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Home My WebLink About06-5268 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff No: O~-S:{I..P (1;CJiL'7-EA-~ vs. COMPLAINT IN CIVIL ACTION TAMMY E PUTT Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt,42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 Seventh Avenue, Suite 2718 Pittsburgh, PA 15219 (412) 434-7955 FAX: 412-338-7130 05216619 C A Pit VOC IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. Civil Action No TAMMY E PUTT Defendant COMPLAINT 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. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 COMPLAINT 1. Plaintiff, CAPITAL ONE BANK is a corporation with offices at 6851 JERICHO TURNPIKE #190 SYOSSET , NY 11791 . 2. Defendant is adult individual(s) residing at the address listed below: TAMMY E PUTT 411 BRICK CHURCH RD ENOLA, PA 17025 3. Defendant applied for and received a credit card bearing the account number 5291152107383289 . 4. Defendant made use of said credit card and has a current balance due of $5389.11 , as of August 17, 2006 . 5. Defendant is in default by failing to make monthly payments when due. As such, the entire balance is immediately due and payable to Plaintiff. 6. Plaintiff is entitled to the addition of interest at the rate of 20.650% per annum on the unpaid balance from August 17, 2006 . A copy of Plaintiff's STATEMENT OF ACCO UNT is attached hereto, marked as Exhibit "I" and made a part hereof. 7. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed and/or refused to pay the balance due to Plaintiff. Wherefore, the Plaintiff prays for judgment in its favor and against Defendant , TAMMY E PUTT , INDIVIDUALLY , in the amount of $5389.11 with continuing interest thereon at the rate of 20.650% per annum from August 17, 2006 plus costs. brodt,42524 INBERG & REIS CO., L.P.A. h Avenue, Suite 2718 urg , PA 15219 (412 43 -7955 FAX: 41 -338-7130 052 66 9 C A pit voc This law firm is a debt collector attempting to collect this debt for our client and any information obtained will be used for that purpose. C5" .?/ l::/'4 ~ '/ ... Your account is delinquent. We want to help! -7 To protect yoyr credit with us, YOy n~ed to mak~ a payment. -t W~ can help-but only if YOy call us. -t When you call, you can ma~e a free check.by'pl1on~ payment. ~~ Return your account to good standing. It's up to you to take the first st~p. Callusl 1-800-479-7231 "'- ~'Plfa'0ne. GOLD MASTERCARD ACCOUNT 5291-1521-0738-3289 NOY 08 - DEC 07, 2002 Pagd 00 Account Swnuwy PrmOUll &lance Pa.ymenu, Credits and Adjustmenu Transa.crions Finance Charges New-Balance Minimum Amouru: Due Paymeru: Doe Dau Total Credit Line Total AwilablrCredit Credit Line for Cash AwiIabk Credit for Cash PaymcntJI, Credits andAdj:JStmcntJI $2,953.07 '.00 164_00 .52.28 U,069,35 U,069.35 J!lD-uary07,2003 TransactioOll 1 OBNOY OVERLlMlTFEE 2 07DEC CAPITALONEMONTHLYMEMBERFEE 3 07DEC PAST DUE FEE $29.00 6,00 29.00 12,000 '.00 12,000 '.00 At your eenice To c:.Ileum..... RUtioot or 10 RpOrt. Ion or oml.en twd: 1-800-903-3637 Forer...onIincK'COWltoertieeand.opecialaooto......o6.n.!oa:onto: .........eapitUcmc.""m Sendpaymenbto: Attn:R<<nittaa<:eP.-ocaoing CaptalOneStnica P.O.B.lx851<47 Ric:hmond,VAm76 Sendinquiriato: EX!IT c.p;wOncSoni<:eo P.O. B.lx 85015 Ric:hmond,VA23.285-S015 Important Aocouot Information It., CapitIl One Bowl Wedt time lIpin! Tune in to ESPN, ESPN2, and ABC ltarting December 17 for the beet in post-lJeUOncoUrgefootballadion,to-.your&voritetrams fight fur bowl champioMhipl, and for college fooIba1l',. ultimBtt prize: the gcs National Championahip. And on New-Year',. D.y, be liW'eto time in to ARe to watch the Capital One BowIli~ from Orlando. Florida! FlnanuC"""," i ~ PURCHASES CASH .....- ttJIlidr. 13.007.'" I," P/_J.""""lUkftri",,.,tmij~ "::' ~ ~~ ."""'P .OS~P 21,"" 21,"" "". .,. ANNUAL PERCENTAGE RAffi'PPlicd thio period 21.15% ... PLEASE RETURN PORTION BELOWWITH PAYMENT, ... Cc.,.III.JOne' 0000000 0 5291152107383289 07 3069350150003069350 13.069.35 13.069.35 ,-, .....' January 07, 2003 a. .- ZIP I Hom.Phcno -..""". 5291-1521-0738--3289 . 2moilAcldrcol PI._,n.u....w..,;MJm,....v....--il~N'""W#WH......;l.did. N_ &l.nu Minimum Amount Doe Payment Due Date Totalrnclocd &x:oumNumber: -, Capi tal One Bank P.O, Box 85147 11I...1111I1111I111.11 Richmond. VA 23276 lul.l.IIlIl.I,llml.IIIIIIII.IIIIIIIIIIIIIIIIIIIIII.ullllll = - = - = - n - N ~ - 0 - - *9034279070613949' MAIL ID NUMBER TAMMY E PUTT 411 BRICK CHURCH RD ENOLA PA 17025-2203 111I1111..11I11I111.1.1.111I1,11.1.11I.11111111I.11.1.11.11111 r Plus, writ'JOlIl'_"t mmlHrOllyawriJdDr mOII'J' mkr wwMi"JUk to CapiJtd 0",. &X~ .". nWl;lI themdt>>dmwloJw. VERIFICATION The undersigned does hereby verify subject to the PFties of 18 A. C.~. 4904 relating to unsworn falsifications to authorities, that he/she is ~CA 4 b I (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 belief. ~ (SIGNATURE) WWR# . , ~: , ~., SHERIFF'S RETURN - REGULAR CASE NO: 2006-05268 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CAPITAL ONE BANK VS PUTT TAMMY E MICHAEL BARRICK , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon PUTT TAMMY E the DEFENDANT , at 1744:00 HOURS, on the 19th day of September, 2006 at 411 BRICK CHRUCH ROAD ENOLA, PA 17025 by handing to TAMMY E PUTT 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: Docketing Service Affidavit Surcharge So Answers: Sworn and 18.00 13.20 .00 10.00 .00 41. 207 IOJb4/0(P Q-. Subscibed to ~~~ R. Thomas Kline ' day 09/20/2006 WELTMAN WEINBERG REIS BY'-7~~&/ before me this of A.D.