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Home My WebLink About06-1136 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff No: (ic- /l3~ &~ vs. COMPLAINT IN CIVIL ACTION KEVIN T BRIDGEFORD 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 04966658 C A pit WLG IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. Civil Action No KEVIN T BRIDGEFORD 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(sl residing at the address listed below: KEVIN T BRIDGEFORD 704 LOUISA LN MECHANICSBURG, PA 17050 3. Defendant applied for and received a credit card bearing the account number 4388641629250817 . 4. Defendant made use of said credit card and has a current balance due of $2468.41 , as of February 14, 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 25.900% per annum on the unpaid balance from February 14, 2006 . A copy of Plaintiff's STATEMENT OF ACCO UNT is attached hereto, marked as Exhibit "1" and made a part hereof. 1< 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 , KEVIN T BRIDGEFORD , INDIVIDUALLY , in the amount of $2468.41 with continuing interest thereon at the rate of 25.900% per annum from February 14, 2006 plus costs. This law firm is a debt collector att pting 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! -7 To protect'/<lur credit with us, you need to make a payment -7 We can help-but only if you call us. ~ When you call, you can make a free check-by-phone payment. ~ - , ,,"\a\I2~ ~ call1~ Return your account to good standlns. It's up to you to take the first step. Cau usl 1-800-479-7231 ~ CapllalOne. VISA GOt.D ACCOUNT OU-6o!16.29'tii.o117 MAR :U. APR 11, l.lm 1'1&<'10(1 AllCllu.tS.....,. PreviouoBlllan<:c ~mcn!:S.CIlldUslltldA.<\j\lSlrna'l13 TJ'1Ill,IIactillD.! FiMlIcc 0Iule.. 'l.YDIeatf.ClCdiuu4 A.dj~bAQU NcwBllllACC Minimum Amount 0... ~",",nIDucDatc $1,941.8] UO 564.00 $4J.16 S2,O~1_69 $l,Ml.69 Mly21,2001 Tr.uhl;lio.1 22 MAR QVERLIMJT FEE 2\....MI, PAST DUE fEE Sl'l,OO lS.QO TOlaJCredil Line TQlalAv.;l.bleC",dic Credit Li""forCub Avlil.blcerodil CarC..1t """ '.00 $1.1lOO '.00 "l'Ollr~llOdll$yaurll<<ountlllL'lbcenl'lQivcd.YO<ll"IlCCOUIlI....ilIbeclolll"WMJljl~.R1bl1llUlCli. Villi! then, )'00 will COOltlnuoo t,O rtQ&,vC)tataJI01ltl and IDU:lI COIlIlIllle 10 make payments. All lQrnl IItd <XJnditions orlM awount will.lpplywhiJe I balan"rem1lins. Pk:IISCKllIcmber 10 ClI.t)'Ou,( oard! UId \:III\Cdal\ 1Ihorp...l\ich~l:Bllybilllo)'ourlCCO""l. 'l'OIlwc:rc-..edaputducfcco(S3S,OOol104/lI/2003 ~yoIII'mjnimwn pll)'1llenlw&1I101 J'IlCeivcdb1the dllCdll\.tof04J2lnool. T<>Il"'e\<l1b\3 f"inlll~ future, w~I1lCOlIlIllOl1d tbU you ll.lJow lit Jellrt 7 bualnell dl)" (Qr YDur Pl)'mCJlIIll rQch C&pl1aJ One. AI)'O"'lRrvice Ta<flICof\ll_RcrlliDno......""""'.I..............-.t. 1-800-903-3637 r"'frec<lll.i.."""'UItC....ioaad~<_afl'<<t.lo.t.""lD.. ......,.......ro...OClftI &=4~1'" ^hn:RcmiIlan",,1'nK:cain1 C...ilOlOll<Scr;io!:. p,o, Bu.I'147 Ri""...OOMI. V"'1.l27~ S_i.......ria..' c.,.olOnoSan1.... f_O,am.'~I' Ri""........v...V21l.~1j l.pon.nl A_...U.torm.uo. rorJetYl~JDSpanilh,pl_AIl{lllOJ929-1J}7.1'a11 _.k.lnenE~1.polfl.orrn....Qucloo..n9-llJ1. Flo_cC"lIca PI___v.J.ftJt...,.,.,."inll>l",oIit>D ! ~ I'tIR.CHASIlS ""'. -- ~ .,oM.. - I\.'~.n ,~ $)17-2' .tl7096% e_ m 13.90% H,9G% '\NANCE CHAROII D'" ~" ANNUAL PI!JlCENTAGII RATB ",U"'"ai.pcri04 2~.90% ... Pl.EASERETUltNPORTrONBRLQWWrrnI'AYMEN't ~ CapitaIQne' 0000000 0 4388641629250811 21 20516901Q00020S16'B TolltcncJ...ed AcQ)lIotN....l>or. :$10'1.69 $1.0S1.69 May2J,200J ,-,.......m,-___.-,po_oWf_"'__ Ncwlbl'n~ Minimum MOWll Due hymCfll Due Date - I "3"-6<116-'92'_0111 o. .. "'. .. -,- ^-- ~A_ . .., ;~ ~ taBlo" o.;~ldB7a~ 1ll1ll",lItl.tl".1II Richllnr.d, V).. 2~216 11.I.lnU."I,llml,II..II...Il".Il.IIl1u.lIu.1I111111ll1 - -- : ;;; ~ - .... 1tS\)112391572e"395j1 MIL ID KHmER KEVIN T BIl1DGErQRll H 02 l,E:SADA OR APT 21,. BA.LT!~IU': Kl 212H .-1919 11I1,ltullul.l.IIIIII..I,IIIII.IIlI,.III,ll1ul.lu,Il".U1 r fJusc "';1# J">'V-.-u".....bcr ...JOIK~"'"'tl'f_J''''*''....d.parol* toCI.pM OI/C' BatIIr."d ....;/ ilIlMtltlCto.dcllW<f"'. I VERIFICATION -~Q~ (TITLE) The undersigned does hereby verifY subject to the penalties of 18 P A. C.S. 4904 relating to unsworn falsifications to authorities, that he/she i~1 ..L>l\ ~ S \ C ( : Q ~ \ (NAME) o Yl~ lr<Z\l/L, plaintiff herein, that (COMPANY) of C<1Z-f~\ he/she is duly authorized to make this verification, and that the facts set forth in the fi egoing Complaint (SIGNATURE) are true and correct to the best of his /her knowledge, information and belief. WWR# oq 9 b bbS6' ~~~D -~~ ...l ~. -+..,..s:, 0" '-'- -c-. 1..") : ~::;:..U d:'- - 'j i.J"', '^ \ cY r-...., ~ -" ,... "-) 7'':) ( 'j SHERIFF'S RETURN - REGULAR CASE NO: 2006-01136 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CAPITAL ONE BANK VS BRIDGEFORD KEVIN T BRIAN BARRICK , Sheriff or Deputy Sheriff of cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon BRIDGEFORD KEVIN T the DEFENDANT , at 1946:00 HOURS, on the 15th day of March , 2006 at 704 LOUISA LANE MECHANICSBURG, PA 17050 by handing to KEVIN BRIDGEFORD a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 21.12 .00 10.00 .00 49.12 ~~~.,~~ R. Thomas Kline me this ;lt~ day of 03/16/2006 WELT~:WEINBER~S~c Deputy Sheriff Sworn and Subscribed to before ~~~AD ,r Pro ary; , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff No. 06-1136 CIVIL vs. PRAECIPE FOR ENTRY OF JUDGMENT BY CONSENT KEVIN T BRIDGEFORD 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 Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#04966658 ~ IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. Civil Action No. 06-1136 CIVIL KEVIN T BRIDGEFORD Defendant PRAECIPE FOR JUDGMENT BY CONSENT TO THE PROTHONOTARY: Kindly enter Judgment against Defendant, KEVIN T BRIDGEFORD, in the amount of $2468.41 plus costs, based upon the consent of the parties. CONSENTED TO: WELTMAN, WEINBERG & REIS CO., L.P.A., KEVIN T BRIDGEFORD, By: ffA; Attorney for Plaintiff By:l~~/~ ~7?~/ Defe t WWR#04966658 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. Civil Action No. 06-1136 CIVIL KEVIN T BRIDGEFORD Defendant STIPULATION OF THE PARTIES FOR PAYMENT AND FOR THE ENTRY OF JUDGMENT BY CONSENT TO THE PROTHONOTARY: Kindly enter Judgment in favor of Plaintiff and against the Defendant, KEVIN T BRIDGEFORD, above- named, in the amount of $2468.41 pursuant to the Stipulation of the Parties for Payment and for the Entry of Judgment by Consent, as follows: I. Defendant admits indebtedness to Plaintiff in the amount of $2468.41 with continuing interest thereon at a rate of25.90% per annum plus costs from FEBRUARY 14,2006. 2. To secure the repayment of said indebtedness, Defendant agrees that Judgment by Consent will be entered in favor of the Plaintiff and against the Defendant, KEVIN T BRIDGEFORD, in the amount of $2468.41 plus continuing interest thereon at the rate of25.90% per annum from FEBRUARY 14,.2006 and costs. 3. Plaintiff agrees not to execute on its Judgment so long as Defendant causes to be delivered to Plaintiff the following payments in full by 12:00 NOON on the following dates: (a) $100.00 due by 5/25/06; (b) $100.00 due on the 25TH day of each consecutive month thereafter until the Judgment amount plus accrued interest and costs are paid in full. . 4. All payments are to be made payable to the order of "CAPITAL ONE BANK" 5. All payments due under this agreement are to be received at the offices of Weltman, Weinberg & Reis, Co., L.P.A., 2718 Koppers Building, 436 Seventh Avenue, Pittsburgh, PA 15219. 6. In the event of default, each payment received shall be first attributed to costs, interest and then to principal. 7. Time is of the essence of this agreement and should the Defendant fail to have in the hands of Plaintiff or Plaintiffs counsel any payment in full within five (5) calendar days of the stated due date, then Plaintiff shall be immediately free to issue Execution as well as pursue all other remedies, in law or in equity, to collect the full balance of the Judgment entered hereunder plus appropriate additional interest and costs. 8. No act or omission of the Plaintiff, nor of anyone alleged to be acting on its behalf, shall constitute a waiver, estoppel, or any other excuse for non-performance of any duty undertaken by the Defendant in this Stipulation which the parties agree is final and complete. 9. Intending to be legally bound, the parties set their hands and seals this -4day of ~ 20 CY.R WELTMAN, WEINBERG & REIS CO., L.P.A. u. By: William T. Molcza PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR No. 04966658 if · ~~ By: ~,..l) fendant, ~ G ORD ~ ~ -:C t~\hB '4-_~~ ~. 4 w ~~ ~ - :b -(l 0 +.:- ~ ~ ~ :L ~ ~ ~ ~ () ~ -\ <;~ -r" "!l ~~ ';;% 60 "),i;~; "i, - ~'1- ,{F~ ... :::::':'1. :; ~ (..,\ -(! ::;.. . .. . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. Civil Action No. 06-1136 CIVIL KEVIN T BRIDGEFORD Defendant NOTICE OF JUDGMENT OR ORDER TO: () Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the following Order qr Judgment was entered against you on ..... Ju . \~ P.;).C>C:f.o , (xx) Assumpsit Judgment in the amount of $2468.4 I plus costs. () Trespass Judgment in the amount of $ plus costs. () If not satisfied within sixty (60) days, your motor vehicle operator's license and/or registration will be suspended by the Department of Transportation, Bureau of Traffic Safety, Harrisburg, PA. (xx) Entry of Judgment of () Court Order () Non-Pros () Confession () Default () Verdict () Arbitration () Award (XX) By Consent Prothonotary KEVIN T BRIDGEFORD 704 LOUISA LN MECHANICSBURG,P A 17050 ~ .~ By: tu,Y{/\_ PRO{rroNOT~DEP TY) '(,