The URL can be used to link to this page

Home My WebLink About06-3896 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK gyp/ Plaintiff No. EACJ7 vs. COMPLAINT IN CIVIL ACTION I SHARON K LANDIS 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. Z7.18..Koppers Bldg. V, '416?9eventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#05252613 o; IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. Civil Action No. SHARON K LANDIS 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) 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. SHARON K LANDIS Defendant Civil Action No COMPLAINT AND NOW COMES, Plaintiff, by and through its counsel, WELTMAN, WEINBERG & REIS, CO., LPA., and hereby files this Complaint against Defendant, SHARON K LANDIS, 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 1809 LETCHWORTH DR CAMP HILL,PA 17011 . 4. Defendant requested the account and made use of said account and has currently a balance due and owing to Plaintiff, as of JUNE 28, 2006, in the amount of $3,201.91. 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, SHARON K LANDIS, individually, in the amount of $3,201.91 with finance charges thereon at the rate of 25.9% per annum from JUNE 28, 2006, plus costs. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED SHALL BE USED FOR THAT PURPOSE. WELTMAN, WEINBER/G & REIS, CO., L.P.A WILLIAM T. MOLCZf,, ESQUIRE l/ PA I. D.#47437 Weltman, Weinberg & Reis Co., L.P.A. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#: 05252613 s it's . ............. VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA. C.S. 4904 relating to unworn falsifications to authorities, that he/she is &Lra- L uk)l o (NAME) R aP 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. (SIGNATURE) WWR# UVI ° ?w CIO IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Piaintiff vs. SHARON K LANDIS Defendant No.06-3896-CiV IL TERM PRAECIPE FOR ENTRY OF JUDGMENT BY CONSENT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: Benjamin R. Bibler PA I.D. 493598 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 W WR#05252613 Judgment Amouml:$3269.93 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY. PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. SHARON K LANDIS Defendant Civil Action No. 06-3896-CIVIL TERM PRAECIPE FOR JUDGMENT BY CONSENT TO THE PROTHONOTARY: Kindly enter Judgment against Defendant. SHARON K LANDIS, in the amount of $3269.93 plus costs, based upon the consent of the parties. CONSENTED TO: WELTMAN, WEINBERG & REIS CO., L.P.A., By. - A orney Iainti, SHARON K LANDIS, By: Defendant WWR#05252613 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. Civil Action No. 06-3896-CIVIL TERM SHARON K LANDIS 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, SHARON K LANDIS, above-named, in the amount of $3269.93 pursuant to the Stipulation of the Parties for Payment and for the Entry of Judgment by Consent, as follows: 1. Defendant admits indebtedness to Plaintiff in the amount of $3269.93 with continuing interest thereon at a rate of 6.0% per annum plus costs from JULY 29, 2006. 2. To secure the repayment of said indebtedness, Defendant agrees that Judgment by Consent will be entered in iavor of the Plaintiff and against the Defendant. S1IARt)N K 1_^ NDIS. in the amount of $3269.93 plus continuing interest thereon at the rate of 6,0°/o per annum from J ULY 29. 71006 and costs. 3. Plaintiff agrees not to execute on its Judgment so long as Defendant causes to he delivered to Plaintiff the following payments in full by 12:00 NOON on the following dates: (a) $10.00 due by 8/30/06; (b) $10.00 clue by 9/30/06; (c) $10.00 due by 10/30/06; (d) $100.00 due by 11/3 0/06; (d) $100.00 due on the LAST 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 fill 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 77ay of .z 20 WELTMAN, WEINBERG & REIS CO., L.P.A. By: --- R13iblcr Xrl a min 8 I.1) 09351)8 WEL) MAN., WFItiL3i.RG & R171IS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR No. 05252613 By; GC^2 ?C ?? Defendant, SHARON K LANDIS IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE, BANK Plaintiff vs. SHARON K LANDIS Iefendant SHARON K LANDIS 1809 LETCfIWORTH DR CAMP HILL,PA 17011 Civil Action No. 06-3896-CIVIL TERM NOTICE OF JUDGINZENT OR ORDER TO: ( ) Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the following Order Judgment was entered against you on P1, ao6e. (xx) ASSUmpsit Judgment in the amount of $3269.93 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 By: - PRO"f ON(0- Y) - SHERIFF'S RETURN - REGULAR CASE NO: 2006-03896 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CAPITAL ONE BANK VS LANDIS SHARON K MARK CONKLIN , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon LANDIS SHARON K the DEFENDANT , at 1410:00 HOURS, on the 13th day of July , 2006 at 1809 LETCHWORTH DRIVE CAMP HILL, PA 17011 n T TT T1l T T TTTTIT0 by handing to 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: So Answers: Docketing Service 18.00 12.32 ???? Affidavit 00 Surcharge 10.00 R. Thomas Kline .00 40.32,/ 07/14/2006 -7/1&/01- WELTMAN WEINBERG REIS Sworn and Subscibed to By: A"( ??z before me this day Deputy Sheriff of A. D. F HF!LD--QFHuE 20 10 MAR -8 P11 3: 59 GU"4 ?.....?;1` IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. SHARON K LANDIS Defendant(s) No. 06-3896-CIVIL TERM PRAECIPE FOR SATISFACTION OF JUDGMENT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: Lyndsay E Rowland, Esquire PA I.D. # 205520 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7999 WWR#5252613 JAM f S? d D ? ?C «?Ely k IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. Civil Action No. 06-3896-CIVIL TERM SHARON K LANDIS Defendant(s) PRAECIPE FOR SATISFACTION OF JUDGMENT At the request of the undersigned attorneys for the Plaintiff, you are directed to satisfy the above-captioned Judgment. WELTMA , WEINBERG & REIS CO., L.P.A. By: Lyndsay , Rowland, F ire PA I.D. 205520 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7999 WWR #5252613 Sworn to and subscribed before me this k"1 day of February, 1A COMMO W yyayns AEAK JamW Sam , tjowy P?? Of AbWMW CMya* June 20, 2010 Mambat, ? Nom