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Home My WebLink About10-1506I 1 of THE?TNONTARY 2010 MAR -4 AM 10: 30 CUP,' :;AUNTY PEN SYUVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA - Plaintiff No: /? - ls6L vs. COMPLAINT IN CIVIL ACTION ASHLEY N DINSMORE 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 07435906 C N Cin EMR 4tq-?.00 ?CL-41? C(t-? N52933b ?2?--.2383f? .a IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff vs. Civil Action No ASHLEY N DINSMORE 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: ASHLEY N DINSMORE 43 VILLAGE CT MCCHANICSBURG, PA 17050 3. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXX0881 . 4. Defendant made use of said credit card and has a current balance due of $3765.78 , as of February 11, 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 25.900% per annum on the unpaid balance from February 11, 2010 . 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 , ASHLEY N DINSMORE , individually , in the amount of $3765.78 with continuing interest thereon at the rate of 25.9000 per annum from February 11, 2010 plus costs. James C. rmbroUt,42524 WELTMAN, /RVINBERG & REIS CO., L.P.A. 525 Vine S reet, Suite 800 Cincinn OH 45202 (513)-7 3 2200 FAX: 5 723-2239 074359 C N Cin EMR This law firm is a debt collector attempting to collect this debt for our client and any information obtained will be used for that purpose. RNANCE Previous Bake Payrnenb 6 Credb CHARGE Traraactions New Balnuree Mh*n m Payment Due Dale ( $2,481 87 * $55.35 * $39.00 = $2,576.22 L$417.00 Oct. 08, 2008 Aug. 14, 2008 - Sep. 13, 2008 Page 1 of 1 PEASE PAY AT LFAV THS AhaJUM Viva Phdnun Acwu t annoolola1 Your Account khrmadon TOTAL CREDIT LINE $2,000 00 TOTAL AVAILABLE CREDIT $0.00 CREDIT LINE FOR GASH $2,000.00 AVAILABLE CREDIT FOR CASH $0.00 Finance Charges (Please see reverse for important Information) Balance rate Penodc Caresponcitg FINAM E appliedb ale APR ONARtfE Pudmw $2,516 03 0.07096% 2590% $553 Cash 30,00 0.07099h 2590% $D00 AfaMIAL PHtCBiiAIiE RATE appled tlrN psrlod: 2SBBY. ? Q AtYour$wW=-Gobyephy ti bmaeyeyolraooourt, w Qe 1aNW3J63T b sport a Ld err.M. cad a speak b CLalxrer RAMns ® PyOrirral wwmalowcom or mudyour pW wtU CepM Ore Bark (USA), NA - P 0 Bon 70tt4. Ondb, NC 23V2aN A sawhypiilrsbo: Opal OrwP0 Box MM- Salt Lelapy,Ur841340186 ® Nave a question about a cringe on yotw MaMment? Please refer b to Biig Rght Sunmarym the beds of you statement or vnt You're behind by five payments Were permanently revoked your charging prK*gw ft you ommue to miss payments your account as at risk of being daged off Please don't let this happen If yWre feeling overwhei ned, call us at 1 HOD 955 6600 We'1 work with you to resolve Ihrs matter Payments, Creaks 8 Adustmerhb Transaedw 1 08 SEP PAST DUE FEE $38.00 Under terms prwroasy dsdosed to you, some a all of your Annual Pacadge Rates (APRs) have been increased since you (lcoount was past die bounce in the past 12 W" cycles If your rates have *as* increased, s(bseciuat dafngmxm wle ded the duaton of the increased rakes Remember If we recew your mrmum monthly payment on tore fa 12 cariseoLve bdi g cydes, this account we be mviswad for a po5si* mbxn b you WWntiodcbry APR You account has gone over is sect ini To avoid adibonal oveAmd fees, please pay ertough to bong your balance bebN you aedd hind mmacla". ad make sue you remain below you aecit Nona Please be sue b acmut br any Wre purchases, fees, and finance charges You account is daegnated to dose Continue to make payment udl you balance reaches $0 You account war dose on the first statement after you balance reedes $0 Do not mace any now charges on you aedt card and stop any a rtomatc payments or preauttgrved chases you may have set LIP on your account M you use (wipe) your card dung the tine, we can coredar this aitnonzatonn to remme the dose mgest and your woout can reran open You were assessed at past die nee because your mnm(m pays wt was not racetved by the In date To mod this fee in the U me, we recommend that you atom at least 7 b ua ess clays fa your mranun payment to reach Ganda! One EXHIBR PLEASE RETURN PORTION BELOW WrTH PAYMENT OR LOG ON TO WWN CAPTTALONE.COM TO MAKE YOUR PAYMENT ONLINE C pftwcr what's .ny-r-II. 7" 50881 13 2576220500000417006 New Balance Minimum Payment Due Data $2,576.22 $417.00 (:Oct. Amount Endosed C Capital One Bank (USA), N.A. P•0• Box 70884 Charlotte, NC 26272-0884 7435906 1'111""" ?'lallll?r191'I'1411'hll'LLI'?'?Il?l?ul'I?Ir'Ir'I Account Number. 881 Please print address or phone number dnrges bdmv using blue or black ik HOW Fhom altevaarae Phone f-mx?7sddrca O #9025855830935929# MAIL ID NUMBER ASHLEY N DINSMORE 43 VILLAGE CT MECHANICSBURG, PA 17050-9166 ?itPPurunll??i•drr?hldtl'Il'Ilau" ?mullu.,lll.l,ll Please write your account number on your payment made payableto Capital One Bank(USA), NA. and mail with this coupon in the enclosed envelope. PROTHONOTARY CUMBERLAND CO CAPITAL ONE BANK (USA), N.A., Plaintiff, V. ASHLEY N DINSMORE 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 Dated: _ K-0 . Davina Jo son A049 WELTMAN, WEINBERG & REIS CO., L.P.A. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff °-ILLi ?ap?xtr of Gir+pbrr/??tD ,- ? ? ` n,~ ? - ! ,?tiJ Jody S Smith Chief Deputy Edward L Schorpp Solicitor tEFii E € T} ,E ~RiF r t n1.? Capital One Bank (U.S.A.) N.A. vs. Case Number . Ashley N. Dinsmore 2010-1506 SHERIFF'S RETURN OF SERVICE 03/12/2010 06:27 PM - Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on March 12, 2010 at 1822 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Ashley N. Dinsmore, by making known unto herself pe onally at 3 Village Court, Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents n t t s re time handing to her personally the said true and correct copy of the same. HARRISON, DEPUTY SHERIFF COST: $37.00 March 15, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF Coun,ySuReShen,f.Ieleo.=.ott Inc.