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Home My WebLink About10-3866 FILED r, t T f ?' - ytil? 2010 1 { 1 FH 2' = 40 _ w" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff No: '6 - 3 no 6 C v,` I -? C/,., VS. JETA COMBS 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. 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 (412) 434-7955 FAX: 412-338-7130 08161252 C N Pit EMR 1-f,. 6& I ,l- -"7 e # y6-y.?5-76 &10- a Y 3 56 3 TN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff vs. Civil Action No JETA COMBS 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 CANNO'T' 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: JETA COMBS 415 HILLSIDE RD NEW CUMBERLAND, PA 17070 3. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXX9042 . 4. Defendant made use of said credit card and has a current balance due of $3817.16 , as of May 12, 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 0.0000 per annum on the unpaid balance from May 12, 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 , JETA COMBS , individually , in the amount of $3817.16 with continuing interest thereon at the rate of 0.000% per annum from May 12, 2010 plus costs. James Wa ro t,42524 WELT WEINBERG & REIS CO., L.P.A. 436 Se e th Avenue, Suite 1400 Pitts r h, PA 15219 (412) 43 -7955 FAX: 41 -338-7130 0816 2 2 C N Pit EMR This law firm is a debt collector attemjtAng to collect this debt for our client and any information obtainecy/will be used for that purpose. Account Previous Balance $1,131-95 Payments, Credits and Adjustments $35.00 Transactions $45.90 Finance Charges $13.39 New Balance $1,156.24 Minimum Amount Due $34.00 Payment Due Due October 23, 2006 't'otal Credit Line $1,200 Total Available Credit $43.76 Credit Line for Cash $1,200 Available Credit for Cash $43.76 AtyourseMce To r 11 Customer Rrhnons or to report a lost or stolen card: 1-800-903-3637 S-11 payman a: Surd arf- t? A=-. Rcraaance Prop 9 C One Bank Capital One P. . Box 70884 P.O. Box 30M Ch.&trq NC 28271-0884 SLC, UT 84130-1285 Importarn Account Information Beginning Oetoba 1st 2006, based on your account activity you may be assessed more than two late, overh=4 or returned dusk fees that occur during any billing period. PLATINUM MASTERCARD ACCOUNT AUG 24 - SEP 23, 2006 Page I of 1 Payments, Credits arsd Adjus-ts 1 22 SEP ELECTRONIC PAYMENT $35.00- Tranactions 2 05 SEP WM SUPERCENTERMECHANICSBURC PA $35.94 3 06 SEP WINE &.SPIRITS 6708 NEW CUMBERLAN PA 4.98 4 21 SEP WINE &.SPIRITS 6708 NEW CUMBERLAN PA 4.99 NOTICE: Look for a new statement design for your Capital One credit card beginning next month. A summary of the key changes will be provided with your new statement EXwTff Finanee Charm Pleaseree n verxride jor tmp atant tnfirmawn ah BA&VLT Aren dt Cax p>Rdrtr WEE go*dto cpp6rdto R P rate E 333 SSS PURCHASES !991.29 .04082% 14.90% 11254 CASH 951 .711 .0408296 14.90% 1.65 SPECLkL R.4NSPMS 1118.49 .00545% 1.99% 1.20 ANWAL PERCENTAGE RATE applied this period 1357% PLLASL RL I LRN Pe1R I10N BLLOIA' N'Il it P:1} MLN 1 0000000 0 ------------ 9042 23 1156240035000034001 8161252 New Balance $1,156.24 Minimum Amount Due $34.00 Payment Due Date October 23, 2006 Total enclosed $ Accoatu Number: 9042 Pfl-t rates 8 dd,- .aid-r, Id.% eel gam -bla 6a t Str,et Ury S- ZIP Home Pl- Alumue P9wae en.>aae? m #9026782503622460# MAIL ID NUMBER Cape=dl One Bank 'ETA COMBS P 0 Sox 70884 411 HILLSIDE RD um 1 1 ut? u? °o NEW CUMBERLAND PA 17070-1863 Charlotte, NC 28272-0884 ? '11?1??IIIIII?IIIIIII11?1'I'IIII11?1'I1?11'I1?'11I11?III?1111? ° '111??'lll???111'111?I?111111I ?'II'l1I?1111?11111??111??1?1?1? Pkwe wnteyorrratmtmt nwnkron yew shark or mo ky order madePayable to C4yosmlOneBank and mail in the rnrlarcd em,& .. r .e PROTHONOTARY CUMBERLAND CO CAPITAL ONE BANK (USA), N.A., Plaintiff, V. JETA COMBS 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: -J ( - Co 7).-) . 4) ?- Margaret Parton A049 WELTMAN, WEINBERG & REIS CO., L.P.A. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff FILcIr~ {~: ' ~~~ti1tr of ~'~e~mb~r1~~,~ "_1~ ~~ ~` '' .:~ I:r1~Y Jody S Smith Chief Deputy ~' -~ ~~ ~ .., ~~ `~,,~~ 2~l0 JJi~~ i 1 Pri 2~ ~-~ Richard W Stewart r_`°'` Solicitor orf;c~ cF '"E sk~R)FF CUI~i. ~.~'U"~Y Capital One Bank (U.S.A.) N.A. Case Number vs. Jeta Combs 2010-3866 SHERIFF'S RETURN OF SERVICE 06/15/2010 07:04 PM -Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on June 15, 2010 at 1904 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Jeta Combs, by making known unto herself personally, at 415 Hillside Road, New Cumberland, Cumberland County, Pennsylvania 17070 its contents and at the same time handing to her personally the said true and correct copy of the same. NOAH CLINE, DEPUTY SHERIFF COST: $43.30 June 16, 2010 SO ANSWERS, ~~`""'., RON R ANDERSON, SHERIFF (c) CountySuite Sheriff, Teleosoft. Inc. fi ~, :'. - rs , Z=~ ~ ~ JUJL 2-~ PM 2~ 2~ _ ~ ... IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CNIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff vs. JETA COMBS Defendant(s) No. 10-3866 CNIL PRAECIPE TO SETTLE, DISCONTINUE AND END WITHOUT PREJUDICE TO REFII,E 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. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412)434-7955 WWR#8161252 NPE ~ s IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANL4 CNII., DIVISION CAPITAL ONE BANK (USA),NA Plaintiff vs. JETA COMBS Defendant(s) Civil Action No. 10-3866 CNIL PRAECIPE TO SETTLE, DISCONTINUE AND END WITHOUT PREJUDICE TO REFILE TO THE PROTHONOTARY OF Cumberland COUNTY: SIR: Kindly settle, discontinue -and end without prejudice to refile the above-captioned matter upon the records of the Court and mark the costs paid. WELTI~CAN, }7dF~~ERC~& )y.EIS CO., L/1~'.A. By: PA LD. # OS 20 WELTM N WEINBERG & REIS CO., L.P.A. 1400 Kop s Building 436 Seventh Avenue Pittsburgh, PA 15219 (412)434-7955 aor+r~oNw~n~ of a~sirw~ww Nonl~ SMI Wayne A. xnaa, Notary PubNc CRy Of h, ~~y ~Y )11tH 29 2014 M e SWORN TO AND SUBSCRIBED before me this ~ day