HomeMy WebLinkAbout06-2952
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK
vs.
No. O~ - :29 S'd-. C/c.> l l ~ ~
COMPLAINT IN CIVIL ACTION
Plaintiff
TINA M REED
Defendants
FILED ON BEHALF OF
Plaintiff
COUNSEL OF RECORD OF
THIS PARTY:
WILLIAM T. MOLCZAN, ESQUIRE
PA 1.0.#47437
Weltman, Weinberg & Reis Co., L.PA
A: 2~)NlfKoppers Bldg.
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WNR#04914708
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IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK
Plaintiff
vs.
Civil Action No. O~- .JHS';)' C;olL~~
TINA M REED
Defendants
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 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
LAWYER REFERRAL SERVICE
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
(717) 249-3166
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK
Plaintiff
vs.
Civil Action No. 01.::,- J.9Sd-... Cv:l '-r~
TINA M REED
Defendants
COMPLAINT
AND NOW COMES, Plaintiff, by and through its counsel, WELTMAN, WEINBERG &
REIS, CO., LPA, and hereby files this Complaint against Defendant, TINA M REED, and, in
support thereof, Plaintiff avers as follows:
1. The Plaintiff is a corporation with its principal place of business located at P.O.
Box 85147, Richmond, VA 23285.
2. Plaintiff is the owner of this account, which is the subject matter of this action.
3. Defendant is an adult individual residing at 90 SPRINGERS LANE CANNa
NEWCUMBERLAND,PA 17070 .
4. Defendant requested the account and made use of said account and has currently
a balance due and owing to Plaintiff, as of MAY 16, 2006, in the amount of $1993.55. A true
and correct copy of Plaintiffs Statement of Account.is attached hereto, marked as Exhibit "1"
and made a part hereof.
5. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed
and/or refused to pay the balance.
WHEREFORE, Plaintiff demands Judgment in its favor and against Defendant, TINA M
REED, individually, in the amount of $1993.55 with finance charges thereon at the rate of
25.9% per annum from MAY 16, 2006, plus costs.
THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED SHALL
BE USED FOR THAT PURPOSE.
INBERG & REIS, CO., LPA
WILLlA T. MOL
PA 1.0.#47437
Weltman, Weinberg & Reis Co., LPA
2718 Koppers Bldg.
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
VVVVR#:04914708
-l , . .
VERIFICATION
The undersigned does hereby verify subject to the SaltieS of 18 P A. C.S. ~904 relating
to unsworn falsifications to authorities, that he/she is ~r?t ~ 1 1..\r) ~ f\
(NAME)
~~
of
, 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 ofhislher knowledge, information and elief.
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IN THE COURT OF COMMON PLEAS OF 'CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK
Plaintiff
No. 06-2952 CIVIL TERM
vs.
PRAECIPE TO SETTLE, DISCONTINUE
AND END WITHOUT PREJUDICE TO REFILE
TINA M REED
Defendants
FILED ON BEHALF OF
Plaintiff
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 A venue
Pittsburgh, PAl 52 19
(412) 434-7955
WWR#04914708
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IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVfSION
~; ..
CAPITAL ONE BANK
Plaintiff
vs.
Civil Action No. 06-2952 CIVIL TERM
TINA M REED
Defendants
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
.f ~ \ '~h
of the Court and mark the costs paid.
WELTMAN, WEINBERG & REIS CO.. L.P.A.
INBERG & REIS CO., L.P.A.
uilding
SWORN TO AND SUBSCRIBED
before me this & day
COMMONWEALTH OF PENNSYL V ANJA
Notarial Seal
Heidi J. Kelly, Notary Public
City Of Pittsburgh, Allegheny County
My Commission Expires Nov. 4. 2009
Member. PennSylvania Alloelallon of Notaries
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