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Home My WebLink About06-0701 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff No: ols. - 701 CLtJ~L~82-W[ vs. COMPLAINT IN CIVIL ACTION RODNEY W ANDERSON 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 2718 Pittsburgh, PA 15219 (412) 434-7955 FAX: 412-338-7130 04966707 C A Pit KMJ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff Civil Action No 0(.. 701 C:.a,;) 0..-- vs. RODNEY W ANDERSON 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 is a corporation with offices at 6851 JERICHO TURNPIKE #190 SYOSSET , NY 11791 . 2. Defendant is adult individual(s) residing at the address listed below: RODNEY W ANDERSON 668 STATE ST LEMOYNE, PA 17043 3. Defendant applied for and received a credit card bearing the account number 4388641822152554 . 4. Defendant made use of said credit card and has a current balance due of $2895.26 , as of January 20, 2006 . 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 6.000~ per annum on the unpaid balance from January 20, 2006 . A copy of Plaintiff's Statement of Acco unt 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 , RODNEY W ANDERSON , individually , in the amount of $2895.26 with continuing interest thereon at the rate of 6.000% per annum from January 20, 2006 plus costs. c;::>( -) //'" V James WELT , CO., L. P . A. 436 S venth Avenue, Suite 2718 Pi t burgh, PA 15219 ( 1 ) 434-7955 : 412-338-7130 66707 C A Pit KMJ This law firm is a debt collector a empting to collect this debt for our client and any information obtained will be used for that purpose. Your account is delinquent We want to help! ~ ~ ~..~ >t> r;j."irdl. '. --1 To protect your credit with us. you need to make a payment. -7 We can help-but only if j<lu caU us. -1 When you tall, you can make a free ched,'by-ph""e payment. Relllll1 your account to 1000 standing. Ifs up to you to take tn. first step. Call usl 1.800.479.7231 CapltalQne' ~= A<<>O.flS_."" ~ioo.&.i....,.. ~C~~"'olj\llll"""'U T_ 1'iMn<;c~Q $1,~*W ,., $62.00 SJH$ NcwllJllmco Mi",Un_~O\l<\ f'Wme!01lN<o..: SI,Mt_54 1:1."~S<I Mq-15,100) T~C~l.."" r"'III'''ail~Cn.:Ilt ~~li>(c..tI "'~wlabkC~1l futCw ,,- '" \>- ,.., At)VW$GC'Ik. T_",o.--~lIt...~.k.oo.._._4- 1-800-903-3637 flOt....__~.......-l_~........Wi< ..---- s..t..,.--.", ,,_Il#lo'-"t'~ c.,....:ooo_.... to...dn~r Jl;l<Il_,V"'U]}6 iko<l......." c..,iWo...,..,.-_ ",,}.""'bll$ ta"""""V,l,:U:l;ll-JOI$ f.~"~Ullb:r-..... I'llfl<:.rvl<<;nS~~~I(jOOJ9a.-'lJl."'" .m...~'bl ~L pE:>t ~""""'" WO-~'lJl. . , . VlSA G01..D ACCQU'NT .1P.MI"'221~-;:j~ MAllI"APlI: H,lOOJ I"'4ic1u(1 J'.r--u,C,.,.ita..II.vlj,.~.u TI'\Ul~""'" 17 MAR OVEllUMlT ftL \5 At'i\ r.J\1'1TA1, {ffll MOi<oIUtL Y MEM1H::. ftl! U APR PAST OUt FEE UU<l ..00 "'" y""_-.-t.,........,!W1>fUl;\>>""W1Y200J ~~.1AilIl1ll'll ~_)1I'J( ~b1lheohll!4alcofOO1~_ T(),...wlbj,toc:",~ &iw....e..._......s!tAil \'tl<I """""..'--1~4IoyJ~yMltlM1"'CIU<<> ~C~I)/o..&. ,___eII_,.. """"''' C.u, -- -. U,W t~ '00 ".".,.,....,....,.,..,......h~__ ~ c____ flW"Na _ JJlIl CHAIWB ~ }~~ 'lH'I1 ~1\'lWlI, 1J~ 1;11) 1~,,~ - - ^- ~- - AHWAL f'UQtN'TAOlS IlATE ..;litlcllll..~ CapltaIQne' ... l'lt.A$E1U;:nikNffilt1'ION/lliLOllivrntp,l. YMlo-m ., 0000000 0 4388641822152554 15 16S6St006100lti86H>( 1'-,....---..-..............-..-"""" - "" N",..Q~ M,,,im-. ,,_~ h>_DulIOa.te Sf 4J(>_~~ tl,4V..1A M..,-rj,200J T<><J!II_k,~" A_.,N.......... OU.....ll-nlj-1:H~ .., ;"f<'.lI~:t; ~;:-:;n~ 1II"""lInlluJlld l!\.ch:xw4, VA 23Zit \..I,ll,lllllllll",Mll1l1l1,ltu.ll".lImll",ILuUml ~ - " -- .- t9C11CS-il;:HI~llM' w.H,:O W,.,j;,il. .ROO~1' III AtCJ$SCN 6t5 StAH $1: UM:lYI-6 FA nQO-15.l~ Illlll!...Ill....I..I"lI11"",llllHIl..I.J..lI,,',,I,I.llU r ".,..,.,...,.....__-w""~~_......_~k>C>p<W u......wI--'.....~ ~._-~~-~_.~~-----~~--~~_._~~---- } VERIFICATION to unsworn falsifications to authorities, that he/she is The undersigned does hereby verify subject to the penalties of 18 P A. C.S. 4904 relating ~f'< (' A {( ~ 1 \[).\V\ (NAME) K\~LE) of C-~V 1'1<< I DYle D-rI}L, plaintiff herein, that (COMPANY) he/she is duly authorized to make this verification, and that the facts set forth in the foregoing Complaint are true and correct to the best of bislher knowledge, information and belief. ~ , (SIGNATURE) WWR#Dl.jqb~7D7 -to.. n "'-' 0 (.) r'? 8 c (:;::::1 -n c"'" -p 7"- tI\ " .." ---I I,', rl ::I:-n \l \\ ~ O'J n'F I ~9~ ~ v) ~,~,~ ,.L., ," Q -0- t,'.t(~. ~ -..." - -" --,..' ~ r"l i.) " \).) -0 ",'" "\J f'" :0 ,< ~ s- F- e:> ~ G'" -{\ - 1=: -C\ r SHERIFF'S RETURN - REGULAR CASE NO: 2006-00701 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CAPITAL ONE BANK VS ANDERSON RODNEY W RONALD HOOVER , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon ANDERSON RODNEY W the DEFENDANT , at 1954:00 HOURS, on the 10th day of February 2006 at 668 STATE STREET LEMOYNE, PA 17043 by handing to SHARON ANDERSON, WIFE 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 Affidavit Surcharge So Answers: 18.00 14.08 .00 10.00 .00 42.08 ~-?"'a.":::-~.r:f:-',.,. "' .,"",..,t.:-.,.........'.,'-- ,!--:~ .r:.-<.A:2;4-~"'-~ ,.~ . R. Thomas Kline 02/14/2006 WELTMAN WEINBERG REIS Sworn and Subscribed to before By: t~4' Deputy Sheriff me this IJ- day of -71l,,-,- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK. Plaintiff No. 06-701 CIVIL TERM vs. PRAECIPE FOR DEFAULT JUDGMENT RODNEY W ANDERSON Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: WILLIAM T. MOI.CZAN, ESQUIRE PA 1.D.#47437 Weltman, Weinberg & Rcis Co., L.P.A. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, P A 15219 (412) 434-7955 WWR#04966707 Judgment Amount $ 2923.34 THIS LAW FIRM IS ATTEMPTING TO COLLECT THIS DEBT FOR ITS CLIENT AND ANY INFORMATION OBTAINED WlLL BE USED FOR THAT PURPOSE. .. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY. PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK. Plaintiff vs. Civil Action No. 06-701 CIVIL TERM RODNEY W ANDERSON Defendant PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter Judgment against the Defendant. RODNEY W ANDERSON above named. in the default of an Answer, in the amount of$2923.34 computed as follows: Amount claimed in Complaint $2895.26 Interest from 1/20/06 at the legal interest rate of 6.00% per annum $28.08 TOTAL $2923.34 I hereby certify that appropriate Notices of Default, as attached have been mailed in accordance with I' ^ R.C.p. 237.1 on the dates indicated on the Notices. WELTMAN. WEINBERG & REIS CO., LPA Bv t~1dT WILLIAM T. M LCZA , ESQUIRE PA 1.0.#47437 Weltman, Weinberg & Reis Co., L.P.^. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, P A 15219 (412) 434-7955 WWR#04966707 Plaintiffs address is: c/o Weltman. Weinberg & Reis Co.. Lp.A., 2718 Koppers Building. 436 7'h Avenue, Pittsburgh, PA 15219 And that the last known address of the Defendant is: 668 STATE ST LEMOYNE.pA 17043 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff Case # h(",-}"6\ - L\VI L..-,?jZ.~ RODNEY W ANDERSON Defendant(s) IMPORTANT NOTICE TO: RODNEY W ANDERSON 668 STATE ST LEMOYNE,PA 17043 Date of Notice: WWR#: 04966707 7/ ~ / C)(-.o { YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE FOLLOWING OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. 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 BRODT, ESQUIRE 42524 WEINBERG & REIS CO., L.P.A. PERS BLDG, 436 7TH AVE. GH, PA 15219 IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY. PENNSYLV ANIA CIVIL DIVISION CAPITAL ONE BANK, Case no: 06-701 CIVIL TERM Plaintiff NON-MILITARY AFFIDAVIT vs. RODNEY W ANDERSON Defendant The undersigned, who first being duly sworn, according to law, deposes and states as follows: That he/she is the duly authorized agent of the Plaintiff in the within matter. Affiant further states that the within Affidavit is made pursuant to and m accordance with the Servicemembers' Civil Relief Act (SCRA), 50 U.S.C. ApI'. S 521. Affiant tllrther states that based upon investigation it is the affianfs belief that the Defendant, RODNEY W ANDERSON is not in the military service. Affiant further states that this belief is supported by the attached certificate from the Defense Manpower Data Center (DMDC), which states that the Defendant, RODNEY W ANDERSON is not in the military service. Further Affiant sayeth naught. M.d.:/~v/~ _ AFFIANT ' r-- SW..O. RN ~ S. U.. BSCR. /BED in my prcsence.tl..'iS xl, day ot fv'(..('r ___,.. ~JJ:Jt; . :II ---.'.- ~ \: ,/ ./ j /NOTARY PUBLIC / This law firm is a debt collector attempting to collect this debt for our client and any information obtained will he used for that purpose. Rej:[uest for Military Status Page 1 0 f 1 Department of Defense Manpower Data Center 8' /' ',~," Military Status Report '.i .,)' Pursuant to the Service Members' Civil Relief Act MAR-20-2006 13:57:30 -<r( Last Name First/Middle Begin Date I Active Duty Status I Service/Agency ANDERSON RODNEY W Based on the information you have furnished, the DMDC does not possess any information indicating that the individual is currently on active duty. Upon searching the information data banks of the Department of Defense Manpower Data Center, the above is the currcnt status of the individual, per the Information provided, as to all branchcs of the Military. rf::'?W ~-- (')-\ 6-- J~ d Robert 1. Brandewie, Director Department of Defense - Manpower Data Ccnter 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense Emollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The Department of Defense strongly supports thc enforcement of the Service Members Civil Relief Act [50 USCS Appx. 99501 et seq] (SCRA) (formerly the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you arc most strongly encouraged to contact us by phone at (703-696-6762). We will thcn conduct further research. Your failure to re-contact DMDC may cause provisions of the SCRA to be invoked against you. This response reflects current active duty status only. For historical information, please contact the military services SCRA point of contact. See: http://www.defenselink.mil/faq/pis/PC09SLDR.html. WARNING: This certificate was provided based on a namc and Social Security number (SSN) provided by the requester. Providing an erroneous namc or SSN will cause an erroneous certiticatc to be provided. Report fD:BUFKlLPCLNP https://www.dmdc.osd.mil/scralowalscra. prc _Select 3/20/2006 C 1'i D -<.0- -D ~ 'L C> C> ~ - ~ ..:r ~ '" C) ?s VI. (. - , w -<:::. -~' , ,-4 1: -r -.c) 'I' ::;-,. ;::i\ ~ (J :"'~I ~ -.() f"-~) ~ t- \ :~) ~ C..") .' IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY. PENNSYLV ANIA CIVIL DIVISION CAPITAL ONE BANK, Plaintiff vs. Civil Action No. 06,701 CIVIL TERM RODNEY W ANDERSON Defendant NOTICE OF JUDGMENT OR ORDER TO: () Plaintiff (xx) Defendant ( ) Garnishee You are herehy notified that the following Order or Judgment was entered against you on --fY1~:?.9, ;y.>Db (xx) Assumpsit Judgment in the amount of$2923.34 plus costs. Trespass Judgment in the amount of$~. plus costs. () Ifnot satistied within sixty (60) days, your motor vehicle operator's license and/or registration will be suspended by the Department ofTranspona1ion. Bureau of Traffic Safety. Harrisburg, PA. (xx) Entry of Judgment of () Court Order () Non-Pros () Confession (xx) Default () Verdict () Arbitration Award Prothonotary Bv: j'#, , PRO%~NOTARY RODNEY W ANDERSON 668 STA TE ST LEMOYNE,PA 17043 Plaintiffs address is: c/o Weltman, Weinberg & Reis Co., L.P .A., 2718 Koppers Building, 436 7th A venue, Pittsburgh, P A 15219 1-888-434-0085