HomeMy WebLinkAbout06-4670w
1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
C',APITAL, ONE BANK
Plaintiff No. ot. - qL76 (2lv?L
vs. COMPLAINT IN CIVIL ACTION
SUSAN A KUHN
Defendant FILED ON BEHALF OF
Plaintiff
COUNSEL OF RECORD OF
THIS PARTY:
V. Kelly Mulholland, Esquire
PA I.D. #69978
WELTMAN, WEINBERG & REIS CO., L.P.A. j
325 Chestnut Street, Ste 1120
Philadelphia, PA 19106
215-599-1500
WWR#05215571
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK
Plaintiff f ?/2.?
VS. Civil Action No. ?. q« 1.. 01- 1
SUSAN A KUHN
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 ?, 6I
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
COMPLAINT I
Plaintiff, is a corporation with offices in 6851 JERICHO TURNPIKE #1.90
SYOSSET, NY 11791.
2. Defendant is an adult individual residing at 385 OXFORD RD, GARDNERS,PA 17324.
3. Defendant applied for and received a credit card issued by Plaintiff bearing the account
number 4388642076307381.
4. Defendant made use of said credit card and has currently a balance due and owing to
Plaintiff, as of AUGUST 4, 2006, in the amount of $2,537.25.
'1
5. Defendant is in default by having not made monthly payments when due. As such the
entire balance immediately due and payable to Plaintiff.
6. Plaintiff is entitled to the addition of interest at the rate of 25.90% per annum on the unpaid
balance from AUGUST 4, 2006.
7. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed and/or
refused to pay the principal balance, finance charges or any part thereof to Plaintiff.
WHEREFORE. Plaintiff demands Judgment in its favor and against Defendant, SUSAN A KUHN
individually, in the amount of 52,537.25 with continuing finance charges thereon at the rate of 25.90% per
annum from AUGUST 4, 2006 plus costs.
THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED
SHALL. BE USED FOR THAT PURPOSE.
WEINBERG & REIS, CO., L.P.A. 1d
PA I . # 978
W T AN, WEINBERG & REIS CO., L.P.A.
3 icstnut Street, Ste 1120
Philadelphia, PA 19106
215-599-1500
WWR9:05215571
VERIFICATION
The undersigned does hereby verify subject to the p Ities of 18 PA. C.S. 4904 relating
to unworn falsifications to authorities, that he/she is a (,(h (in/ J
(NAME)
M-t! 1D(?T of A/ 6KC 13aKk-- 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)
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SHERIFF'S RETURN - NOT FOUND
CASE NO: 2006-04670 P
COMMONTWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
CAPITAL ONE BANK
VS
KUHN SUSAN A
R. Thomas Kline Sheriff or Deputy Sheriff, who being
duly sworn according to law, says, that he made a diligent search and
inquiry for the within named DEFENDANT
VTTUT\T CTTCAT\T n but was
unable to locate Her in his bailiwick. He therefore returns the
NOTICE
COMPLAINT
the within named DEFENDANT , KUHN SUSAN A
385 OXFORD ROAD
, NOT FOUND , as to
GARDNERS, PA 17324
DEFENDANT COULD NOT BE SERVED AT ADDRESS PROVIDED, PRIOR TO EXPIRATION
DATE, PER CORINE AT ATTY MULHOLLAND'S OFFICE, RETURN NOT FOUND.
Sheriff's Costs: So answers:--
Docketing 18.00
Service 4.40
NOT FOUND RETURN 5.00 R. Thomas Kline
Surcharge 10.00 Sheriff of Cumberland County
37.40 ? WELTMAN, WEINBERG & REIS
09/18/2006
Sworn and Subscribed to before
me this day of
A. D.
WELTMAN, WEINBERG & REIS CO., L.P.A.
BY: Michael J. Dougherty, Esquire Attorney for Plaintiff(s)
I.D. No. 76046
325 Chestnut Street, Suite 501
Philadelphia, PA 19106
Phone: 215.599.1500
Fax: 215.599.1505
File # 05215571
CAPITAL ONE BANK
V&
SUSAN A KUHN
Cumberland County
Court of Common Pleas
No.: 06-4670
PRAECIPE TO DISMISS WITHOUT PREJUDICE
TO THE PROTHONOTARY:
Kindly dismiss the above matter without prejudice.
WELTMAN, WEINBERG & REIS CO., L.P.A.
By
Michael J. ough6rty, Esquire
Attorney for Plaintiff
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