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Home My WebLink About06-6971 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff No: (};u~L't&~ COMPLAINT IN CIVIL ACTION ot:. - ~cr'7l vs. JACQUELIN B WHITE 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 05453392 C N Pit DKB IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. Civil Action No JACQUELIN B WHITE 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 140 EAST SHORE DR GLEN ALLEN , VA 23059 . 2. Defendant is adult individual(s) residing at the address listed below: JACQUELIN B WHITE 147 FIELDSTONE DR CARLISLE, PA 17013 3. Defendant applied for and received a credit card bearing the account number 4862362450073351 . 4. Defendant made use of said credit card and has a current balance due of $1193.76 , as of November 08, 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 26.990% per annum on the unpaid balance from November 08, 2006 . A copy of Plaintiff's STATMENT 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 , JACQUELIN B WHITE , INDIVIDUALLY , in the amount of $1193.76 with continuing interest thereon at the rate of 26.990% per annum from November 08, armbrodt,42524 EINBERG & REIS CO., L.P.A. th Avenue, Suite 2718 h, PA 15219 4-7955 2-338-7130 392 C N Pit DKB 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. , .. . Have you checked your rewards points lately? It's so easy to earn rewards. Just make purchases with your Capital One- Rewards card, pay your bills on time or carry a balance and you earn valuable rewards points. Please review Rewards Program Rules for complete details. 3 easy ways to earn ooints: Redeem your points for rewards and merchandise at fine <D Just make a purchase retailers like Borders, Starbucks, Old Navy, Bath 8< Body Works ~ Pay your bill on time and Sears. You can even use your points to get over-limit.fee ~ Carry a balance credits or temporarily lower your purchase APR! M=hant ,.,.,mfNUi-. ...bj<<t '" c;""". r To redeem your points or d1cck on your point balance, call 1-800-406-7287, Your current point total is included 1 in your monthly statemcnL You can also visit us at www.gctmyrcwaxds.com to review your rewan:l options and redemption levels. Caplla,One" AccoUllt Summaty Previous Balance Payments, Credits and Adjusbnents T_ons Finance Charges S841.82 S.OO S29.00 S19.51 New Balance Minimum Amo\D'lt Due PaYlllfllt Due Date S89O.33 S89O.33 September 03, 2005 S500 S.OO S500 S.OO Total Credit Line Total AvailableCredit Credit Line for Cash AvailableCredit for Cash At your service To callCustomelt.e1ationrorto ....,-IOStorstolen:ard: 1-800-903-3637 Senc\>aymenllo: Attn:Remittancfrocessing CapitaDneBank P.O. BoX790216 Sl Louis,M063 179-0216 Sendinquiriem: CapitaDne P.O. Boxl0285 SLC, UT 84130-0285 PLATINUM VISA ACCOUNT 4862-3624-5007-3351 JUL 04 . AUG 03,2005 Page 1 ofl PaYlllfllts. Credits and Adjustments Transactions 03 AUG PAST DUE FEE S29.00 Remember using your card earns points for great rewards such as APR reduction, statement credits, merchandise, gift certificatesand much more. You were assesseda p~t due fee of$29.00 on 0810312005 becauseyourminimum payment was not receivedby1l1e due date of 0810312005. To avoid this feein 1I1e future, werec:ommend that you allow a! least 7 business days for your payment to reach Capital One. You have redeemed a total of 0 reward points between 07/0412005 and 0810312005. Y ouryear-to-date redemption total is O. Y ouhave earned a total of 129 reward points betw_ 07/04/2005 and 0810312005. Y ouryear-to-date total is 781. ACCOWlt activity outside of these dates does not appear on this statement For more up to date infonnation or details about your points, calI1I1e Capital One Rewards Center a! 1-800-406-7287. EM \ Finance Charges Pleasese<<evel'Scsideforimportantinfonnation s: Balanaate Periodic COTc!ing FINANCE opplietb rate CHARGE ~ PURCHASES S851.22 .07395'11 26.99% S19.51 CASH S.OO .07395'11 26.99% S.OO ANNUAL PERCENTAGE RATE applied 1I1is period 26.99% CapIIaIOne" T PLEASE RETURN PORTION BELOW WITII PAYMENT T 0000000 0 4862362450073351 03 0890330727920890339 Pleasprin1addr"""anglbe1owsinIl>IUOlrblacink. New Balance Minimum Amount Due Payment Due Date S89O.33 S89O.33 September 03, 2005 Total enclosed Acco\DIt Number: 4862-3624-5007-3351 .., ~~b~t:~x O~~O~~~k 1,1,,1,,1,1,1,,1.1I,,1 St. Louis, MO 63179-0216 1,1111"11""11111I11,11111,,,,,1.1..,11.11,11I,11,11,,1,,1,1 Street Aptll ZIP City S_ Hom'hone Altem8llhone - ~ - ~ g = #9021673823991724# MAIL ID NUMBER JACQUELIN B WHITE 147 FIELDSTONE DR CARLISLE PA 17013-9054 r 111,11I11,111,11I"111111,1,111111111,.1,,1,,1,1,,11,,,11,1,,1 PleasewriteYOUf8CCOUllilumberon yourchec:lormonOJOfdennadepayableto Capital OneBankand mail in 1I1eencloseolnvelope. . - - - - - g 8 i ~s::1 ,,:;~i 0"'''' I I 1 · VERIFICATION CAPITAL ONE BANK vs WHITE, JACQUELIN B The undersigned does hereby verify subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities, that he/she is, MAISHA DAVIS, Authorized Agent, of CAPITAL ONE BANK, Plaintiff Herein, that he/she is duly authorized to make this Declaration, and that the facts set forth in the foregoing Complaint in Civil Action are true and correct to the best ofhis/her knowledge, information and belief. , IV--..L-Q.-- '--_ - MAISHA DAVIS r ~~~o~ MYRA PRINDLE Notary Public Gw!n~ett County Georgia My CommIssIon Expires July 31st 2009 4862362450073351 A049 WELTMAN, WEINBERG & RBIS CO., L.P.A. 1- (:) ~ ~ III t!l . ........ N CJ1 G ~ "- D (") "" ~ c c:::> 0 -..,.... c:::> ~ \") f=? C" -n ~ 0 :r:n ~ ~~; f:-- rT'1 "'- ;:~... !~',-_:..: n rn (h r- "<: _.~f "-:.' , tJiTi r' 01 i8:( ~ l~ -0 ----; '.' ~.;~ ~:_- ;'~2~; ):~~: :x ..::...-. L..) (:) rn -) ::;:-1 /> '-, .::0 N -< l ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff No. : 06-6971 CIVIL TERM vs. PRAECIPE TO SETTLE, DISCONTINUE AND END WITHOUT PREJUDICE TO REFILE JACQUELIN B WHITE Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William 1. Molczan, Esquire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#05453392 ~ ... IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. Civil Action No. : 06-6971 CIVIL TERM JACQUELIN B WHITE 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. By: Attorney for Plaintiff 2718 Koppers Buildi 9 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#05453392 SWORN TO AND SUBSCRIBED before me this _t 51' day ,2007 tit:tM Wayne A. Jones, Notary Public CIly Of PitlsburgJ, AII~ ColI1ly MtCommlssion Expires June 29,2010 Member, Pe"".ania Association of Notaries o c: l"'--:l <::;:, c.:;::> --..j o ""1"l :.-:1 01~ ~q~;, .-j", <"'.S;~;~ t5 rf~ ::;-\ ,.;.-~ :D -< ..-',.,.,. ~:.:~ =~:J , 0'"\ ~ ~ \_0 .r:- c.J1 SHERIFF'S RETURN - REGULAR CASE NO: 2006-06971 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CAPITAL ONE BANK VS WHITE JACQUELIN B SHAWN H.l\RRI SON / Sheriff or Deputy Sheriff - ,- - - - - -i- ..... t - ...... - - - - Cumberland County/Pennsylvania, who being duly sworn accor ng to law, says, the within COMPLAINT & NOTICE was served upo WHITE JACQUELIN B the / at 1523:00 HOURS, on the 26th day of Dee DEFENDANT at 147 FIELDSTONE DRIVE CARLISLE, PA 17013 JACQUELIN WHITE by handing to a true and attested copy of COMPLAINT & NOTICE tog her with and at the same time directing Her attention to the conte Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 6.16 .00 10.00 .00 v/34.16 ,/J 46 7 9__ Sworn and Subscibed to before me this day of So Answers: <~r~ R. Thomas Kline 00/00/0000 2006 - ,- - - - ~ ..... -Iii - - - ... By: A.D. "- - - - ~ ...I .. .. . .