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Home My WebLink About09-8711IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff VS. LISA BILLMAN Defendant No: 0 - 8111 a-, vi l -Fe rm 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 07492672 C N Pit KMJ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff vs. LISA BILLMAN Defendant Civil Action No 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: LISA BILLMAN 456 STATE ST ENOLA, PA 17025 3. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXX3329 . 4. Defendant made use of said credit card and has a current balance due of $1400.93 , 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 24.400% 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/oz- refused to pay the balance due to Plaintiff. Wherefore, the Plaintiff prays for judgment in its favor and against Defendant , LISA BILLMAN , individually , in the amount of $1400.93 with continuing interest thereon at the rate of 24.400% per annum from November 13,. 2009 plus costs. James u. WELTMAN, 436 Sev Pittsb (412) FAX: 4 07492 This law firm is a debt collector attempt our client and any information obtained w Ymbrodt,42524 INBERG & REIS CO., L.P.A. Avenue, Suite 1400 PA 15219 955 8-7130 N Pit KMJ to collect this debt for be used for that purpose. FINANCE previous Balance Payn Rls 8 Credds CHARGE Ttansactiorm New Balance Minimlan payment Due Dale F$649.81 $0.00 + $14.04 + $84.95 = $748.80 $248.80 Jul. 16, 2008 May. 22, 2008 - Jun. 21, 2008 Page 1 of 1 Yisa ftlin m Account 411111124911-113Z= Your Account Information TOTAL REVOLVING CREDIT LINE $500. TOTAL AVAILABLE J REVOLVING CREDIT $0 CREDIT LINE FOR CASH $500 OO AVAILABLE CREDIT FOR CASH $0Fase see reverse for Important information) ate Periodic C orespondrg FRANCE to rate APR CHARGE .06 005822%D 2490°% S1404 00 0061f2P%D 2490% $0.00 RATE applied tits period: 2487% Q AtYotrServke 14BB?B00363T To cd cue r. Rears orb report a lator sbei cad ® Send payinere to: Captel One B Vm),m • P D Bar 70BM • L7hatae, NC 2877'2 884 A Send hrqukdec to: Capital ores P D am 3M - Set Lale City. Uf 8413D07B6 ® Have a question about a charge on your st bOmil? Please refer to the Biting; ROO Summary on the back of your statement or vet www caoilabne oom/dsputes nEASE PAY ATL9 TM5 AWUW Yo to behi d by two payments Left tale If yayre havug fi a vaal dt6cultes and can't make your mmmurn payment - we want to help Lars work together to find a solubw Payments Credits 8 Adjustments Transactions 1 16 JUN PAST DUE FEE 2 21 JUN PAYIADIT PROTECTION IMB-527a04 $6.95 3 21 JIRJ OVERUMIT FEE &N 21, 2008 539.00 Under tams previously disclosed to you, sane of all of your Annual Peacwtage Rates (APRs) have been increased sine your amount was past die twice n the post 12 bdkg cycles If your rates have alwo( Increased, srbse4>ent defrgienaes extended the duabon Df the increased rates Remember If we receive your minimum monthly payment on time for 12 conseoutAre tiling cycles, this account will be renewed for a possible return to your Non-Introdclary APR. You account has gore over Its credit limn. To avad additional overtrrat fees, please pay enough to bring your balance below your credit Imd immediately, and mace sue you remain below you =4 timt Please be sure to account for any future purchases, fees, and fir ence charges You are a valued Payment Protection customer and may be elgble for berefits to be paid to your account par to team of your Payment Protection agreement. If you have experienced an do* bes event, please call Storebrrdle Benefit Services ad 1-888.527.OM4 to see If your stuabon qualifies for barrels You account is 60 days past dire ad you coverag-- will be sugxn w 9 t reaches 90 days past de, as stated in your Payment Protection agreement. You were assessed a pest de fee because yaw mrrwnun payment was rut reamed by the due date To a.,ad this fee in the future, we recommend that you albw at least 7 business days for your mrimum payment to reach Capilail One EXHIBIT PLEASE RETURN PORTION BELOW WITH PAYMENT OR LOG ONTO MMIW.CAPITALONE)COM TO MAKE YOUR PAYMENT ONLINE ?? what's in your wallM7" 0 4862367113123329 21 0748800057570248809 New Balance Minimum Paymelrt Due Date $748,80 $248.80 Jul. 16, 2008 PLEASE PAY AT LEAST THISAMOUNT Amount Endosed C= Capital One Bk(USA),NA ?u?nr?utu???u?tr?rr?t? P.O. Box 70664 Charlotte, NC 26272-0664 7492672 iniruerirnirunnirriruirrrinirirrirrirnurrirrirrnnrii Account Number. 4862-3671-1312-3329 Please print address or phone number changes below using blue or black ink Home Rhone Nlre urre Fhone £,7m7adde9 O fi9017409903669641# MAIL ID NUMBER LISA BILLMAN PO BOX 172 DAUPHIN, PA 17016-0172 Please write your account number on your dx k or money order node payable to Capital Dne B05N,NA and mail with this coupon in the enclosed envelope. PROTHONOTARY CUMBERLAND CO CAPITAL ONE BANK (USA), N.A., Plaintiff, V. LISA BILLMAN 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.. _ gt?1y" `` ' o I? Dated: 1 k Sierra Fenner A049 WELTMAN, WEINBERG & REIS CO., L.P.A. 0 11 Cr r 0F l','pi??Y 2000 G?' i?r i f f E C `t t 7r ? ?ga.oo f1b AITY c?. 4559h831 f"atgs# a35a?5 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ,~~,n~~' at' ~~rrffL~r~~~~~ >~~~ FF i ~ 7F ' ~E 5 :.~IeF ~11.~i? :~c t't~- Tl'F ~'- ,~,ar''!t Jody S Smith Chief Deputy Edward L Schorpp Solicitor ~~~~ ~~~~ i ~ ~~ ~~ w~ Pci`~~ti~ Y~x r;, ` . Jrli~lt Capital One Bank (U.S.A.) N.A. vs. Lisa Billman Case Number 2009-8711 SHERIFF'S RETURN OF SERVICE 05/14/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Lisa Billman, but was unable to locate her in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant Lisa Billman. Request for service at 507 3rd Street, Enola, PA 17025 is vacant. The Enola Postmaster has advised Lisa Billman's new address is 1661 Mountain Road, Dauphin, PA 17018. SHERIFF COST: $60.00 SO ANSWERS, May 14, 2010 RON R ANDERSON, SHERIFF .c7 GruntySuite Sheriff. Teiecsaft. Mc- ?1-Cf- DICE ' fit. PROTHONOTARY L- Z-, J 0 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff vs. LISA BILLMAN Defendant(s) No. 09-8711 CIVIL TERM PRAECIPE TO SETTLE, DISCONTINUE AND END WITHOUT PREJUDICE TO REFILE FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: Lyndsay E Rowland, Esquire PA I.D. #205520 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#7492672 NPE IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff VS. Civil Action No. 09-8711 CIVIL TERM LISA BILLMAN Defendant(s) PRAECIPE TO SETTLE, DISCONTINUE AND END WITHOUT PREJUDICE TO REFILE TO THE PROTHONOTARY OF Cumberland COUNTY: SIR Kindly settle, discontinue and end without prejudice to refile the above-captioned matter upon the records of the Court and mark the costs paid. WELTMAN, WEINBERG & REIS CO,L.P.A. SWORN TJANDS SCRIBED before me tday of '2010 By: Lyndsay E wland, Esquire PA I.D. #20520 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 COMM6NW Notarl'I seal - Wendy L. Gault, Notary Public NO ARY PUB - e- city of Pittsburgh, Allegheny County My Commission Expires July 15, 2014 Member. Pennsylvania Association of Notaries