The URL can be used to link to this page

Home My WebLink About10-5198a?D!0 106, to F..? ?1,?;,; ?Iyj ! : SO I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff No: (O _Jri98 c:v?l?pr?'? VS. COMPLAINT IN CIVIL ACTION SONAL A HALL 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 08234263 C N Pit EMR O *ga.oo Po" e,-r 4(04 (491 04 o'94W87 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff vs. Civil Action No SONAL A HALL 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 5100 PEACHTREE INDUST.BLVD NORCROSS , GA 30071 . 2. Defendant is adult individual(s) residing at the address listed below: SONAL A .HALL 880 CROOKED STICK DR MECHANICSBURG, PA 170503. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXX6838 4. Defendant made use of said credit card and has a current balance due of $2899.45 , as of June 22, 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 19.900% per annum on the unpaid balance from June 22, 2010 . A copy of Plaintiff's Statement its 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 , SON4 A HALL , individually , in the amount of $2899.45 with continuing interest thereon at the rate of 19.900. per annum from June 22, 2010 plus costs. James ro t,42524 WELTMAN, NBER.G & REIS CO., L.P.A. 436 Seve h venue, Suite 1400 Pittsbur h, A 15219 (412) 43 -7 55 FAX: 41 -33 -7130 0823426 C Pit EMR This law firm is a debt collector attemptibg/to collect this debt for our client and any information obtained w be used for that purpose. FYevioue ee{atlce FINANCE Payments & Cre6F? CHARf3E Tranuction6 New Balarwe 6linim(m Payment Due Date $2,366.26 - $0.00 * $47.15 + $39.00 = $2,454.41 $493.00 Sep. 30, 2009 Aug. 06, 2009 - Sep. 05, 2009 iage 1 Of 1 Y KE 9 PAY AT LWTHS AMO Mf An Platinum Account You're beNnd by w payment) If we charge off your accost due to late or mis3ecipsyrnent3 finance asommo4ox charges will oorhwe to accrue Act now b prevent ft from happenng Please pay the mrrnun Your Account lllfarrnallon IIEMrAnDS Payment antrum on you statement co We w a call at 1800 956 M We're here b help Take control of you credit with Crplal One TOTAL CREDIT LINE $2,00000 TOTAL AVAILABLE CREDIT $000 Rewards Sulamiq CREDIT LINE FOR CASH $2,00000 Prevcusavalablebakrce 881 AVAILABLE CREDIT FOR CASH $000 Earned to penod 0 (rdb b li w cl. poabd dmg f big qb) Avadd* 0denoe 881 Fnaltce Charges (Please see remse fa mpbrtant dwinalon) Pawnents Credits 3 Adiuetlnents Balance rate Perodc Corrop ning FNVACE applied b rale APR CHUM Transaclim Purchases S'L,39B 49 006342% D 2 15% 54715 1 31 AUG PAST DUE FEE S3900 Cash 90 00 0 06342% D 2$15% S000 AWAAL PERCENTAGE RATE applied this perlom 23.15% 0 PWOn**at ormalP4PW-tb: Capifd Oro Be* (lSA), NA • P 0 Bw 710830 Owbib, NO 1093 A se kKilim aa. Capital One• P 0 Boa 30PB5 • Sat Lakes City, UT 841M.VM ® Iaogge your Reearb orlne is by vis" a Cdr 278MM ® Have a question about a dwge on your afafened? Please refer b the Bing RKJtts $umma on ere back of your staterneM or visd www.®oslab?he.carrhrdr9arMs PLEASE RETURN PORTION BELOW W1TH PAYMENT OR LOG ON TO W W W CAMALONE COM TO MAKE YOUR PAYMENT ONLINE ATh At Your SWAM- Go b mm.comilaimarn "wwae)ar m murk O .Cat1M090R3637areportabitorsUkn d,wd orVo*bO IWW rlaldom You account has gone ores is lied hint To a4 d adStord overland fees, you sho lit pay more than ft Muhmum Payment Please pay enough b brag your womnt bdence below your lied Imd mmedAsy, and mace sure your axount balance romans balm your lied limit Please be we the amount you pay womb for any Wepurd ow. fees, and finance charges You were assessed a pest die fee l Kww you marnrm payment was not received by the due date To un d the fore in Ce Wire, we re mmerd tlhd you allow at least Ttweness drys for your mramum payrnent to reeds Cmw Ons Irnportant change to your Rewards travel mclerrptons bqm ig Febmay 2010 A bo6aT fee msy apply wfen you cal our Rewards Con* b book travel usrg you rewards However, you can still book travel online for free at www cupildone corn 1 838 05 2454410073000493004 8234263 Cap" AcwuM Nu 38 Due Date New Balance MInI Payment Amount Enclosed Sep. 30, 2009 $2,454.41 ? -00 PL?gSE PAY AT (FAST iHISAMOUNT #9024947450238634# SONAL A HALL 660 CROOKED STICK DR MECHANICSBURG, PA 17050-229L 1111111'III'111'II"I'IIIIylylLvrarlrl'1111111°1II111111111'I GO GREEN. SAVE GREEN! Pay online and save money on stamps. Sign up at www capdalone com Capital One Bank (USA), N.A. P.O. Box 71063 Charlotte, NC 26272-1063 1111111'Ill"11111'11'1111111x'111111"11'1'111'11"11111111'1111 Please make diedc pay" to Capital One Bank (USA), NA. and mad with this Coupon in the enclosed erwekape. EXHIBIT l PROTHONOTARY CUMBERLAND CO CAPITAL ONE BANK (USA), N.A., Plaintiff, V. SONAL A HALL Defendant(s). VERIFICATION The undersigned does hereby verify subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities, that he/she is an authorized agent of CAPITAL ONE BANK (USA), N.A., Plaintiff herein, and that he/she is duly authorized to make this Verification, and that the facts set forth in the foregoing Complaint in Civil Action are true and correct to the best of his/her knowledge, information and belief. Dated: Margaret Parton N00000033135807 371280736 A049 WELTMAN, WEINBERG 8$ REIS CO., L.P.A. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff r ~~tr t~uu~bp~~~~ f __ `,~. .. ~,,.. Jody S Smith Chief Deputy G ~° ~ yt ;~ Richard W Stewart ~ ~~- a0~0 AUG ~1 ~K <<: ~~ Solicitor t~lcecr T~EsK_~irF ~ii.``'~ i... _ ;,~~~ ~~~ ~_ Capital One Bank (U.S.A.) N.A. Case Number vs. Sonal A. Hall 2010-5198 SHERIFF'S RETURN OF SERVICE 08/13/2010 07:38 PM -Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on August 13, 2010 at 1938 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Sonal A. Hall, by making known unto himself personally, at 880 Crooked Stick Drive, Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time handing to him personally the said true and correct copy of the same. ~~~,~--~ RYAN BUR EPUTY SHERIFF COST: $37.00 August 16, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF (o) CountySuite Shenfl. Teleosoft, Inc. ~'t'_; C~~'~' ~,~~~~Pat ~~i ~si's ~i; t ~ _ ._ . Li _.~,~ ~..rS SQL"~_,~, r t ' ": ~- W THE COURT OF COMMON PLEAS OF CUMBEKLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff vs. SONAL A HALL Defendant(s) No. IO-5198 CIVIL TERM PRAECIPE TO SETTLE, DISCONTINUE AND END WITHOUT PREJUDICE TO REFILE 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#8234263 NPE IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff vs. Civil Action No. 10-5198 C1VlL TERM SONAL A HALL Defendant(s) 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. _ WELTM N, WEINBERG &REIS CO., ...A. n~-~-- By: Lyndsay E Roy land, squire PA LD. #2055 0 WELTMAN, ~ EINBERG &REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 SWORN TO AND,~UBSCRIBED before me this r ~ day COMMONWEALTH OF PENNSYLVANIA ,, Notarial Seat of 010 Wendy L. Gault, Notary Public City of Pittsburgh, ptlegheny County - ' l Y~________ . My Commission Expires ]uly 15, 2014 .J---~---'~ .- Member. PennsvlvaNa A4soriation of Notaries -'~'ARY