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Home My WebLink About07-1806IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. LENORA STAAB Defendant No: ??a? 6to? L COMPLAINT IN CIVIL ACTION 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 05614703 C N Pit SGM I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK VS. Plaintiff Civil Action No LENORA STAAB Defendant COMPLAINT AND NOTICE TO DEFEND You have been sue in court. If you wish to defend against the claims set forth in th 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 P RSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 I COMPLAINT 1. Plaintiff, CAPITAL ONE BANK is a corporation with offices at 140 EAST SHORE DR GLEN ALL N , VA 23059 2. Defendant is adultlindividual(s) residing at the address listed below: LENORA STAAB 5337 OXFORD CIR MECHANICSBURG, PA 17055 3. Defendant applied for and received a credit card bearing the account number 5178052444244293 4. Defendant made uselof said credit card and has a current balance due of $3061.88 , as of February 21, 2007 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 25.900% per annum on the unpaid balance from February 21, 2007 . A copy of Plaintiff's STATEMENT is attached hereto, marked as Exhibit 111" and made a part hereof. I 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 , LENORA STAAB , INDIVIDUALLY , in the amount of $3061.88 with continuing interest thereon at the rate of 25.9000 per annum from February 21, 2007 plus costs. James WELTM 436 S Pitts (412) FAX: 056 4 armbrOat,42524 EINBERG & REIS CO., L.P.A. en h Avenue, Suite 2718 r , PA 15219 3 -7955 -338-7130 3 C N Pit SGM This law firm is a debt collector atte4ip ing to collect this debt for our client and any information obtains will be used for that purpose. f 0 peoplepic- online u A better way to Internet. $q,97' 1-888-587-9669 Mention Offer Code: BRONZE Visit: www.peoplepc.corrk/go/bronze UNLIMITED INTERNET ACCESS PeoplePC Online offers all the features you would expect from higher-priced Internet Service Providers, including: 19 Virus Protection powered by $ynuatft "` ® Pop-Up BlockerTm * Spam Controls ® 4? Smarter Smart Dialer Technology More Email Addresses ® f Internet Call Waiting e CapitalQW- Account Summary PreviousBalance $2,112.34 Payments, Credits and Adjustments $.00 Transactions $64.00 Finance Charges 547.61 New Balance $2,223.95 Minimum Amount Due $2,223.95 Payment Due Date October 07, 2005 Total Credit Line $2,000 Total AvailableCredil $.00 Credit Line for Cash $1,000 AvailableCredit for Cash S.00 At your service To callCuslomeRelationer to report lostor stolemard: 1-800-903-3637 Sendpaym nt¢b: Srndinquirieso: Atm: RemittanclProcessing CappitalDneBank Caappi fne P.O Box790216 P.O.Box30285 St. LouisMO 63179-0216 SLC,UT84130-0285 Important Account Information Twelve unsung heroes of collegeathletics are competing for the honor of Capital One National Mascot ofthe Year- and you can help decide who wins) Each week, the mascots go head-to-head in competition, but only one will win the coveted title and $10,000 for their school. Go to capiWone.com where you can vote daily for your favorite mascot - and don't forget to time in to the Capital One Bowl on ABC on Monday, January 2, 2006, to see who wins] Finance Charges Please eerevmcsidefohmponantinfomration Balancrate Periodic Corresponding FINANCE ° applied) rate APR CHARGE n PURCHASES CASH $1891.56 5'272 72 .07096% 25.90% $41,61 07096 . . % 25.90% $6.00 ANNUAL PERCENTAGE RATE applied this period 25.90% PLEASE RETURN PORTION BELOW WITH PAYMENT Capitalo W 0000000 0 5178052444244293 07 2223950180002223958 New Balance $2,223.9 5 Minimum Amount Due $2,223.95 Payment Due Date October 07, 2005 Total enclosed $ Account Number: 5178-0524-4424-4293 PLATINUM MASTERCARD ACCOUNT 5178-0524-4424-4293 Payments, Credits and Adjustments AUG 08 - SEP 07, 2005 Page 1 of 1 Transactions I 08 AUG OVERLMT FEE $29.00 2 07 SEP PAST DUE FEE 35.00 You were assesseda past due fee of $35.00 on 09/07/2005 becauseyourminimum payment was not receivedby the due date of 09/072005. To avoid this fee in the future, we recommend that you allow at least 7 businessdays for yourpayme t to reach Capital One. Pleasprinenailingddreold/oe-maibhangdcloxuing)l u®rblacknk. street Apt# - City State ZIP Homfh me Altemallhone in less #9025155191555154# MAIL ID NUMBER Capital One Bank L 1441 NORAAPSTA CIR P.O. Box 790216 APT 182 St. Louis, MO 63179-0216 MECHANICSBURG PA 17055-3902 Pleasewrite yowaccounttutnberon yourcheckrcmoncy rdermadepayabletoCapital OneBank and mail in theencloselnvelope. r peoplepc- online %___1 A better way to Internet. UNLIMITED INTERNET ACCESS 1-888-587-9669 e Mention Offer Code: BRONZE Visit: www.peoplepc.conVgo/bronze PaoplePC is solely responsible for this offer, and Is not affiliated with Capital One. Capital One does not provide, endorse or guarantee, and Is not affiliated with, any product or service shown here. Any trademarks mentioned herein are solely owned by the respective an iry AS rights reserved. By responding to this offer, you may be conmunicating information about yourself to the company drat provides this product - for example, that you are a Capital One customer. `PeoplePC Online: First 3 months are billed at $4.97 par month; $9.95 per month thereafter. PsoplePC Online Accelerated m: First 3 months are billed at $7.47 par month; $14,95 per month there".. Offer available to new dial-up wosoribars at least 18 years of age and may not be redeemed with any other offer Oiler subject to change at any time. Phone technical support available for $1.95 per minute. }with PeoplePC Online Accelerated, certain Web page text and graphics will bad faster when compered to standard c, Internet service. Actual results may vary. Pool Online Accelerated is only compatible with PeoplePC Online Internet service and specified Wlndowa® browsers. PeopW Online Accelerated Is not compatible with YJIrWowa® 95 with IE 5S SP2. Service not available in all areas. Access tees, taxes, and other fees and restrictions may apply. Telephone toi charges may apply, even during trial periods. You are responsible for determining whether a call to one of our access numbers will result in telephone toll charges. Access may be limited, especially during times of peak usage. Dial-up numbers may be changed at PeoplePC'a discretion. Continuous use subject to timeout procedures. All use is subject to PeoplePc Onlineb Services Agreement and Acceptable Use Policy. SW is the maximum speed of service; actual speed may vary. O 2005 PeoplePC Inc. All Rights Reserved. PeoplePC Online and its logce are trademarks of PsoploPC in the U.S. and other countries. O 2005 Capital One Services, Inc. Capital One is a federally registered service mark All rights reserved. o I N I n O IAN VERIFICATION CAPITAL ONE BANK vs STAAB, LENORA 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 of his/her knowledge, information and belief. MAISHA DAVIS Dudiey lumer Notary Public, Dekalb County, Georgia My Commission Expires January 19, 2009 5178052444244293 A049 WELTMAN, WEINBERG & REIS CO., L.P.A. b V IQ V 7 _. -j c.,a c? ?a» r?? r= 7? ?7?44i ?Y^r d IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK, Plaintiff vs. LENORA STAAB Defendant No. 07-1806 CIVIL TERM PRAECIPE FOR DEFAULT JUDGMENT 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. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#05614703 Judgment Amount $ 3,239.82 THIS LAW FIRM IS ATTEMPTING TO COLLECT THIS DEBT FOR ITS CLIENT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. I IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK, Plaintiff VS. Civil Action No. 07-1806 CIVIL TERM LENORA STAAB Defendant TO THE PROTHONOTARY: PRAECIPE FOR DEFAULT JUDGMENT Kindly enter Judgment against the Defendant, LENORA STAAB above named, in the default of an Answer, in the amount of $3,239.82 computed as follows: Amount claimed in Complaint $3,061.88 Interest from FEBRUARY 21, 2007 TO MAY 14, 2007 at the legal interest rate of 25.9% per annum $177.94 TOTAL $3,239.82 I hereby certify that appropriate Notices of Default, as attached have been mailed in accordance with PA R.C.P. 237.1 on the dates indicated on the Notices. WELTMAN, WEINBERG & REIS CO., L.P.A. By: ?? WILLIAM T. MOLCZAWSQUIRE PA I.D.#47437 Weltman, Weinberg & Reis Co., L.P.A. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#05614703 Plaintiffs address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7t' Avenue, Pittsburgh, PA 15219 And that the last known address of the Defendant is: 5337 OXFORD CIR MECHANICSBURG,PA 17055 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK, Plaintiff vs. Civil Action No. 07-1806 CIVIL TERM LENORA STAAB Defendant NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the following Order or Judgment was entered a ainst you on 1{ pa' (xx) Assumpsit Judgment in the amount of $3,239.82 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 (xx) Default ( ) Verdict ( ) Arbitration Award Prothonotary By: PROT ONOT LENORA STAAB 5337 OXFORD CIR MECHANICSBURG,PA 17055 Plaintiffs address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7`n Avenue, Pittsburgh, PA 15219 1-888-434-0085 N IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK, Plaintiff vs. LENORA STAAB Case no: 07-1806 CIVIL TERM NON-MILITARY AFFIDAVIT Defendant The undersigned, who first being duly sworn, according to law, deposes and states as follows: That he/she is the duly authorized agent of the Plaintiff in the within matter. Affiant further states that the within Affidavit is made pursuant to and in accordance with the Servicemembers' Civil Relief Act (SCRA), 50 U.S.C. App. § 521. Affiant further states that based upon investigation it is the affiant's belief that the Defendant, LENORA STAAB is not in the military service. Affiant further states that this belief is supported by the attached certificate from the Defense Manpower Data Center (DMDC), which states that the Defendant, LENORA STAAB is not in the military service. Further Affiant sayeth naught. AFFIANT SWORN TO AND SUBSCRIBED in my presence this Pf _I __ '• y . 77--7. day t 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. Request for Military Status Department of Defense Manpower Data Center Military Status Report Pursuant to the Servicemembers Civil Relief Act Page 1 of 2 MAY-14-2007 08:12:42 -K Last Name First/Middle Begin Date Active Duty Status Service/Agency STAAB LENORA Based on the information you have furnished, the DMDC does not possess any information indicating that the individual is currently on active duty. Upon searching the information data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the current status of the individual as to all branches of the Military. Aky_ Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The Department of Defense strongly supports the enforcement of the Servicemembers Civil Relief Act [50 USCS Appx. # 167;# 167; 501 et seg] (SCRA) (formerly the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's active duty status by contacting that person's Military Service via the "defenselink.mil" URL provided below. If you have evidence the person is on active-duty and you fail to obtain this additional Military Service verification, provisions of the SCRA may be invoked against you. If you obtain further information about the person ( e.g., an SSN, improved accuracy of DOB, a middle name), you can submit your request again at this Web site and we will provide a new certificate for that query.. This response reflects current active duty status only. For historical information, please contact the Military Service SCRA points-of-contact. See: http_//www.defenselink.mil/faq/pis/PC09SLDR htrnl WARNING: This certificate was provided based on a name and Social Security number (SSN) provided https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 5/14/2007 Request for Military Status Page 2 of 2 by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID: WUMWDJVYJ https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 5/14/2007 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff LENORA STAAB De f endant (s) IMPORTANT NOTICE TO: LENORA STAAB 5337 OXFORD CIR MECHANICSBURG,PA 17055 Date of Notice: WWR#: 05614703 Case # U ??? u C??? !^^ YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY"ATTORNEY-AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT'ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE FOLLOWING OFFICE SET FORTH BELOW.. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. 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 BY: ;-a- IIVWAd WOO$Y O, PATRICK THOMAS WOODMAN PA I.D. #34507 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 KOPPERS BLDG, 436 7TH AVE. PITTSBURGH, PA 15219 T-) ik 3 ac . Z cri L?'y -77 r, SHERIFF'S RETURN - REGULAR CASE NO: 2007-01806 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CAPITAL ONE BANK VS STAAB LENORA RICHARD SMITH , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon STAAB LENORA the DEFENDANT at 1949:00 HOURS, on the 2nd day of April 2007 at 5337 OXFORD CIRCLE # 69 MECHANICSBURG, PA 17055 by handing to LENORA STAAB 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 18.00 13.44 .00 10.00 .00 41.44 Sworn and Subscibed to before me this of day So Answers: R. Thomas Kline 04/03/2007 WELTMAN WEINBER R I By: ,% eputy Sheriff A. D.