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Home My WebLink About06-3892 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff No. Q(s 3? /02 ?tVL(? vs. COMPLAINT IN CIVIL ACTION JAMES A LEESE Defendants FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: WILLIAM T. MOLCZAN, ESQUIRE PA I.D.#47437 Wellman, Weinberg & Reis Co., L.P.A. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#05252351 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. Civil Action No. JAMES A LEESE 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. JAMES A LEESE Defendants Civil Action No. COMPLAINT oc- -3?9;1? AND NOW COMES, Plaintiff, by and through its counsel, WELTMAN, WEINBERG & REIS, CO., LPA., and hereby files this Complaint against Defendant, JAMES A LEESE, 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'residirig at 46 W ALLEN ST MECHANICSBURG,PA 17055. 4. Defendant requested the account and made use of said account and has currently a balance due and owing to Plaintiff, as of JUNE 30, 2006, in the amount of $1,197.42. 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, JAMES A LEESE, individually, in the amount of$1,197.42 with'fihance charges thereon at the rate of 25.9% per annum from JUNE 30, 2006, 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. MO C , ESQUIRE PA I.D.#47437 Weltman, Weinberg & Reis Co., L.P.A. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412)434-7955 WWR#: 05252351 VERIFICATION The undersigned does hereby verify subject to thovenalties of 18 PA. C.S. 4904 relating to unworn falsifications to authorities, that he/she is (NAME) of , plaintiff herein, that (TITLE) (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 his/her knowledge, information and belief. L (SIGNATURE) WWR# - l ? I• oto f • IN THE COURT OF COMMON PLEAS OF CUMBERLAND COl1N"I'Y, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Pl:?intif-f . vs. JA;MF.S A JJ"ESE Defendant No.06-;892-('lVll-. 'ITRw1 PRAECIPE' I'OR ENTHN' OF JUDGMENT I3Y CONSENT FILG) ON BF11;11,1' 01= Plaintiff COUNSEf- OF RECORD OF 'I'IIIS PARTY: Jamcs C. Wlrmbrodt, Esquire PA 1.DA42524 WILTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 W WR1105252351 Judgment nmi??mt:?+ 1,?22.50 r a IN THE COURTOF COMMON Pf:EAS CUMBFI2I.AND COI A l'Y. PFNNSYI VANIA CIVIL DIVISION CAPI'T'AL. ONE BANK Plaintiff vs. JAMES A LEESE Defendant Civil Action No. 06-3892-CIVILTERM PRAECIPE FOR JUDGMENT 13)" CONSENT F0 1111F PIZOTIIONOTARY: Kindly enter Judgment against Defendant, JAMES A 1.1-T i'.. in the alnOunt cif $ 1,222.50 plus costs, based upon the consent of the parties. CONSENTED hO: WI,LTMAN, WEINBERG & REIS CO., L..P.A., 13) Ai W IN THE COURT OF COMMON PLEAS CU,MBEAl.1ND COUNTNI, PV:NNSYLVANIA CIVIL. [)!VISION CAPITAL ONE BANK Plaintiff VS. Civil Action No. 06-3892-CIVIL TERM JAMES A LEESE Defendant STIPULATION OF THE PARTIES FOR PAYMENT AND FOR THE ENTRY OF JUDGMI N'r BY CONSENT fO TI IE P'WTIIONOTARY: Kindly enter Judgment in favor of Plaintifhand against the l.) lcndant, JAMES A LEI=;S1:, above-named, in the amount of $ 1,222.50 pursuant to the Stipulation of the Parties for Pavmcnt and I'ur the Entry of Judgment by Consent, as follows: 1, Defendant admits indebtedness to Plaintiff in the amount of $ 1,222.50 with continuing interest thereon at a rate of 6.0% per annum plus costs from AUGUST 9, 2006. 1 To secure the repayment of said indebtedness, Defendant agrees that Judgment by Consent will be entered in favor ofthe Plaintiff and against the Defendant, JAMES /? LGESL, in the amount Of $ 1,222.50 plus continuing interest thereon at the rate of 6.0% per annum from AUGUST 9, 2006 and costs. 3. Plaintiff agrees not to execute on its Judgment so long as Defendant causes to be delivered to Plaintiff the i61lowing payments in full by 12:00 NOON on the following dates: (a) $100.00 due by 8/3/06; (b) $100.00 due on the 3rd day 01'each ConSCCUti\,e month thereafter until tho Judgment amount plus accrued interest and costs are paid in dill. 1. 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 Buildino. 436 Seventh Avenue, Pittsburgh, PA 1 52 (9. 6. In the event of default, each payment received shall he first Etttributed 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 Plaintiff's counsel any payment in frill 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 cqu?ity, ro collect the full balance ofthe Jud-ment 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. ??. Intending to be legally bound, the parties set their hands and seals thislyday of ?0 Wl;I. L\dA`;. ",],"INIiI,R() & RI:IS CO., L.P.A. By: ----- Ja? C. Warmbrodt, I; quire PA 1. 1t 2524 WEL 'M. N', WEINBEIRG & RIMS CO., L.P.A. 271 Kot pars Building 43 Sev nth Avenue P' sb -gl?, PA 15219 ( 1 434-7955 WWR No. 05252351 1)e c int. JAMES A L,EESE W W --C, C d C? Ga IN THE COURT OF COMMON PLEAS OFCUMBERLAND COUNTY, PENNSYLVANIA CIVIL, DIVISION CAPITAL. ONE: BANK Plaintiff vs, Civil Action No. 06-3892-CIVIL TERM JAMES A UE'SE Defendant NOTICE; OF,IUDGME NT OR ORDER fO: ( ) Plaintiff (Ya) Defendant ( ) Garnishee You are hereby notified that the following Order Judgment was entered against you on _ a2 I ar-Dc--? (xx) Assumpsit Judgment in the amount of $ 1,222.50 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, I Iarrisburg_ P A. (xx) Entry Of JUdgmCnt of ( ) ( o,,-I Order ( ) NWI-Pros ( ) (0 ,tcssiori ( ) Default ( ) Verdict ( ) Arbitration ( ) Award (XX) By Consent Prothonotary JAMES A 1,LFSE 46 W AI-LEN ST MFCHANICSBURG,PA 17055 By: _- PROTb ONOTAR bl,, JTY) SHERIFF'S RETURN - REGULAR CASE NO: 2006-03892 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CAPITAL ONE BANK VS LEESE JAMES A TIMOTHY REITZ Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon LEESE JAMES A the DEFENDANT , at 1509:00 HOURS, on the 12th day of July 2006 at 46 W ALLEN STREET MECHANICSBURG, PA 17055 JAMES A LEESE by handing to 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 18.00 Service 8.80 Affidavit .00 Surcharge 10.00 So Answers: R. Thomas Kline 36.80./ 07/13/2006 7/x/,4 WELTMAN WEINBERG REIS Sworn and Subscibed to By: ?- before me this day De t Sheri f of , A. D. IN THE COURT OF COMMON PLEAS OF CUMBEI CIVIL DIVI ION CAPITAL ONE BANK Plaintiff vs. JAMES A LEESE Defendant No ND COUNTY, PENNSYLVANIA -CIVIL TERM PRAECIPE FOR SATISFACTION OF JUDGMENT FILD ON BEHALF OF Plai tiff COYNSEOF RECORD OF THIS PARTY-. Jar es C. armbrodt PA . D 44 524 WE TMA , WEINBERG & REIS CO., L.P.A. 271 Kop ers Building 436 Seve th Avenue Pitt burg , PA 15219 (41 ) 434 7955 2351 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVI ION CAPITAL ONE BANK Plaintiff vs. Civi Actio No. 06-3892-CIVIL TERM JAMES A LEESE Defendant TISFACT ENT At the request of the undersigned attorneys for the Plaintiff, you are directed to satisfy the above-captioned Judgment. WELTMAN, WEINBERG & REIS CO., L.P.A. By: v Jam es C armbrodt PA I . D 24 WE T A WEINBERG & REIS CO., L.P.A. 271 Kop ers Building 436 Sev th Avenue Pitt gh PA 15219 (412 434- 955 Sworn to and sub?ribe before me thisIy J d of October 07 'k, 0 OTARY CiPA y . . f J Oyf A 40 6.* /? ? ?^n!'?tN"???tib. ? nrr,.-tip- r;ac??r`cA? . 52351 8 00 C-) o t n Zt F -4 pp ?[r 4 C 0 r i N