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HomeMy WebLinkAbout09-8341t IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff vs. STACEY L BARRICK Defendant No : 0- 0 J / t Gtv I an 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 07731897 C N Pit KMJ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff vs. STACEY L BARRICK Defendant Civil Action No 6G7, g?3 q (? I 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: STACEY L BARRICK 602 CENTERVILLE RD NEWVILLE, PA 17241 3. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXX4721 . 4. Defendant made use of said credit card and has a current balance due of $2174.41 , as of November 13, 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 23.100% per annum on the unpaid balance from November 13, 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 , STACEY L BARRICK , individually , in the amount of $2174.41 with continuing interest thereon at the rate of 23.100% per annum from November 13, 2009 plus costs. James C. a ro t,42524 WELTMAN EINBERG & REIS CO., L.P.A. 436 Sev, n h Avenue, Suite 1400 Pittsb rg , PA 15219 (412) 3 -7955 FAX: 1 -338-7130 07731/8 9 C N Pit KMJ This law firm is a debt collector attemp ng to collect this debt for our client and any information obtained will be used for that purpose. Previous Balance Payme+tls 8 Credits C AR GE Transactions Nm Balance minimum Payment C$1,699.88D - $0.00 + $32.79 * $39.00 = $1,771.67 $445.00 Jan. 13, 2DD9 - Feb. 11, 2009 Page 1 of 1 REASE PAY AT LFA rMAMOUNT Nla6tKQW Phdnurn Account 5fl845244422AT21 Your Account Informiation REWARDS TOTAL CREDIT LINE $2,00000 TOTAL AVAILABLE CREDIT $228.33 CREDIT LINE FOR CASH $2 000.00 AVAILABLE CREDIT FOR CASH $22833 Due Date Mar. 09, 2009 You're behnd try m payments If we chard off your aownt due to kte or mmsaed payments, fiance charges will contrm to aoaue Ad now to prevent this from happening Please pay the nuns un payment amount on your sldement or gave us a cd at 1 87D 955 M We're here to help Tahn control of you credt with Capital One °Importart Nctme Under to terms we prevousy dscWW to you, your aacomt is now eigtce for an increase in Annual Percentage Rates (APRs) eftli a rnmeddely However, Capital One has elected not m raw your APRs at this time Ptewe be adored the tyou fit tD keep yoir account n good standing, Capital Ore reserves the right b rase your APRs in the tut re Inane Charges (Please see reverse for mportant in mhation) Rewards Surnmaly Beane rate Paodc Correspon6 g FINANCE orevnus akatabb balsnoe 2,815 applied io rule APR CHARGE Earned to peroi 0 Purchases $1,72341 O.OM42%D 2315% 93279 "Fact hn-bae posted dare tis sing rycb) Cash $0.00 0.0634276 D 2315% $O.OD Available Balance 2,815 AN4UAL PERCENTAGE RATE hlpplled fhk pufod: Z3,157G 7731897 Q At Your servke - Go b orb manage your scout, Payments Credits di A4ustments or Wt 1.800.4033E17 b repcrt a bst or shin cad or span to Didwer Rawo$ Transactions Aliak Pry Orindwmiyawei1xe.WmormalymrpWrimmD: 1 06FEB PAST DUE FEE S39X Capital Ore Be* (USA), NA • P 0 B. T1083. Oabl@, NC You were assessed a pest due fee because yoy mrarun payment was act received by the due date To 2892.1083 a ord this fee in the fibre, we recommend that you allow at last 7 business days for your minimum ® Saud IrRA to: payment breach Capital One CptalOro-PD 9x 30281• Sat L" Cry, UT 84130-M Ift Manage your Rewrite atone by vsi or cat 1A00.2ffi. I ® Have agnWonaboutadwWonyourWtemart? Please refer to the Bung Rob Summary on the beck dyour statement or YeA PLEASE RETURN PORnON BELOW WITH PAYMENT OR TAG ON TO WAMrA ITALDNEiCOM TO MAKE YOUR PAYMENT ONLINE 1 5178052414224721 11 1771670050000445007 ?' Cwifa Tze Account Number.5178-052411422721 Lend a hand. Save the land. Due Date New Balance Minimum Payment Amount Enclosed Manage your account online today- it's fast, easy and secure. Mar. 09, 2009 $1,771.67 $445.00 C:?D Pay online anytime-no more checks, stamps or duffer 10 PLEASE PAY AT LEAST THISAMOUNf © Moving? Change your address online or on the back 0 Help save the planet Co paperless #9004318824288222# 0 Sign up at www capitalone com STACEY L BARRICK 602 CENTERVILLE RD Capital One Bank (USA), N. A. NEYVILLE, PA 17241-9501 P.O. Box 71063 Charlotte, NC 26272-1063 "??1?'1"I'I??'ll??'11??'l?llll'?I?IIII'?'?I?I?II?I?nlllllll?ll Il????lrlllallll?'II'?I??Illrr??llllrr??rlr???rl?n???l??l?'?II? Please make CtwW payable to Capital One Bank (1.150, NA and mail with this wupon in the enclosed envelope. PROTHONOTARY CUMBERLAND CO CAPITAL ONE BANK (USA), N.A., Plaintiff, V. STACEY L BARRICK 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: ? 1 Siena Fenner A049 WELTMAN, WEINBERG & REIS CO., L.P.A. T'r ZQG? OEC -3ir?"tl S. pd `#y ega3gg34 WELTMAN, M'EINBERG & REIS CO., L.P.A. BY: Sarah E. Ehasz, Esquire Attorney for Pll"09 2 9 # I.D. No.86469 CUMBERLAND COUNT' 436 Seventh Avenue, Suite 1400 Pittsburgh, PA :5219 PENNSYLVANIA Phone: 412.434.7955 Fax: 412.434.7959 File # 7731397 CAPITAL ONE BANK (USA) NA vs. STACEY i. BARRICK CUMBERLAND County Court of Common Pleas NO. 09-8341-CIVIL PRAECIPE FOR SATISFACTION OF JUDGMENT TO THE PROTHONOTARY: Please kindly Satisfy the Judgment of the above-captioned matter upon the records of the Court and ,,lark the cost paid. By S,vorn to and subscribed Before me the 25 day of August, 2011 AOTAR PUBLIC 13 4' E& T_#-QF KNNSYLVANIA Notafial5"l ,ew 6 9@va i, Notary Public Allegheny County y i tiiws9itin Uee Nov. 15, 2014 vriaF?L Pwn eve IA ON OF NOTARIES WELTMAN, WEINBERG & REIS CO., L.P itlf Sarah E. Ehasz, Esquire Attorney for Plaintiff oavi % %"D p°1 aNt? ?- W ab3a19