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Home My WebLink About07-2275 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAFITAL ONE BANK Plaintiff vs. SHERI BECHTEL Defendant 1 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 05744543 C N Pit BNT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. Civil Action No SHERI BECHTEL 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: SHERI BECHTEL 363 MAPLE LN CARLISLE, PA 17013 3. Defendant applied for and received a credit card bearing the account number 5178052449191622 . 4. Defendant made use of said credit card and has a current balance due of $1360.70 as of March 02, 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°s per annum on the unpaid balance from March 02, 2007 A copy of Plaintiff's STATEMENT is attached hereto, marked as Exhibit "1" 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 SHERI BECHTEL INDIVIDUALLY in the amount of $1360.70 with continuing interest thereon at the rate of 25.900 per annum from March 02, 2007 plus costs. James C. rmbrodt,42524 WELT W INBERG & REIS CO., L.P.A. 436 event Avenue, Suite 2718 Pitt burg PA 15219 (41 ) 434 7955 FAX 412- 38-7130 057 4543 C N Pit BNT This law firm is a debt collector atte pti to collect this debt for our client and any information obtain d w' 1 be used for that purpose. • peoplepc~ online ~ Abetter way to Internet. J ~. 5z fastert~, d ~ FREE Accelerator forme first 12 monthsr-a>`BO vahre! 1-888-587-9669 ~` ~ n • Mention Offer Code: COIN r~ Vsit www.peoplepc.com/golcoin UNLIMITED INTERNET ACCESS PeoplePC Online offers the features you would expect from higher-priced Internet Service Providers, including: ® Virus Protection Powered by symantecrM ® Pop-Up BlockerT"" `~ Spam Controls ® Smarfer Smart Dialer Technology ® ~1 More Finail Addresses ® Internet Call Waiting Capita/Q~° Account S Previous Balance =974.13 Payments, Credits and Adjustments =.00 Transactions 229.00 Finance Charges E21.66 New Balance =1,024.79 Minimum Amount Due 51,024.79 Payment Due Date December 23, 2005 Total Credit Line =500 Total Available Credit =,00 Credit Line for Cash (500 Available Credit for Cash s,00 At your service To call Customer Relations or to report n lost or stolen card: 1-800-903-3637 Send pnymenn to: Send inquiries to: Attn: Aenuttance Promsing Capital On<Bank Capital One P.O. Box 790216 P.O. Box 30285 St Louis, MO 63179-0216 SLC, UT 84130-0285 PLATINUM MASTERCARD ACCOUNT OCT 24 - NOV 23, 2005 5178-0524-4919-1622 Page 1 of 1 Payments, Credits and Adjustments Transactions 1 23 NOV PAST DUE FEE t29,00 Take control and pay your Capital One aedit card bill online for free. Eliminate the hassle of writing checks, finding stamps and sealing envelopes. Everything you need to access, review and pay }roar bill is available online. Our Web site offers you a convenient, simple and secure way to manage your account. Visit www.capitalone.mm and register your azcount to start simplifying your life today! As a valued Capita] One customer, you aze eligible to receive a free Year-End Summary for this specific a«ount that recaps your 2005 tLarges, provided }roar account is in good standing and you have made transactions during the calendaz year. Please cal] 1-877-794-4487 before December 31, 2005, to reserve your copy for this account We will begin processing orders in January 2006. We appreciate your business and you deserve great benefits. We'd like you to know that your Platinum card benefits have been updated. For details, visit www.capitalone.com/aeditcardsand dick on the Guide to Benefits link. Thanks for choosing Capital Onr.. You were assessed a past due fee of (29.00 on 11/23/2005 because your minimum payment was not received by the due daze of 11/23!2005. To avoid this fee in the future, we recommend that }row allow a[ least 7 business days for your payment to reach Capital One. " " '~'J~ lt' '' __ _._ __ Finance Charges Pleare ru re°erreride for important in jo»aatian liafi Tarr Pr.;od'r CureponL'ng E ~ o aa~lirdta rde ,lpR E ~ PURCHASES CASH f984.57 .07096% 25.90% (21.66 5.00 .0709E1K 25.90% i.00 ANNUAL PERCENTAGE RATE applied this period 25.9096 • PLEASE RETURN PORTION BELOW WITH PAYMENT /'1,_,, ~~~rvr~a 0000000 0 5178052449191622 23 102479 0100001024791 New Balance (1,024.79 Minimum Amount Due 51.024.79 Payment Due Date December 23, 2005 Total enclosed = Account Number. 5178-0524-4919-1622 P/ arc prim awiliag addrru and/or r-nsailrAmges btlam wring bhu w b1anE ink sverr Apc ~ Gq Stare ZIP Home Phone Atu•rnare Phone #9032808084226660# MAIL ID NUMBER Capital One Bank ~ SHERI BECHTEL P.O. Box 790216 ~s~n~u~~n~i~i~ui~~ u, 363 MAPLE LN St. Louis, MO 63179-0216 m ~ CARLISLE PA 17013-7824 m ~t~~un~~uu~~~nt~~s~u~~uus~i~ur~~i~~uus~~i~~u~n~s~ ° ~ Pleare write yoty arcrount number ort your check or money ordn raadtpayablt to CapitalOnt Bank and mail in tht ent/tved envtlopc r .,_. ~ ~~~ ~ ~ ~ .~ ,,, VERIFICATION CAPITAL ONE BANK vs BECHTEL, SHERI 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, DUDLEY TURNER, 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 hislher knowledge, information and belief. LEY T ~ 2~ ~~ MYRA PRI~JDLE Notary Public Gwinnett County Georgia My Commission Expires July 31st 2009 5178052449191622 A049 WELTMAN, WEINBERG & REIS CO., L.P.A. . V d ~ (/~ "Q ~ ~ C c° ~ W -.~ '`L. ~ 'CIIT~ ~' e-n ~ -~ ,. ~ n ~ cr.~ ~> ~ ~~ ~' =~ Z :~ ~ ~., m G*~ SHERIFF"S RETURN - REGULAR CASE NO: 2007-02275 P COMMONWEALTH OF ENNSYLVANIA: COUNTY OF CUMBER AND CAPITAL ONE BANK VS BECHTEL SHERI ROBERT BITNER Sheriff or Deputy Sheriff of Cumberland Coun t ,Pennsylvania, who being duly sworn according to law, says, the withi COMPLAINT & NOTICE was served upon BECHTEL SHERI the DEFENDANT at 1800:00 HOURS, on the 14th day of May 2007 at 363 MAPLE E CARLISLE, PA 17 13 by handing to SHERI BECHTEL a true and atte ted copy of COMPLAINT & NOTICE together with and at the sam time directing Her attention to the contents thereof. Sheriff's Cost So Answers: Docketing Service Affidavit 18.00 5.76 .00 ~~~:~ ~a,,4~~~~~~p Surcharge 10.00 R. Thomas Kline .00 4~.26Ip ~ / 33.76 05/16/2007 WELTMAN WEINBERG REIS Sworn and Subs ibed to By: before me thi day Deputy Sheriff of A.D. %.. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. SHERIBECHTEL Defendant No. 07-2275-CIVIL PRAEC[PE FOR DEFAULT JUDGMENT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt, Esquire PA LD. 42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 Seventh Avenue, Suite 2718 Pittsburgh, PA 15219 (412) 434-7955 FAX: 412-338-71305 WWR#05744543 Judgment Amount $ 1,495.88 THIS LAW FIRM IS ATTEMPTING TO COLLECT THIS DEBT FOR ITS CLIENT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. } IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. SHERI BECI=ITEL Defendant TO THE PROTHONOTARY: Civil Action No. 07-2275-CIVIL PRAECIPE FOR DEFAULT JUDGMENT Kindly enter Judgment against the Defendant, SHERI BECHTEL above named, in the default of an Answer, in the amount of $1,495.88 computed as follows: Amount claimed in Complaint $1,360.70 Interest from March 2, 2007 to July 20, 2007 at the interest rate of 25.900% per annum $135.17 TOTAL $1,495.88 I hereby certify that appropriate Notices of Default, as attached have been mailed in accordance with PA R.C.P. 237.1 on the dates indicated on the Notices. WELTMAN, WEINBERG &REIS CO., L.P.A. By: ' James C. War br dt, Esquire PA I.D. 42 24 WELTM N, EINBERG &REIS CO., L.P.A. 436 Seve h Av nue, Suite 2718 Pittsbu gh, A 15219 (412) 4-7 55 FA .41 -338-71305 Plaintiff s address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Buildi , 436 7`~ Avenue, Pittsburgh, PA 15219 And that the last known address of the Defendant is: 363 MAPLE LN CARLISLE,PA 17013 ~r ~!~` .~. .~. ~ ~ ~ ~' J -~- T Q ~.. c... ~i -. { ~~t ~ ~.. ~ x ,~ ~ .~ ~-. "SS ~ .t- ~ '~ .~G ., 1 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff SHERI BECHTEL Defendant(s) IMPORTANT NOTICE TO: SHERI BECHTEL 363 MAPLE LN CARLISLE,PA 17013 Date of Notice : ~ ~ ~ ~ ~ 1 WWR$# : :0.574.4•.543 Case # ,_~~ - ~~7s_(,IVI 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: PATR C N PA I. 34507 WELT WEINBERG & REIS CO., L.P.A. 2718 KOPPERS BLDG, 436 7TH AVE. PITTSBURGH, PA 15219 '° c~ ~i C t" W ~3 ~ C.l~~ %- ~"C. t G7 C3 j , ~' . C a ~ 3 Z y ~ I ~ 1 IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. SHERI BECHTEL Case no: 07-2275-CIVIL NON-MILITARY AFFIDAVIT Defendant .The undersigned, who first being duly sworn, according to law, deposes and states as follows: That he7she 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, SHERI BECHTEL 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, SHERI BECHTEL is not in the military service. Further Affiant sa ~is~,e~-'aay CC)~y' ' "__ ' nr ^~Ni~,ISyLVgNIR aft 1!~~ .-s4" - i 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. CC'a , s.~ a ~ t~ ~ ~-- ~ ~, 2 ~~ ~ t .' r-- w ~ -ra Cfa ,.t -<.~_~ O ~ ~-.; ~ ~ .. .~' --# Request for Military Status Department of Defense Manpower Data Center Military Status Report Pursuant to the Servicemembers Civil Relief Act Page 1 of 2 JUL-19-2007 09:03:57 ~C Last Name First/Middle Begin Date Active Duty Status Service/Agency BECHTEL SHERI 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. ~ ~,-~.- 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 seq] (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.htm1 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 7/19/2007 . ~ 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: BJEA WJUDEXM https:llwww.dmdc.osd.mil/scra/owalscra.prc_Select 7!19/2007 ~ ~ '' f 1N THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAP[TAL ONE BANK Plaintiff vs. Civil Action No. 07-2275-CIVIL SHERIBECHTEL Defendant NOTICE OF JUDGMENT OR ORDER TO: ( )Plaintiff (xx) Defendant ( )Garnishee You are hereby notified that the following Order or Jud ment was entered against you on (xx) Assumpsit Judgment in the amount of $1,495.88 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: PRO. ONOTA DE TY) SHERI BECHTEL 363 MAPLE LN CARLISLE,PA 17013 Plaintiff s address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7`h Avenue, Pittsburgh, PA 1.521.9 1-888-434-0085