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HomeMy WebLinkAbout10-1432 ZOlO i it ` 1 Phi 12' 4 7 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff No: vs ALEXANDER J REEVES 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. 525 Vine Street, Suite 800 Cincinnati, OH 45202 (513)-723-2200 FAX: 513-723-2239 07867205 C N Cin EMR 01?? es? ?si?x?s' ?. as 8?sb 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: ALEXANDER J REEVES 8 COBBLESTONE DR CARLISLE, PA 17015 3. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXX8223 . 4. Defendant made use of said credit card and has a current balance due of $2193.04 , as of February 10, 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 10, 2010 . A copy of Plaintiff's Statement is attached hereto, marked as Exhibit 111" and made a part hereof. 10 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff vs. Civil Action No ALEXANDER J REEVES 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 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 , ALEXANDER J REEVES , individually , in the amount of $2193.04 with continuing interest thereon at the rate of 23.100% per annum from February 10, 2010 plus costs. James C.' rmbrodt,42524 WELTMAN W INBERG & REIS CO., L.P.A. 525 Vi S reet, Suite 800 Cinci at', OH 45202 (513) 2 -2200 FAX: 1 -723-2239 0786 2 5 C N Cin EMR This law firm is a debt collector attempV-ing to collect this debt for our client and any information obtained will be used for that purpose. FINANCE Previous Balance Payments 8 Credits CHARGE Trarnactiorm Now Wenx Minimum Payment Due Dab ( $1,550.89 - $0.00 + $30.96 + $78 00 =( $1,659.85 $362.00 F Mar- 10, 2009, Jan. 14, 2009 - Feb. 13, 2009 Page 1 Of 1 re PLEASE PAY AT 11" THIS AMOUNT Finance ChWges (Please see reverse for important Information) Balance rate Periodic Carespondrg FMANCE applied to -ale APR CHARGE Purchases $3 13 00$342% D 2315% $6.59 Cash $14942 00634296 D 231% $24,37 ANNUAL PEItCENrAGE RATE appMed Bit period: 23.15% At Yew Sow -GiloMWaeoihhrecambmaapeyour a Oi 140.903 W b report a bet or SU. Paid or speck to axorm ReMbns ® PayOolrieatyw ormdyorpevwieib: ('wren ore eaik NSA). NA - P O B. TM • G t>na, Nc 2BU2.1083 Send Irgiiritt to: CSI Orin, P 0 Bed 30286 • Sid Ldw Q4, UT 641300286 ® Haw a gmdm about a charge on your /Memont? Pease refer b the Bikg Rg* Summary m the back ofyow statement or visit www-caotalonepomirdisoutes I REASE RETURN PORTION BELOW WITH PAYMENT OR LOG ON TO WWW.CAMALONE.COM TO MAKE YOUR PAYMENT ONLINE Madi rCatd PNtinum Account Your Account hrOrmallon TOTAL CREDIT LONE $1,00000 TOTALAVAILABLE CREDIT $0.00 CREDIT LINE FOR CASH $1,000.00 AVAILABLE CREDIT FOR CASH $000 You're behnd W fN- payments WeVe permanently revoked your ohargng pr vieges It you oonalue to mss payments your account is at risk of being charged off Please don't let this happen If yWre Tacky weiw9helmed, call us at 1 BUD 955 6600 well work with you to resort 11m matter 38223 13 165985079DO50362001 7867205 Account Number lONEEMONW8223 Due Date New Balance Minimum Payment Amount Enclosed Mar. 10, 2009 C$1,659.85 ( $362.00 PLEASE PAY AT LEAST THIS AMOUNT #9004588114012157# ALEXANDER J REEVES A COBBLESTONE DR CARLISLE, PA 17015-4366 111. 1..111 lid =-.:a-Lrl 77-11 ^ Tlansa Lions 1 07 FEB PAST DUE FEE $3800 2 13 FEB OVERUMIT FEE FEB 13, 2009 $31900 Under tams prevlousy disclosed to you, some or al of your Arru l Percerrage Rates (APRs) have been increased since your amount was past die trice in the pod 12 billing cycles Hyour rates fare already increased, Wmquent dean ueroes eittanded the dratron of the rc eiraed raft Remember If we rexirve your minimum monthly payment on tone for 12 carsecrhie bdrg cycles, the account will be reviewed for a posable return to your Nartlrhtroduclay APR Your account has gone aver is credit unit To avoid add6onal o erhrit fees, you elauld pay more than the Mi imurn Payment. Please pay sough to brig your account odance bebw your credit brit immediately, aid make sue your account balance remain bebw your credit brit. Mom be sire the amount you pay accourb for ary future purdmas, fees, all finance charges You were assessed a past ore fee because you mraram pafnent was not received by the due date To avoid this fee in the future, we recom maid that you aloe at lent 7 heiress days for your miwmun payment to reach Capital One 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 © Movin97 Change your address online or on the hack 0 Help save the planet Go paperiess 0 Sign up at www capdalonc com Capital One Bank (USA), N•A- P•0• BOK 71063 Charlotte, NC 26272-1063 lllllllrlllrallllirlrlllllllrrllllllrrllrlelllellirllllllllrllll Please make checks payable to Capital One Bank (USN, NA and mail with this coupon kt the enclosed envelope. PROTHONOTARY CUMBERLAND CO CAPITAL ONE BANK (USA), N.A., Plaintiff, V. ALEXANDER J REEVES 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: U-5/1-0 S Shawn Wood A049 WELTMAN, WEINBERG & REIS CO., L.P.A. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy S. %L R 'T THE: F, 2010 HAR 10 PI' 2: 25 Edward L Schorpp Solicitor Capital One Bank (U.S.A.) N.A. vs. Alexander J. Reeves Case Number 2010-1432 SHERIFF'S RETURN OF SERVICE 03/08/2010 04:50 PM - Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on March 8, 2010 at 1645 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Alexander J. Reeves, by making known unto himself personally, at 1101 Claremont Road, Carlisle, Cumberland County, Pennsylvania 17015 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $38.80 March 09, 2010 GE LD WORTHIN N, DEPUTY SO ANSWERS, RONNYY R ANDERSON, SHERIFF c GountySulte She-t, Teinsott. In,-,