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HomeMy WebLinkAbout10-1818 2010 Pt 12 P,1 3. 0 t ff"y IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff VS. No : ?b - late 0-1144 I -w COMPLAINT IN CIVIL ACTION JEFFREY L QUACKENBUSH 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 07411119 C N Pit CFR 0 +qa.oo PA AT" ce 460-6-33 R:t* a.381344 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff VS. Civil Action No JEFFREY L QUACKENBUSH 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 0 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: JEFFREY L QUACKENBUSH 415 3RD ST ENOLA, PA 17025 3. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXX3161 . 4. Defendant made use of said credit card and has a current balance due of $1346.85 , as of March 01, 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 15.9000 per annum on the unpaid balance from March 01, 2010 . A copy of Plaintiff's STATEMENT is attached hereto, marked as Exhibit 11111 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 , JEFFREY L QUACKENBUSH , INDIVIDUALLY , in the amount of $1346.85 with continuing interest thereon at the rate of 15.90001 per annum from March 01, 2010 plus costs. t,42524 James KPA WELTM& REIS CO., L.P.A. 436 Se, Suite 1400 Pitts5219 (412) FAX: 07411 CFR This la w firm is a debt collector attemp V-1 t o collect this debt for our client and any information obtained be used for that purpose. Previous Bolo= Payments & Credits FINANCE Payments CHARGE Transactions New Balance Minimum Pa Due Oahe $968.94 i? '?- ? ? + $12.84 + $39.00 = $1,020.78 $165.00 ?OCt. 27, 2008 Sep. 02, 2008 - Oct. 01, 2008 Page 1 of 1 r;•. Phtl111n1um Accotnt :1 Your Account httbmulil n TOTAL CREDIT LINE $750.00 TOTAL AVAILABLE CREDIT $0,00 CREDIT LINE FOR CASH $750,00 AVAILABLE CREDIT FOR CASH :0,00 F1na11Ce Charges Peace we reverse for rnpartent information) Babrce rate Percdc Conaopon ig FINANIM R:pted to rale APR CHARGE Purdasee, 3882.89 0.04356%P 1590% $12.84 Cash $0.00 0 N055% P 10M $0.00 ANNUAL PERCENTAGE RATE applied Ub period: 18.90% ® At Your Ssivks-Gobepp miotngryarewant, a Od 1400333807 b ripprat a bet or sCkn cad cr speck b amomar Rellra ® Pill/ Online atmmowbra9714ormsiyarPNrili'tto COW Ora Berk NSA). NA - P 0 9. 71083 • Qabtle, NC 282721083 Sad btqubiss b: :aped OrrP0 Bat AN - Sat Labe CJy, Ur 8413D.M REASE PAY AT LEAST THIS AWUM Y0Vre behnd th' sk payments Itwe charge off you wcark die to late or mooed payments, fiance Barges wil wnfnue to a=ue Ad now to prevent the from hopperiong Please pay the non omi naynterrt amout on you Statement or give us a cal at 1 800 955 660D Were here to help fake oodrd dyou creditwlh Capital lhre Payments, Credits 8 Tlansactlons 1 26 SEP PAST DUE FEE $3B 00 You account has gorse over ds credt lord. To ereid addYxtel o erbrol fees, plaase pay ercuglt to brig you ball below your credit Imd rnmedalelj, and make we you reman below yeu =1 bad I'lowe be sue to acco rt for any facie puchmw, fees, ad firwce eh rges You were assessed a poet die fee because yalr mnmtm pWmat wee not meowed by the da dote To mood the fee in the hAno, we recommend that you allow at least 7 busress days for your mrantm payment to reach Capid One ® Have, a quovillon about adougeonyewl EXHIBIT refer b to Ing ghls Summary on the beck dyer I staloment or Vert PLEASE RETURN PORTION BELOW WITH PAYMENT OR LAG ON TO W VWVrAPITALONE.COM TO MAKE YOUR PAYMENT ONLINE 7411119 C,api -l?L ?(?y Account Number: 3151 Due Date New Balance Minimum Payment Amount Enclosed Oct. 2T, 2008 C$1,020.78 ( $165.00 U PAYAT LEAST THISAMOUNT #9027640805254722# JEFFREY L QUACKENBUSH 415 3RD ST ENOLA, PA 17025-3126 Jill loll l..11111?11?L?11?II...?ILl1?.lI11l.l?.l...ll?Jll1?1?' 13161 01 1020780075000165002 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 © Moving? Change your address online or on the hack ® Hop save the planet Co paperless © Sign up at www caprtalone corn Capital One Bank (USA), N.A. P.O. Box 71083 Charlotte, NC 26272-1063 Please intake chedts payable to Capitol One Bank (USA), NA and mail with this coupon in the erdosed towelope. PROTHONOTARY CUMBERLAND CO CAPITAL ONE BANK (USA), N.A., Plaintiff, V. JEFFREY L QUACKENBUSH 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, informatioMavina e Dated: Jo son A049 WELTMAN, WEINBERG & REIS CO., L.P.A. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy ??ti??it?? pt 4wr?brr?r???+? ZOiU MICR 22 A 8 ?S Edward L Schorpp Solicitor Capital One Bank (U.S.A.) N.A. vs. Jeffrey L. Quackenbush Case Number 2010-1818 SHERIFF'S RETURN OF SERVICE 03/18/2010 07:03 PM - Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on March 18, 2010 at 1903 hours, she served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Jeffrey L. Quackenbush, by making known unto himself personally, at 415 Third 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. - ?"N 4) N AUGH, DEPU SHERIFF COST: $41.50 March 19, 2010 SO ANSWERS, (;" ? z2/1/ -- RON R ANDERSON, SHERIFF (C C )LIMYSUlte Shenff TeleoSott hr