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Home My WebLink About10-0300I .. rru`? Tjx: 2010 JAN t t PM 12: 18 rC ` r ?Yj,? h u1?N.? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff No: 1c) - ? &ViLTerpt vs. COMPLAINT IN CIVIL ACTION JOHN F DRENNAN 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 07752121 C N Pit KMJ *ga. Do PD rar, c0 899-3030-/ q39 ,30o ?3& 09 (/ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff vs. Civil Action No JOHN F DRENNAN 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: JOHN F DRENNAN 513 BRIDGE ST., ##3 NEW CUMBERLAND, PA 17070 3. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXX4525 . 4. Defendant made use of said credit card and has a current balance due of $4551.00 , as of December 10, 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 23.1006 per annum on the unpaid balance from December 10, 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 , JOHN F DRENNAN , individually , in the amount of $4551.00 with continuing interest thereon at the rate of 23.100. per annum from December 10, 2009 plus costs. fames WELTM 436 S Pitts (412) FAX: 0 2 This law firm is a debt collector att our client and any information obtain Wa ro t,42524 WEINBERG & REIS CO., L.P.A. e th Avenue, Suite 1400 r h, PA 15219 4-7955 -338-7130 1 C N Pit KMJ ing to collect this debt for ill be used for that purpose. Previous Balance Payments & Credb CHAR E Trareaefbra New Balance Minim n Payment Due Date C$2,904.41 - $0.00 + $62.24 + $78.00 = $3,044.65 $178.00 OCt. 04, 2008 Aug. 10, 2008 - Sep. 09, 2006 Page 1 Of 1 Visa PlWn m Account 49B&""40404625 Your Account IdomwMm TOTAL CREDIT LINE $2.950.00 TOTALAVAILABLE CREDIT $0.00 GREDIT LINE FOR CASH $2,960.00 AVAILABLE CREDIT FOR CASH $0.00 Finanee Charges (Please see reverse for nporfent information) Balance rate Periodic Gorrespondrrg FINANCE applied to rote APR CHARGE Purchases $2,316 41 0.05822% D 2490% $48.90 Cash 562572 0.06622% D 24.90% $1325 ANNUAL PERCENTAGE RATE Wpkd 0ts perlod: 24.00% Q At Your SKAW • Co to wAWx otdM=b mange your eommt, or08t1X903 bspatabdaemkncadorspeak togrvioi- ReN?m ® Pay Ordneetm am mm ormdymrpayrnemb: CaPW 28271-0 One batk (USA), NA • P 0 Elm 70094 • (Tattle, NC A Send luqu- 6o: CepiW One, P O_ Bw 3DM • Set tale Cty, Ur 84130-M ® Haveaquestion WvutacMrgeonyarst*mwV Please refer to the Billing RU* Summary on the bads d your slatemr t or vst rMcagitalone.oWdeputes Yotlre behind by ore payment Remember that paying the mranum payment by the due date keeps your amount current So make sue you serd n the mnmum payment b keep your accent current. Payments Credits & Adiustrrments Transacd mms 1 03 SEP PAST DUE FEE $3900 2 09 SEP 0`R IMIT FEE SEP 09, 2008 $3900 Under terms prevw * dsdeed to you, some or all of your Amual Percenlege Rates (APRs) have been increased since your account was pest die twice n the past 12 bdi g cycles If your rates have &ea* increased, u6aeq)et dalingaanow edaded the duration of the increased rates Renumber If we reserve your mnmum monthly payment on ime for 12 mrs aAm birg cycles, the account will be reviewed for a possible return to yam N"nlrodjcdry APR Your aunt has gone war is credit lant. To avoid addbmal merYnd tees, please pay enough to bing your balance below your credit limit mmedately, and make we you remain below your m* limit Please be sue to axon fa any Un purchases, fees, and frence charges You were assessed a pest due fee became you minimum payment was not received by the dire date To and this be n the future, we recommend that you slow at least 7 business days for your mrhmum payment to reach Gapilal One PLEASE RETURN PORTION BELOW WITH PAYMENT OR LOG ON TO W VWVL TAIONELOM TO MAKE YOUR PAYMENT ONLINE olle char „? ?r wa .t.,,. )4525 09 3044650176000178008 New Balance Minimum Payment Due Date C$3,044.65 $178.00 Oct. 04, 2008 Amount Enclosed C? Capital One Bank (USA), N.A. P.O. Box 76864 Charlotte, NC 28272-6884 7752121 I'Ills'?t"r'rllll'?141?1'Ihll"llltlll't'?ll?l?lll?l?ll?lr'I Account Number: 4388-64184040-4525 Please print address or phone number dwges below using bkre or black ink Home Phom A&WWte Phvfv f rnsAadoless #9025422696905114# MAIL ID NUMBER JOHN F DRENNAN 642 ABERDEEN RD ELIZABETHTOWN, PA 17022-9451 uPlNrl'Ill"Nhrr?ll'rdirrll'I?hll"'rldrrrr'Pqulur Neese write your account number on your payment made payable to Capital One Bank (USN, NA. and mail with this coupon in the enclosed envelope. PROTHONOTARY CUMBERLAND CO CAPITAL ONE BANK (USA), N.A., Plaintiff, V. JOHN F DRENNAN 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: Shawn Wood A049 WELTMAN, WEINBERG & REIS CO., L.P.A. Ronny R Anderson Sheriff Jody S Smith Chief Deputy Edward L Schorpp Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY FlL^'=i ra .)F THE PPtOTL,, OTAPY ??tttt+v of ?u,ubtrf,?,,?? ?.. k 2010 FEB -8 PM 12= 01 ?CUtY'r" :r cal F = ERtFF ;?.?.• S l.'t?r? Capital One Bank (U.S.A.) N.A. vs. John F. Drennan SHERIFF'S RETURN OF SERVICE Case Number 2010-300 02/03/2010 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: John F. Drennan, but was unable to locate him in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant John F. Drennan. Mickey Minnich, Landlord advised Deputies John F. Drennan moved out three years ago. SHERIFF COST: $48.30 February 03, 2010 c CruntySuite $r a;tf, ieleosoft In- ~"~'i=~~ t~ up`'r'; ;~QT ~ PEI~(IvSYI~b'~IA ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff vs. JOHN F DRENNAN Defendant(s) No. 10-300 CIVIL TERM PRAECIPE TO REINSTATE COMPLAINT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: Lyndsay E Rowland, Esquire PA ID #205520 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Buidling 436 Seventh Avenue Pittsburgh, PA 15219 (412)434-7955 WWR#7752121 NPE Q 10.00 Pa A'C7~/ C*g1Y184R 5 R,~ ~, ~17101~3 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPI`fAL ONE BANK (USA),NA Plaintiff vs. Civil Action No. 10-300 CIVIL TERM JOHN F DRENNAN Defendant(s) PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. WELTMAI~;-jWEINBERG & REIS CO., L.P.A. By: /- ~ Lyndsay E ow and, Esquire PA ID #2 520 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Buidling 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR #7752121 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ~9~~tn ct ~utt+brrt~ry~ Jody S Smith ,. Chief Deputy ~ `~ ~ ~~ #``~ i~., ~.Y Richard W Stewart SOiICItOf C}F~ICE: t~ES~ERIFF Capital One Bank (U.S.A.) N.A. vs. John F. Drennan Case Number 2010-300 SHERIFF'S RETURN OF SERVICE 09/27/2010 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: John F. Drennan, but was unable to locate him in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant John F. Drennan. Current occupants of 332 4th Street, New Cumberland, PA 17070 advised Deputies, John F. Drennan has moved from this location. The New Cumberland Postmaster has confirmed, John F. Drennan is not known at 332 4th Street, New Cumberland, PA 17070. SHERIFF COST: $48.30 September 27, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF t~ - r.., ~ `~ .. P.F ~8; 1`z t ~ _ !-~ ~ T f~~ ~'"1 "' ~:a7f -'C ~ [V to ..r7 i::3 1 ~' ~~ _ ~ ~~: ~ __5 ~ "rj --~. ~- C~ ~Y W C'7 ~ r-n ~ rva ~? ~~ .`. -< (c) GountySuite Sheriff, Teleosoff, Inc. WELTMAN, WEINBERG & REIS CO., L.P.A. BY: Benjamin R. Bibler I.D. No. 93598 436 Seventh Avenue, 1400 Koppers Bldg Pittsburgh, PA 15219 Phone: 412.434.7955 Fax: 412.434.7959 File # 7752121 NPE 3 Attorney for Plaintiff(s);?CD =M mot... cn ? -C ? ?o D ? ? q CAPITAL ONE BANK (USA),NA vs. JOHN F DRENNAN Cumberland County Court of Common Pleas No.: 10-300 CIVIL TERM PRAECIPE TO DISMISS WITHOUT PREJUDICE TO REFILE TO THE PROTHONOTARY: Kindly dismiss the above matter without prejudice to refile. WELTMAN, WEINBERG & REIS CO., L.P.A. By r.? M ca cn x?• OD OD --a M C) . c) d- C) i ° r7i