HomeMy WebLinkAbout05-5184
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK
Plaintiff
No. ()~ - .s/ cf4
{I~d T~
vs.
COMPLAINT IN CIVIL ACTION
BETTY E. ARNOLD
Defendant
FILED ON BEHALF OF
Plaintiff
COUNSEL OF RECORD OF
THIS PARTY:
William T. Molczan, Esquire
PA I.D. #47437
WELTMAN, WEINBERG & REIS CO., L.P.A.
2718 Koppers Building
436 Seventh A venne
Pittsburgh, P A 15219
(412) 434-7955
WWR#04219869
'.
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA
CIVIL DIVISION
CAPlT AL ONE BANK
Plaintiff
vs.
Civil Action No. .
BETTY E. ARNOLD
Defendant
COMPLAINT IN CIVIL ACTION 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 tiling 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
HA VE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
(717) 249-3166
COMPLAINT
Plaintiff is a corporation with offices in 6851 Jericho Turnpike #190, Syosset, NY 11791.
1.
2.
17257.
Defendant is an adult individual residing at 14 Apache Drive, Lot 134, Shippensburg, P A
3.
Defendant applied for and received a credit card issued by Plaintiffs assignor bearing the
account number 4388641567577569.
4. Defendant made use of said credit card and has currently a balance due and owing to
Plaintiff, as of September 29, 2005, in the amount of $2,373.46.
5. Defendant is in default of the terms of the cardholder Agreement having not made monthly
payments to Plaintiff thereby rendering the entire balance immediately due and payable.
6. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed and/or
refused to pay.
WHEREFORE, Plaintiff demands Judgment in its favor and against Defendant, Betty E. Arnold
individually, in the amount of $2,373.46 additional interest at the legal interest rate of 6% per annum from
the date of judgment plus costs.
,
THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED
SHALL BE USED FOR THAT PURPOSE.
WELTMAN, WEINBERG & REIS, CO., L.P.A.
~
William T. Molcz ,Esquire
PA 1.0. #47437
WELTMAN, WEINBERG & REIS CO., L.P .A.
2718 Koppers Building
436 Seventh Avenue
Pittsburgh, P A 15219
(412) 434-7955
WWR#:04219869
,
VERIFICATION
The undersigned does hereby verify subject to the penalties of 18 P A.C.S. 94904 relating to
agent
(Title)
of
Melissa Lattimer
(Name)
Capital One , plaintiff herein, that
( Company)
unsworn falsifications to authorities, that he/she is
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.
'illli~
(SIgn ture)
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SHERIFF'S RETURN - REGULAR
CASE NO: 2005-05184 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
CAPITAL ONE BANK
VS
ARNOLD BETTY E
KENNETH GOSSERT
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE
was served upon
ARNOLD BETTY E
the
DEFENDANT
, at 1902:00 HOURS, on the 13th day of October ,2005
at 14 APACHE DRIVE
LOT 134
SHIPPENSBURG, PA 17257
by handing to
BETTY ARNOLD
a true and attested copy of COMPLAINT & NOTICE
together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Postage
Surcharge
So Answers:
18.00
18.24
r~~
R. Thomas Kline
10.00
.00
-4 6 .24
10/17/2005
WELTMAN WEINBERG REIS
me this .J-. (
day of
Sworn and Subscribed to before By:
(
.....
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA
CIVIL DIVISION
CAPITAL ONE BANK
Plaintiff
No. 05-5 I 84CIVIL
vs.
SUGGESTION OF BANKRUPTCY
BETTY E ARNOLD
Defendants
FILED ON BEHALF OF
Plaintitl
COUNSEL OF RECORD OF
THIS PARTY:
James C. Warmbrodt
PA I.D #42524
WELTMAN, WEINBERG & REIS CO., L.P.A.
2718 Koppers Building
436 Seventh Avenue
Pittsburgh, P A 15219
(412) 434-7955
WWR#04219869
..
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK
Plaintiff
YS.
Civil Action No. 05-5 \ 84CIVIL
BETTY E ARNOLD
Defendants
SUGGESTION OF BANKRUPTCY
TO PROTHONOTARY:
AND NOW comes Plaintiff, by counsel, Weltman, Weinberg & Reis, Co., L.P.A. to advise this Honorable
Court that the above named Defendant, BETTY E ARNOLD. has tiled a Chapter 7 Bankruptcy in the United State
Bankruptcy Court t()r the MIDDLE District of Pennsylvania at Bankruptcy Case Number 05-09915, and
accordingly, all proceedings in this Court are stayed pursuant to 11 U.S.C. ~ 362.
WELTMAN, WEINBERG & REIS CO., L.PA
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