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HomeMy WebLinkAbout06-3807 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff No. 0(. - JPc>7 Ct'uLl y~ VS, COMPLAINT IN CIVIL ACTION LUANN E BERRIDGE Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: JAMES C WARMBRODT, ESQUIRE PA 1.0.#42524 Weltman, Weinberg & Reis Co" L.PA 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 FAX: 412,338-7130 W\lVR#05215388 '- ,,,.,' ,. r- r"!"" IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs, Civil Action No, LUANN E BERRIDGE 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) day~ after this complaint and notice are served, by entering a written appearance personally or by ai1 attorney and filing in writing with the court your defenses or objections'~o 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 ,~::< J 1/'1 aCii"" ".: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs, Civil Action No. 0," -JPC>1 (};l.J'LL/~ LUANN E BERRIDGE Defendant COMPLAINT AND NOW COMES, Plaintiff, by and through its counsel, WELTMAN, WEINBERG & REIS, CO., LPA, and hereby files this Complaint against Defendant, LUANN E BERRIDGE, 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 27 RAYS DR NEWVILLE,PA 17241 . 4. Defendant requested the account and made use of said account and has currently a balance due and owing to Plaintiff, as of JUNE 26, 2006, in the amount of $2,559.45 . \ "'! 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, LUANN E BERRIDGE, individually, in the amount of $~,&5~.4~ with finance charges thereon at the rate of 20.65% per annum from JUNE 26, 2006, plus costs, THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED SHALL BE USED FOR THAT PURPOSE. ;" \ G & REIS, CO., L.PA ,.., ,', \ VERIFICATION 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 is ~ (lfG.. {L,., 1Jo If-> (NAME) (:\ C\e ~) of ri' \-f.. \ t:w ~ ~~~ plaintiff herein, that 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 ofhis/her knowledge, infonnation and belief. ,.. N ~ ( (SIGNATURE) WWR# (; <; 1. ~l(~ S-- ){ N f"::) ~ :jl 1 .~ 0 ~'.. ,:J --11 - -' c_ :..-:1 ~ ~ & r-; , f'i'i:!J e w r'~-~ r- "<) I r:; W Ui T ~ ~ ~ ,',., -.;, ~ C) ,-) , I C~ ' , ~ r.' - ", --P SHERIFF'S RETURN - REGULAR CASE NO: 2006-03807 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CAPITAL ONE BANK VS BERRIDGE LUANN E VALERIE WEARY , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon BERREIDGE LYNN E the DEFENDANT , at 1004:00 HOURS, on the 13th day of July at 27 RAYS DRIVE , 2006 NEWVILLE, PA 17241 by handing to GARY FICK, BOYFRIEND, ADULT IN CHARGE 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 12.32 .00 10.00 .00 40.32 r~~ R. Thomas Kline day 07/13/2006 WELTMAN WEINBERG REIS f~~ s~ By: Sworn and Subscibed to before me this of A.D. " IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff No. 06-3807 CIVIL TERM vs. PRAECIPE TO SETTLE, DISCONTINUE AND END WITHOUT PREJUDICE TO REFILE LUANN E BERRIDGE Defendant 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 Avenue Pittsburgh, PA 15219 (412) 434-7955 WNR#05215388 . .. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. Civil Action No. 06-3807 CIVIL TERM LUANN E BERRIDGE Defendant PRAECIPE TO SETTLE, DISCONTINUE AND END WITHOUT PREJUDICE TO REFILE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: SIR: Settle, Discontinue and End the above-captioned matter upon the records of the Court without prejudice to refile and mark the costs paid. WELTMAN, WEINBERG & REIS CO., L.P.A. SWORN TO AND SUBSCRIBED .', .--- before me this S day COMMONWEALTH r-----.-~.-----,. j No':'", Seai J. K(:!Jf. r\fot3ty P 01 ' ,(~;~j~~Jhe '".. Xr)\~ ,'It \ -,il~-~\-!\ianj& P,-;:'~-;(.lClat:,~ g 92ff ,n",' . :r,> Z[.. en .'c ;:L .,: GC ):; /~H'~, zh >c ~ ~ c:;:,) C;:;:t c:I'"' o P -1 ~ ~~ -om est, a:> =r: ::n ~ %~~ - ~ ;. ~ N