please print address or phone number changes below using blue or black ink Home Phone Alternate Phone E-mail address a 49013696514628487# NAIL ID NUMBER DOUGLAS C DISBROW 6 DOGWOOD DR MOUNT HOLLY SPRINGS, PA 17065-1936 7061579 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 CAPITAL ONE BANK (USA), N.A., Plaintiff, V. DOUGLAS C DISBROW Defendant(s). VERIFICATION The undersigned does hereby verify subject to the penalties of 18 Pa.C.S. Section 4904 relating to unswom 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 ?' 60 C? ICJ ---- 0 Jennifer Si pkins A049 WELTMAN, WEINBERG & REIS CO., L.P.A. 0-- 1) 1)n" r c. CUiI?%