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Home My WebLink About11-4415 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff vs. CHRIS MANSFIELD Defendant No : ) I- L4 L/1 5 b yl COMPLAINT IN CIVIL ACTION 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 07410693 C N Pit CXC d 0 M -Z 99. 60 ?c1 p- it a59 3003 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff VS. Civil Action No CHRIS NLkNSFIELD 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) 249-3156 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: CHRIS MANSFIELD 308 S SPRING GARDEN ST CARLISLE, PA 17013 3. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXX5473 . 4. Defendant made use of said credit card and has a current balance due of $2488.90 , as of May 09, 2011 . 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 24.400% per annum on the unpaid balance from May 09, 2011 . 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 , CHRIS MANSFIELD , INDIVIDUALLY , in the amount of $2488.90 with continuing interest thereon at the rate of 24.4006 per annum from May 09, 2011 plus costs. James War ro t,42524 WELT WEINBERG & REIS CO., L.P.A. 436 S v nth Avenue, Suite 1400 Pitts gh, PA 15219 (412 34-7955 FAX- 22-338-7130 074 0 93 C N Pit CXC This law firm is a debt collector atte ting to collect this debt for our client and any information obtaine will be used for that purpose. FINANCE Previous Balance Payments & Credits CHARGE Transactions New Salarce Minimum Payment Due Date $1,265.29 - $0.00 * $27.06 + $39.00 =C$ ,331 .35 $199 00 Oct. Or., 20081 i Aug. 06, 2008 -Sep. 05, 2008 Page 1 of 1 (Asa Platiralm Aaolnt 4Ba2J171i7A6.6473 Your Account Information TOTAL CREDIT LINE $75000 TOTAL AVAILABLE CREDIT $0.00 CREDIT LINE FOR CASH $50.00 l AVAILABLE CREDIT FOR CASH $000 PEAR PAY AT LEAS7 THIS AMOUNT You're behind by five payments We've permanently revoked your charging prMleges If you continue to mss payments your account is at risk of beng charged off Please don't kl Ova happen If yodre feeirg v e whelrncl, call us at 1 800 955 66DO Well work with you to resolve this matter Payments. Credits & Adustments Transacilo w 1 05 SEP PAST DUE FEE $49.00 Urudar lams prevohshy disclosed to you, sorry or all of your Annual Percartage Rates (APRs) have been m aamd %m your aCm" was past die twm n the past 12 talhg cycles If your rates have already, increased, subsequent deingienctes edended the duirahon of the ncreased rates Remember If we receive your minimum monthly payment on time for 12 consecutive bilrhg cycles, this account will be renewed for a possible return to you Plor Ontrod.ictory APR. You account is 90 days past die and your Payment Protection coverage has been suspended. As slated in your rr*ment Protection agreenart, your cevemge mid monthly charge will be reinstated once your account is no longer 90 days past due You may all be eligible fa benefits to be pad to you account for loss events described in you Payment Protection rgreerrmt Cal Slonebrrdle Benefit Services at 198&5275904 to we if your situation qualities for benefits You account has gone over ids asst III To avoid addhonal over" fees, please pay enough to bring your balance below your credit Imes immediately, and make sure you roman below your credit limit Please be sure to account for any future p(lrclgses, fees, and finance charges You were assessed a past die fee because your minimum payment was not received by the due data To avoid this fee in the futse, we recommend that you allow at least 7 business drys for your rnnmum payment to reach CVU One Finance Charges (Please see reverse for Important information) Balance rate Periodic Corresponding FINANCE applied to rate APR CHARGE Purchases $1,279.57 005822%D 2490% $27.05 Cash $000 0.00822% D 24 W% $000 ANNUAL PERCENTAGE RATE applied this period: 24.80% 91c At Year Service - Go b mmowitabne.com b manage your accent, m Cal 14W_ni3837 b retort a bet ar sin cad or sW* b Cussxrer Releems 0 Pay Online at wAw.ceofti oemm or nalymrPwrrrat b: CaotN One Boric (USA), NA • P 0 Bw 70884 • Cnattle, NC 28272-M Send IFKF*in to: Coital Ore- P 0 Bw 30 5 - Set Lake Oly UT 8413D.M ® Have a gwstlen about a charge on your slatomenrt4 Please refer tote Bring Rights Summary on the back ofyour statement or vusrt www.mortaloneoombkoutes PLEASE RETURN PORTION BELOW WITH PAYMENT OR LOG ON TO WWW.CANTALONE.COM TO MAKE YOUR PAYMENT ONUNE ?Of7G'? wnah h ?? r„?, ,.aileh7. New Balance Minimum Payment Due Date $1,331.35 $199.00 Oct. 06, 2008 PLEASE PAY AT LEASE THISAMOUNT Amount Endosed 0 4862367187955473 05 1331350070970199007 Capital One Bank (USA), N•A- P•0• Box 70664 Charlotte, NC 26272-0664 7410693 Illllllllllrll'Illll'I1111111111111111111Illlhll'1'I1I11'Iltll'11 Account Number. 4862-3671-8795-5473 Pieria print address or phone number changes below using blue or Wads ink Nome Phone A7tenwte vnorm E-mm7addirsr p #9025066544784955# MAIL ID NUMBER CHRIS MANSFIELD 306 S SPRING GARDEN ST CARLISLE, PA 17013-2554 PIIIPIIP-l-16l-II I I11nIIl.,INPnluugl-llh°IIIrIIIIII Please write your account number on your payment made payable to Capital Dne Bank (USA), NA. and mail with this coupon in the enclosed envelope. EXHIBif CAPITAL ONE BANK (USA), N.A., Plaintiff, V. CHRIS MANSFIELD 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 and belief. Dated: 1 ti Sandra Davis N00000029142819 785138587 A049 WELTMAN, WEINBERG & REIS CO., L.P.A. SHERIFF'S OFFICE OF CUMBERLAND COUNTY r i.'v;' Ronny R Anderson Sheriffy?, of ?uubrr/ i t Jody S Smith' 'U5 14 P I: Chief Deputy Richard W Stewart ?EH?SY?VA, Solicitor Capital One Bank (U.S.A.) N.A. Case Number vs. 2011-4415 Chris Mansfield SHERIFF'S RETURN OF SERVICE 06/14/2011 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Chris Mansfield, but was unable to locate him in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant Chris Mansfield. Request for service at 308 S. Spring Garden Street, Carlisle, Pennsylvania 17013 the Defendant was not found. The Carlisle Postmaster has confirmed, Chris Mansfield has moved and left no forwarding address. SHERIFF COST: $39.00 June 14, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF QN C; tip; l °I? - I p} II: ?a f CUi,-IBERLAND COUNTY WELTMAN, WEINBERG & RE ?CKSoLP:'1 A BY: Sarah E. Ehasz Attorney for Plaintiff(s) I.D. No. 86469 436 Seventh Avenue 1400 Koppers Building Pittsburgh, PA 15219 Phone: (412) 434-7955 Fax: (412).338-7130 File # 7410693 SEE/ABR CAPITAL ONE BANK (USA),NA Cumberland County Court of Common Pleas vs. No.: 11-44:5 CIVIL CHRIS _MANS, ILLD PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly (5s;aiss the above matter without prejudice . WELTMAN, WEINBERG EIS CO , L.P.A. By Sarah E. Ehasz, Esquire Attorney for Plaintiff 111111111111111111111 1111P1111 1111111111111111111111111I I I 111111