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Home My WebLink About10-0513 T?,, 2'il10 JAii 22 P, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff No: 10- 513 &ivil IEri? VS. COMPLAINT IN CIVIL ACTION RICHARD MORRIS 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 07806703 C N Pit KMJ "a.oo Po ATN C??' 8Ra3? ?1?o8?F8to IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff vs. Civil Action No RICHARD MORRIS 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: RICHARD MORRIS 930 S HUMER ST ENOLA, PA 17025 3. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXX4725 . 4. Defendant made use of said credit card and has a current balance due of $1807.56 , as of December 28, 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 0.000% per annum on the unpaid balance from December 28, 2009 . A copy of Plaintiff's Statement is attached hereto, marked as Exhibit "1" 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 , RICHARD MORRIS , individually , in the amount of $1807.56 with continuing interest thereon at the rate of 0.000°§ per annum from December 28, 2009 plus costs. James C. WELTMAN, 436 SevE Pittsbu (412) 3 FAX: 4 2 07806 03 h uLU.LUUC?6514 NBERG & REIS CO., L.P.A. Avenue, Suite 1400 h PA 15219 955 38-7130 C N Pit KMJ This law firm is a debt collector attempt V4 to collect this debt for our client and any information obtained will be used for that purpose. e?+isn 7806703 FINANCE Balance Payments 8 Credits ?-- CHARGE Transactions New Balance Minimum Payment Due Date C$1,62?-? $O W.:D + $31.36 + $39.00 $1,695.75 - $556.00 Aug. 31, 2009 Jul. 07, 2009 - Aug. O5, 2009 Page 1 of 1 MasterCard Plazinum Account 51745774725 Your Account Information TOTAL CREDIT LINE TOTAL AVAILA BLE CREDIT $ CREDIT LINE FOR CASH AVAILABLE CREDIT FOR CASH $000 Balance rate Pencdc Corresponding FONANM Purchases applied 1,54823 005342%D 231155% C?? 63135 Cash SO 00 005342%D 2315% 9D co ANNUAL PERCENTAGE RATE appied this period: 23.15% Q At Your Service -GobHww.caomlx.oo bmanspyowaxourt, 04 51 363) b reprxt a bat or Sob, cad ,p,* to Qrsbme, or Relailor 0 Pay online 011ar,caoaativ ormalyarpWmartb: Ctpkal Ore Beic (USA). NA r P 0 Bcec 71063.Ohabtle, NO 26272.1063 Send kRL&ies to: C4*A Ores P D Elm 30285. $at Lalw qty UT 6, 4100285 ® Have a question about a charge on your stakement7 Please refer to the Bkkg Rgfhls Summary on the bed of your statement or vent Fiance Charges {Pl?e see reverse for important nfamatan) PLEASE RETURN PORTION BELAw wrrH PAYMENT OR RAG ON TO wwW.CAPITALONE.COM TO MAKE YOUR PAYMENT ONLINE X'. Account Number: 5178-0572{6097.4725 Due Date New Balance Minimum Payment Amount Enclosed Aug. 31,200 $1,695.75 $5,00 _ PAY AT LEAST THIS AMOUNT #9021857638985811# RICHARD MORRIS 930 S HOMER ST ENOLA, PA 17025_2925 II..I I-11.11.11.111.111111rl lrrlrl11..I11'Id.11111161P11,11.11 PLUM PAY AT LE45r M6 Atvannr You're behind by W payments If we charge off your account de to late or messed payments, finance Charges willcontinue to accrue Ad raw b present the tom hTpernng Please pay the mn n m Payment amount on your statement or gore us a call at 1 B00 9555 5500 Vie're here to help Take ocntot of your credit with capital One crease ImporlahI in Annual I'L the terms we previously disclosed to Yom, your aowunt is now *be for an in - ceka,X Rates (APRs) effeck a immediately However, Cq ial One has elected not to rase your APRs at the time Please be advised tat k you fell b keep your account in good starhdirg Capital One reserves the right b rase your APRs in to We Payments. Credits 8r A4itlstments Transar?ions 1 S3900 Your 31 JJL PAST DUE FEE ?counL has gone over its Credit knR To avail additional we h at fees, you sho dC pay more than the ivleumurn Payment please pay eraugh to brrhg your account balarhce below mr ediatey your credit knit , and make sire your account balance remains below you cre it knit Please be sue the arhaunt you pay accounts far any futue purchases, fees, and (Hance charges You were assessed a pest the fee because you mr muxn payment was not received by the due date To awed the fee in the futu e, we recommend that you aloes at least 7 busrless days for your minimum payment to reach Cgalal one r4725 05 1695750018000556006 Lend a hand. Save the land. Manage your account online today- it's fast, easy and secure. e Pay online anytime-no more checks, stamps or clutter Q Moving? Change your address online or on the hack 0 Help save the planet Go paperless 0 Sign up at www capitalone corn Capital One Bank WSA), N.A. P.O. Box 71083 Charlotte, NC 28272-1083 uIIIP.1u..Nllli11t61Pllrrllnhr?llrhlllrllrrllhlilirlul Please make Checks payable to capital one Bank (uW, NA and mail with this coupon in the enclosed envelope. PROTHONOTARY CUMBERLAND CO CAPITAL ONE BANK (USA), N.A., Plaintiff, V. RICHARD MORRIS 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: . S ze-? Shawn Wood A049 WELTMAN, WEINBERG & REIS CO., L.P.A. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ?????ttp Ol L Rihl?gx f*? OFFICE'.) -t-F S-ERIFF r -,Any Jody S Smith Chief Deputy Edward L Schorpp Solicitor uapi[ai une banK (U.S.A.) N.A. vs. Richard Morris 201 Jt.'i ?S 1?1.1Y + i-s/ Case Number 2010-513 SHERIFF'S RETURN OF SERVICE 01/26/2010 04:23 PM - Michelle Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on January 26, 2010 at 1623 hours, she served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Richard Morris, by making known unto himself personally, at 930 S. Humer Street, Enola, Cumberland County, Pennsylvania 17025 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $41.50 January 27, 2010 SO A WE V NY R ANDERSON, SHERIFF 1 By Deputy Sheri f c CounfySuite Sheriff. Teleosof7 Inc.