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Home My WebLink About09-8342IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff No: 09-? ?',Ia ) cji'j: VS. COMPLAINT IN CIVIL ACTION CORLA K DEOUDES 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 07500780 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 CORLA K DEOUDES 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: CORLA K DEOUDES 432 KARA WAY SHIPPENSBURG, PA 17257 3. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXX2914 . 4. Defendant made use of said credit card and has a current balance due of $8443.02 , 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 24.900% per annum on the unpaid balance from November 13, 2009 . A copy of Plaintiffs 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 , CORLA K DEOUDES , individually , in the amount of $8443.02 with continuing interest thereon at the rate of 24.900% per annum from November 13, 2009 plus costs. r - Jam*e Wa ro It, 42524 WELWEINBERG & REIS CO., L.P.A. 436 th Avenue, Suite 1400 Pit h, PA 15219 (41 -7955 F 338-7130 07 C N Pit KMJ This law firm is a debt collector att m ing to collect this debt for our client and any information obtain will be used for that purpose. PrWous Balance Payments IA Credits FINANCE CHARGE Traraactloru New Balance Minimum Payment Due Doke $5,984.78 - $0.00 + $128.03 + $39.00 = $8,151.81 $1,174.00 Jul. 02, 2008 May. 08, 2008 - Jun. 07, 2008 Page 1 of 1 VWa PWhain Account 4W2-M4 0X$29r4 Your Account Information TOTAL REVOLVING CREDIT LINE $5,000.00 TOTAL AVAILABLE REVOLVING CREDIT $000 CREDIT LINE FOR CASH $5,00000 AVAILABLE CREDIT FOR CASH $000 PLEASE PAY AT LFASr M5AWJW Yoke behind by sec payments Itwe charge off yar mcout the to lab or missed payments, fnance darges will continue b acaue Ad now to prevent the from happening please pay th mnrn wn payment Mout on your stalemerd or give us a call at 1 BCD 955 6600 WeYe here to tielp Take control of your crest with Capital One `Important NobW' Uhler the terns we pvvcusy dosed to you, your account ie now ehgt* for an naease in Annual Percen&e Rates (APRs) elfactre immediately Hmwer, Capital One has elected not to rasa your APRs at this trine Please be ad+eed that I you fai to keep your aCCout in good standing, Comet One reserves Ile right b rase your APRs in the future Finance Charges (Ply see reverse for nportgtt nfamatrmn) BaEncerate Periodic Correspondrg FNIANCE applied to rate APR CHARGE Purchases $4,84912 0,06822%D 2490% $102.55 Cash $0.00 0.08822% D 24.90% $000 SpeciITras $1204.85 0.05822%D 2490% $2548 ANNUAL PERGWAGE RATE applied this pertod: 24M. e AtYorrServkx 1.11BB404W To Will Cu*mer Rekaoneorb report a betor eblann aad 0 Send payments to: Rota One DOYA),M • P 0 Bac 70884 - Qeabae, NO2827MU Send WIvirles lo: Capital Orr P 0 Bxc 30285 • Sat Lace Qty, LIT 8413UM Have a question about a dv rge on yore ctaknuin Y Please refer to the Billing Rob Summary on the bed( dyour stazertnent or vsd Pamtents. Credits dr AillustInents Transactions 1 D2 M PAST DUE FEE $3900 Your axount has gore over its exact kind. To avoid add" OveriM fees, please pay enough to big your balance balm your credit imd mmedately, and make we you remain bebw your crack kind Please be sue to aocamt for any future purchases, lees, and finance charges You were assessed a past due tae because your mnrrun payment was not received by the due deb To avoid this fee in the futue, we recommend that you allow at least 7 business days for your mrramum payment to reach Capital One PF MW PLEASE RETURN PORTKfN BELOW WITH PAYMENT OR LAG ON TO VNNW.CAPITALONE.COM TO MAKE YOUR PAYMENT ONLINE 0 4862362405052914 07 6151810150001174002 ?..yi.roe??e what's m ynur walkH7" New Balance Minimum Payment Due Date C$6,151.81 $1,174.00 Jul. 02, 2008 PLEASE PAY AT LEAST THIS AMOUNT Amount Enclosed E-=. Capital One Bk(USA),NA P.O. Box 70654 Charlotte, NC 28272-0884 7500780 irr?t??,r?rrr?rurrn?nr?nn?rnn?nr?r?rn?rr?rrnrr?rn?rrnnr?? Account Number. 4862-3624-0505.2914 Please Pain address or phone number durges below using blue or Wade irk None A)" AWMre Ph" -- E'7W rddrcs p #9016026197152604# MAIL ID NUMBER CORLA K DEOUDES 432 KARA WAY SHIPPENSBURG, PA 37257-8820 Please write your aaount number on your dred( or money order made payable to Capital Dire BOSA),NAand mail with this coupon in the enclosed envelope. PROTHONOTARY CUMBERLAND CO CAPITAL ONE BANK (USA), N.A., Plaintiff, V. CORLA K DEOUDES Defendant(s). VERIFICATION The undersigned does hereby verify subject to the penalties of 18 Pa.C.S. Section 4904 relating to unworn 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 d belief. Dated: TIP\ --)M\- -- Sierra Fenner A049 WELTMAN, WEINBERG & REIS CO., L.P.A. 20a4 DEC -3 3 1 I y ;`j'L 1 5r 7?, S-p II &4' q3s ;_5qq3,7