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HomeMy WebLinkAbout10-1428¦ c f ILL'J .. _: L 2u 0 hAR, -1 2: 3 IN THE COURT OF._COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff No: ID ILI-14 VS. ANGELIA M KULP Defendant 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 07821836 C N Pit EMR 192.00 11L'14(.? Cry -ysaV43 R*?aa gls?- A IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff vs. Civil Action No ANGELIA M KULP 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: ANGELIA M KULP 920 WERTZVILLE RD ENOLA, PA 17025 3. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXX9691 . 4. Defendant made use of said credit card and has a current balance due of $4518.87 , as of February 16, 2010 . 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 23.100. per annum on the unpaid balance from February 16, 2010 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 , ANGELIA M KULP , individually , in the amount of $4518.87 with continuing interest thereon at the rate of 23.100% per annum from February 16, 2010 plus costs. ,42524 WELTM& REIS CO., L.P.A. 436 S, Suite 1400 Pitts219 James FNPiEtu0EEMR (412) FAX: 0782:b 782 This law firm is a debt collector attem ing to collect this debt for our client and any information obtaine will be used for that purpose. FINANCE Previous Balance Payments & Credtfs CHARGE Transactions; New Balance Minimtlrn Payment Due Date C$3,506.36 - $0.00 + $62.90 + $78.00 = $3,647.26 $671.00 Apr. 15, 2009 Feb. 22, 2009 - Mar. 21, 2009 Page 1 Of 1 7821836 Ylsa Pk* m Accent sommoom Your Account Mfotnladim TOTAL CREDIT LINE $2,650.00 TOTAL AVAILABLE CREDIT $0,00 CREDIT LINE FOR CASH $2,650.00 AVAILABLE CREDIT FOR CASH $0,00 Fnalce (;hleges (Please see reverse for ffnportan1-_______*_information) Balance rate, Parodic Co responarg FRANCE applied b rate APR CHARGE Purchases 53,54212 0OSi42% D 2315% $SZ90 Cash $0.00 0.06342% D 2315% $0.00 ANNUAL PERCENTAGE RATE appled this period: 23119% Q AtyorService -Gob "womitatim mto merepryour wcout, or CIA 1EOD-9 4169b repast a bat or d*ncad or apadc b Ombnirr Robbie 0 PayOdneti rtercarabyoonormaymrpW=rdv CalfailOne Bart (USA),NA -P0Bak7109-Chirdb,NC 28271-1083 A Said iqukies Lo: C*WOrwP0 Esc 30295• Sat Lde ck, Ur $4130-M ® Have a gteWon about a charge on yow dam ew Please refer to the BNfrg Rights Summary on the back d yaw statement or vast REASE PAY AT LEW T% AM M You're behind by SK payments 1t we charge off your atom die Lo tare or missed payments, from dtarges will cA*-m to accrue Act now to prevent this from happening Please pay the mmmrun pa)mr_nt amount on your statement or give ue a cal at 190) 255 66M We're here to help Take control of your credit with Capital One 'Important Norm,- Under the terms we Ramusy disclosed to you, you account is nax elgble for on rcreese in Amuel Piamntsge Rates (APRs) effective i mnedately I-mmer, Cpl Ore has elected not b rase yar APRs st this time Please be advised thal f you fail to keep you account in grad starrirg, Oa dal Ora reserves the rot to rase you APRs in the kt a Payments, Cl edito & AuiustlneMt Transar w1s; 1 18 MR PAST DUE FEE $39.00 2 21 MAR OVERLIMIT FEE MAR 21,2X9 $39100 You account has gone over ifs aedit limit To avail addYoral overYrrl fees, you should pay more than toe hMMmtm Payment Please pay ero# b bring you account balance below yaw credt knit immediately, and make we yaw account balXge remains baloN yew credit Imt Please, be sure the arounl you pay accounts for any futile puctases, fees, and finance charges You were assessed a past due fee because you mnmun payment was not received by the die d7ta To cord this fee in the future, we recommend tat you slaw at least 7 business days for you mrlimum payment breach Capital One PIFASE RETURN PORTION BELOW WITH PAYMENT OR LOG ON TO MM CAMAIDNE.COM TO MAKE YOUR PAYMENT ONLINE 1 59691 21 3647260100000671000 X Account Number:4WSNWMMNMW9691 tend a hand. Save the band Due Date New Balance Minimum Payment Amount Enclosed . Manage your account online today- Apr. 15, 2009 $3,647.26 $671.00 it's fast, easy and secure. e Pay onhne anytime-no more checks, stamps or clutter T?HISAMOUNT 0 .,n,l Change your address online or on the back ® Help save the planet Go paperless #9008106800247627# © Sign up at w capitalone cam ANGELIA R KULP 920 YERTZVILLE RD Capital One Bank (USA), N.A. ENOLA, PA 17025-1635 P.O. Box 71063 Y+1111 charlotte, NC 28272-1063 Please make checks payable to Capital One Bank (USA), NA and mail with this coupon in the endosed envelope. Nf l ???? PROTHONOTARY CUMBERLAND CO CAPITAL ONE BANK (USA), N.A., Plaintiff, V. ANGELIA M KULP 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 I Dated: n4L:-?? Davina John n A049 WELTMAN, WEINBERG & REIS CO., L.P.A. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy ~9t`1.,. of ~iirrrb~tfiir0 _~ ; t~. At~D-t`'~rjCE >3F ?'~'~ p~~p~t{ ~t~~Q1ARY 2010 ~~~ 19 A1~ 8~ ~0 Edward L Schorpp Solicitor - -~,. y ~. ~`ri~ CUPV~ . ~` J 'VC t "~~ i ,` Capital One Bank (U.S.A.) N.A. vs. Case Number Angelia M. Kulp 2010-1428 SHERIFF'S RETURN OF SERVICE 03/16/2010 07:00 PM -Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on March 16, 2010 at 1900 hours, she served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Angelia M. Kulp, by making known unto herself personally, at 920 Wertzville Road, Enola, Cumberland County, Pennsylvania 17025 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $41.50 March 18, 2010 AMA DA COBAUGH, DEPU SO ANSWERS, RON R ANDERSON, SHERIFF (cj Cn~intySuite Shen~f T~!~ecsuft. Inc. ~ ry,~ l-iL~ '_. ~-'._ z~l~ ,J',_ 2~ P~ 2' 3~ T`f GUP~'- ~ ` r'~,•. ,~ ~., , , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CNII., DNISION CAPITAL ONE BANK (USA),NA Plaintiff vs. ANGELIA M ICULP Defendant(s) No. 10-1428 CIVIL TERM PRAECIPE TO SETTLE, DISCONTINUE AND END WITH PREJUDICE TO BEETLE 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 1.400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412)434-7955 WWR#7821836 NPE r ~ IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff vs. Civil Action No. 10-1428 CIVIL TERM ANGELIA M KULP Defendants} PRAECIPE TO SETTLE DISCONTINUE AND END WITH PREJUDICE TO REFILE TO THE PROTHONOTARY OF COUNTY: Settle, Discontinue and End With Prejudice to Refile the above-captioned matter upon the records of the Court and mark the costs paid. WELTIV~AN, ~VETNBERG & R~'lIS CO., L.P By: \. Lyndsay E R lan , squir PA I.D. #20 , 5 0 WELTMAN„ INBERG & REIS CO., L.P.A 1400 Koppe s uilding 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#7821836 Sworn to and subscri ~d Before me the Day of ~~y ARY ~ P .NN LVANIA NoraAM MM WayM A, 7aNM NobrY PubNc Qry of -~Y