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Home My WebLink About09-8347 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff No: y, TS q 7 vs MEGAN S ZIMMERMAN 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 07436320 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 MEGAN S ZIMMERMAN 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 1 . 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: MEGAN S ZIMMERMAN 149 N EAST ST CARLISLE, PA 17013 3. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXX3175 . 4. Defendant made use of said credit card and has a current balance due of $1663.32 , 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 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 , MEGAN S ZIMMERMAN , individually , in the amount of $1663.32 with continuing interest thereon at the rate of 24.9000 per annum from November 13, 2009 plus costs. fames warmbrodt,42524 WELT W ELT & REIS CO., L.P.A. 436 v nth Avenue, Suite 1400 Pitt b gh, PA 15219 (41 34-7955 FAX 2-338-7130 07 20 C N Pit KMJ This law firm is a debt collector att ting to collect this debt for our client and any information obtai will be used for that purpose. FINANCE Prevails Elalance PaynnaNs ti Credits CHARGE Transactions New Balance Minimum Payment Due Date C$1,013.58 - $80.34 :) + $19.84 + $39.00 = $992.08 $112.00 Jul. 21, 2008 May. 27, 2008 - Jun. 25, 2008 Page 1 of 1 Visa Platinum Account 4BI236/1.71I4317S Your Account Inficnim on TOTAL REVOLVING CREDIT LINE $800.00 TOTAL AVAILABLE REVOLVING CREDIT $000 CREDIT LINE FOR CASH $80000 AVAILABLE CREDIT FOR CASH $000 FnanCE Chai (Please sea reverse for important information) Ba6mce rate Penodic Caratipo red g FINANCE applied to rate APR CHARGE Purchases 5942 006822%D 24.90'% $1984 Cash 50.00 0.06822% D 24.90% $0.00 ANNUAL PFRC91fAGE RATE appYed Ws period: 24.90%. e AtYowftrvior 149040.3/37 To cal QaF'rnar ReWrs orb repot a Est a s? cad Send payreeris lo: CeorTal Ore BIQl15A),NA • P 0 Bola 70884 • , IJC 28272-0884 Send kqutbe to. GWW Orr P D Bkk 30286 • Sid Lel® Oly, lR 841340'186 ® Have a queslbn about a charge an yaw staftnert7 Please rater to tuna Blkg Rg1MS Summary m tie track of yar statement a vst www.wipbbne uWdsoutes NEAsE FAY Ar LEAsr mks A xjw Yahe beW by tree payments But you can brag you aunt crrert by pWM the mra num payment amount on your sislament. Iyo0e having financed dffrallies and yorde feeling oveNtrebed - we went to rep Ci+e one of our associates a cal at 1 HM 955 66DO Yodd be surprised whet we can do togeter to work the out Payments, Credits dr Atfiustments 1 03 JUN OL Fee Refired S78.n 2 03 JUN France Charge Refund S2,34- Transactions 3 2D AJ I PAST DUE FEE 530.00 Urdar terms previously disclosed to you, some ix all of your Annual Percentage Rates (APRs) have been increased since your a coo was past die twice in the past 12 bl i g cyder ffyour rates have ateady increased, snbeegnat daiglenaes extended the drffion d the n xeased rates Rement:w If we receive your minimum monthly payment on tim for 12 cormeative tailing cycles, to account will be revie-wed for a possble return to your No -Iniodxtay APR, You account has gone over t9 as* limit To avoid addip?el ovarknat fees, please pay 6'gOgh to bring your balance baba your aedlt land immediately, arid make sue you remain belay you as* knit Please be sue to account for any future purchases, fees, and (name cages You were assessed a past die fee boom= your maarrrm payment was not reumved by the due date To avoid this fee in the fiLae, we recommend that you allow at let 7 b wjm days for your minimum payment to reach Caprlel One PLEASE RETURN PORTION BELOW WITH PAYMENT OR LOG ON TO W W W.CAPITALONE.COM TO MAKE YOUR PAYMENT ONLINE C?IpIfalQf?" what's rn your waIIM?' New Balance Minimum Payment Due Date C$992.08 $112.00 :D Jul. 21, 2008 PLEASE PAY AT LFAST THISAMOUNT Amount Endosed C= 0 4862367178843175 25 0992080045040112000 Capital One Bk(USA),NA ?n?rr?rr?r???rrrrr??r? P.O. Box 70864 Charlotte, NC 28272-0884 7436320 irririirrirrrilurrrirrirnirrrir,irir,inrirrurrirrirru,rrn Account Number. 4862-3671-7884-3175 Please print address or phone number dwrges below using blue or black it Ad&w Home Aar" Akerreeu Aar" £,msd eddies Q !19017818229418816# MAIL ID NUMBER MEGAN S ZIMMERMAN 32 TOWNHOUSE HERSHEY, PA 17033-2317 Please write your amount number on your Idled( or money order made payable to Capital One Bk(US&NA and mail with this coupon in the enclosed envelope. PROTHONOTARY CUMBERLAND CO CAPITAL ONE BANK (USA), N.A., Plaintiff, V. MEGAN S ZIMMERMAN 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: Sierra Fenner A049 WELTMAN, WEINBERG & REIS CO., L.P.A. ?S 1 ? 7 Fr 5? p? ?/3 5--y7 6