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HomeMy WebLinkAbout10-1434 1 FIL C? -? ? 2CI?nR - I P11 12: 4 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff Vs. No: Ll-?nl-t y COMPLAINT IN CIVIL ACTION PATRICIA G STECK 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 07889857 C N Cin EMR 0 CIt-4 A/9L737 ? .23 8if38 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: PATRICIA G STECK 802 HUMMEL AVENUE LEMOYNE, PA 17043 3. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXX0739 . 4. Defendant made use of said credit card and has a current balance due of $2667.53 , 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. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff VS. PATRICIA G STECK 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 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 , PATRICIA G STECK , individually , in the amount of $2667.53 with continuing interest thereon at the rate of 23.100% per annum from February 10, 2010 plus costs. James warmr?rou?, ????? WELT WEINBERG & REIS CO., L.P.A. 525 V10: treet, Suite 800 Cinci t', OH 45202 (513) 72 -2200 FAX: c13 723-2239 078 985 C N Cin EMR This law firm is a debt collector atte{ ing to collect this debt for our client and any information obtaine will be used for that purpose. Prevlous Balance $1,642.84 - Paymatts 6 Credits $0.00 :) + SCI MGE Trartsadbrls $32.77 + $137.00 New Balance MirlimlarL Payment Due Date = $1,812.81 $188.00 Jan. 07, 2009 Nov. 14, 2008 - Dec. 13, 2008 Page 1 f011 KM PAY AT LEAST Ta6AMOM Gard P ?iaati Account Your Account Iflfomntlon TOTAL CREDIT LINE $1,500.00 TOTAL AVAILABLE CREDIT $0.00 CREDIT LINE FOR CASH $1,000.00 AVAILABLE CREDIT FOR CASH $0.00 =(Plww ease see reverse to r rportant information) rate Pere d c Carespo rd g FetANCE b ate APR (.l1AR(NE .31 00654896D 239096 $3277 0.00 O.00541%D 239096 S0.0D RATE eppled We period: 23A096 At Your Serrvke-Gobryn 6Mlomaragyora d, or gt 11MIXI033E37 b Wort a bid of sl13111n cod a ryedr b QNbrW Rdabris ® PayOrnrmdrtpLy& lorMWWpwrratto C*w ore Bak VW, NA • P 0 Buc 71083 - Tattle, NC 28272-1083 A Surd kqukin o tor: QPtd Ors P P 0 Buoc 30288 ? Si Lee ON, lJf 841300286 ® Have a 4lwwon about a chaW on your ddermntT Please refer to the Blirg Rghls Sunmay on the beds of you swemenl or Vist Yoke betmd by two payments Lens tek 9 yorre tmag fnaztaal dlfiWIles and oan't make your mnmun payment - we went to help Lers work together to find a solution P- rnents, Credits 8 Aciustrrfents Transactions -- -? 1 OB DEC PAST DUE FEE ? UD 2 13 DEC CAPITAL ONE IvENER FEE ? 00 3 13 DEC OVERLIMIT FEE DEC 13, 2008 Lrndar term pevcL4 ascbsed b you, sortie or all of your Annual paemlage Rates (APRs) have been rmoeNese ed owed arc e your rn account was e$ pot do twce in to poet 12 bilirg oyclee If your ratee howe *a* w the duration of the ircmand rake Rarnernber If we e nor}naives re your rtaa minenum rtgrihy payment on time fa 12 coreaoiwe bang cYcies, tors ttccaun wi be mAph,ed for a possble ro n to you Nm4nrod Lzy APR. Your account has gore over its onedt lend. To avod adibnal ov Kknot fees, you should p more Dun the Minmum Payment Please pay erough b brig your amount balance below you annedMey, lad make sue your accent balance rerreans ? cre* t Please be sure the amount you pay accounts fix any fiAn pu:hwee, fees, You were assessed a past due fee because yar mr cram payment was not reowed by the do date To mod this fee in the We, we re=rr*rd that you abr at least 7 bwrtess days for your mrlmun payment to reach CapM One PLEASE RETURN PORTION BELOW WITH PAYMENT OR LOG ON TO WYWV.CAPITAIANE.COM TO MAKE YOUR PAYMENT ONLINE 7889857 1 5178057290690739 13 1812610189490188002 739 Account Nun Due Date New Balance Minimum Payment Amount nclosed Jan. 07, 2009 $1,812.61 $188.00 nfASE PAY AT LEAST THIS AMOUNT #9034981393081247# PATRICIA 6 STECK 802 HUNREL AVENUE LEMOYNE, PA 17043 rurrlrlllllhrrllrH.Irrliurirlpplllrurrrlrrrulllrlltlh Lend a hand. Save the land. Manage your account online today- it's fast, easy and secure. O Pay crlme anytime-no more checks, stamps or clutter © Moving? Change your address online or on the hack ® WAp save the planet Go paperless O Sign up at www capitalone com Capital One Bank (USA), N.A. P.O. BOX 71083 Charlotte, NC 26272-1063 lllllllrlllrrlllllrllrlllllllrrllllllrrllrlrlllrgrrlllllllirllll please nuke checks payable to Capital One Bank (USN, NA and mail with this coupon in the enclosed ewelWe. ?...?.el PROTHONOTARY CUMBERLAND CO CAPITAL ONE BANK (USA), N.A., Plaintiff, V. PATRICIA G STECK 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 d Shawn Wood A049 WELTMAN, WEINBERG & REIS CO., L.P.A. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson ~IL~D-ui-r-'G~ sheriff ~~~ ?I-f~ P1•'0~?-i0'~~10TARY ~~~r{cu ct ~aua6rrf~ifd~ Jody S Smith 201 ~~~ -5 Pig 2~ 3? ~~ Chief Deputy ~ ~ ~ ~ ~` ~v~t .~ ~~, , x•. Edward L Schorpp ~` OuP~~; ~ :; ..~ ':~i~~~Y Solicitor ~FF'c~ ~` 'rr `~FRii/F LV 'f~ t~L I ,liv ~~ t~ Capital One Bank (U.S.A.) N.A. Case Number vs. 2010-1434 Patricia G. Steck SHERIFF'S RETURN OF SERVICE 03/02/2010 08:59 PM -Stephen Bender, Deputy Sheriff, who being duly sworn according to law, states that on March 2, 2010 at 2100 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Patricia G. Steck, by making known unto Edward Steck, Husband of defendant at 802 Hummel Avenue, Lemoyne, Cumberland County, Pennsylvania 17043 its contents and at the same time handing to him personally the said true and correct copy of the same. ~~i~ STEPHEN BENDER, DEPUTY SHERIFF COST: $42.40 March 03, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF (c:. GountySuite Sheriff. Teieosott, tnc.