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Home My WebLink About07-2537IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK I ~ ~ ~,,~~ P l a i nt i f f No : 0~ -~ a s37 ~~ U ~ 1. ~~--- " l~ vs. COMPLAINT IN CIVIL ACTION DONALD E PIPER Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: Samantha T. Estevez,89204 WELTMAN, WEINBERG & REIS CO., L.P.A. 325 CHESTNUT STREET SUITE 501 PHILADELPHIA, PA 19106-2614 215-599-1500 FAX: 215-599-1505 05801930 C N Jer EDC IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. DONALD E PIPER Defendant Civil Action No 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: DONALD E PIPER 80 VICTORY CHURCH RD GARDNERS, PA 17324 3. Defendant applied for and received a credit card bearing the account number 5178052171625102 . 4. Defendant made use of said credit card and has a current balance due of $1405.51 as of March 27, 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 27.740% per annum on the unpaid balance from March 27, 2007 A copy of Plaintiff's STATMENT 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 DONALD E PIPER INDIVIDUALLY in the amount of $1405.51 with continuing interest thereon at the rate of 27.740 per annum from March 27, 2007 plus costs. Samant a Estevez,89 WELTMAN, WEINBERG & RE S CO., L.P.A. 325 CHESTNUT STREET SUITE 501 PHILADELPHIA, PA 19106-2614 215-599-1500 FAX: 215-599-1505 05801930 C N Jer EDC 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. •~ ~ eo IepcrM online p p u Abetter way to Internet. ~'' 5x fastert~-, a ' ~ • FREE Acce/eraMr (w the fret i2 matlhat -a f60 value! 1-888-587-9669 r ~ Mention Offer Code: DOLLAR ` Visit www.peoplepc.corn/go/dollar 003 UNLIMITED INTERNET ACCESS PeoplePC Online offers the features you would expect from higher-priced Internet Service Providers, including: ® Virus Protection powered by Symaniecr" ® Pop-Up BlockerT"" `~ Spam Controls ~ Smarter Smart Dialer Technology ~ ~ More Email Addresses ® (~ Internet Call Waiting Capital Q~° PLATINUM MASTERCARD ACCOUNT NOV 23 -DEC 22, 2005 5178-0521-7162-5102 Page 1 of 1 IG3~ y~0 Account Sutnntary Pa errs, Credits and Ad' tments Previous Balance =984.36 Payments, Credits and Adjustments 5.00 Transactions Transactions 135.00 69 122 1 22 DEC PAST DUE FEE 535.00 . Finance Chazges Your recprest to close your account has been received. Your account will be dosed when it rearlres a f0 balance. New Balance 11,042.05 Uutil theq You will coronae to receive statements and must continue to make payments. All terms and Minimum Amount Due (1,042.05 conditions of the account will apply while a balance remains. Please remember to cut your cards and cancel all Pa ent Due Date January 21, 2006 Ym drazges which automatically bill to your account. Total Credit Line f325 s 00 As a valued Capital One customer, you are eligible to rearve a free Year-End Summary for this , Total Available Credit specific account that recaps your 2005 chazges, provided your account is in good standing and Credit Line fa Cash (325 you have made transactions during the calendaz year. Please call 1-877-794-4487 before January 31, Available Credit for Cash f.W 2006, to reserve your copy for this account. Orders will be marled out by the end of February 2006. At yow service We appreoate your business and you deserve great benefits. We'd like you to know that your visit www.capitalone.com/aeditcards and For details dazed have been u f d b To all Customer Rdations or to report a lost or stden ord: , . p ene its Platinum car dick on the Guide to Benefits link. Thanks for choosing Capital One. 1-800-903-3637 You were assessed a past due fee of 135.00 on 12/22/2005 because your minunum payment was not For frx online amount servi« and speasl automcr offer, log on to: received by the due daze of 12122/2005. To avoid this fee in the fume, we recommend that you www.optilon~mm allow at least 7 business days for your payment to reach Capital One. ~mdpa~n~~ta: SersdN~;erto IT Attn: Remittantt Proaasing EXHIB Capful One Bank Capin! One P.O. Box 790216 P.O. Box 30285 St Laois, MO 63179-0216 SLC, UT 84130-0285 I lmporratrt Acmtvrt Information It's Capital One Bowl week time again! Tune in to ESPN and ESPN2 starting on December 20 for the best in post-season college football action to see your favorite teams fight for bowl championships. And on January 2 at 1 pm (ET), be su:e to tune m to ABC to watch the Capital One Bowl live from Orlando, Florida! Furanee Chatges Pleare ru reverre ride for imfoRant injarm~ian Bolan .arc Pt.wd Cor+npo"d"'t ~~~r APR yeplvdto .ah rn PURCHASES f995.28 .07600%P 27.74% (2269 07600%P 27.74% 3.00 00 5 ~ . . CASE{ ANNUAL PERCENTAGE RATE applied this period 27.7496 • PLEASE RETURN PORTION BELOW WITH PAYMENT CA~c~j0118~ 0000000 0 5178052171625102 22 1042050331001042056 New Balance Sl oa,_ 2.05 Min'nnum Amount Due 51,042_05 Payment Due Date January 21, 2006 Total enclosed f AtcoantNumber. 5178-0521-7162-5102 Plrarrprint mailing addzrr and~w r-mail mgrs below acing bl mblark ink Sneer Apr a Gty Star ZIP Home Phone Almvmtt Phone #9035784278328561# MAIL ID N[JMBER Ca ital One Bank . DONALD E PIPER P I I III I I III N 80 VICTORY CHURCH RD P.O. Box 790216 "' """ "' m ~ GARDNERS PA 17324-9003 St. Louis, MO 63179-0216 ,"„ ~ Irllrrrtllt.allltrrlltl,rllrtttrl,IrrtILlltrttrll,Ilttl~tLl Please turiteyour attmtnt number on yore check or morsry order made Payable to Capital0rst Bank and mail in the mdared envelope. r peoplepcra online ~ Abetter way to Internet, UNLIMITED INTERNET ACCESS i -888-587-9669 Mention Offer Code: DOLLAR rr""77 Visit www.peoplepc.com/go/dollar PecNePC is solely respmsble for Nis rifer, and is not affiliated witlt Capital One. Caphal One does rat povide, endorse a guarantce, and'IS not afflated with, any product a service shown here. Arty trademarks mentioned herein are solely owned by the respective angry. All rigttis reserved. ~' responding to Nis o1Fer, you trey be colimtalicating itdtxmatim about ytxaseff to the txtrnparry that provides this product -for example, tlat you are a Captal One customer. •Pt»plePC Mite: Frst 3 months are ~kd at 54.97 per monN; 59.95 Par momh ItkYeaflel Oiler available to rrew dial-up subscrNers at least 18 years of age end may liol be redeertled with arty other ditrr. 0%er subiact to drarr~ at any tone. Phone tecMical support available la 57.95 per rNnNe. tAccelerelor N tree for 72 months. Offer good for limited time. After the first 12 rtamhs, the Accelerated service wit automatically reaert to the standard PeoplePC ONile service. Offer subject to dlange at anytime. Wrth Pe9pePC Oriine Accelerated, certain Web page text and graphics wiN klad faster when canP~d to staldad dial~up Iniemet service. Adual results may vary. PeoplePC Onllce Accelerated 's my compatide Yritlt ~ Onlire Intemetservlce and speciF~ed Wmdows® Mowsers. PeoplePC OniM Accelerated is not compatible wrih Widavs® 95 wiN IE 5.5 SP2. StxYfce not available m all areas. Aaess fees. taxes, and oNer fees old reslrictians may appy. Telephone tbll charges may apply, even during trial periods. Yw are respaisible For determining whether a taH to one d our access mlmllere will resole n telephone tcg charges. Access maybe linild, esplxiaiy durirg times d peak 119age. Oialitp numbers may be changed ~ PeoplePC$ dlsaetim. Continlxwa use subject to timeM procedlaes. N use is subject to PeoplePC lktl'me's Services AgreerMm and Acceptable Use Pdicy. 56K is the mmcimum speed of service; actual speed may vary. 0 2005 PeoplePC Inc. AI Rights Reserved. PeoplePC Online and Ks logos are trademarks of Peopl~C in rile U.S. and other countries. 0 2005 Capital One Semces, Ma Caphal One is a federally registered service made All rights reserved. O O N ; o rn ~ N n N ~N Cl periadc rate. To obtain the average daily Delance for the your arxro[nt ii it has already been rinsed. For exampe, ou aurlnrized a puniux from a merchant and we rf t. Flow To Awtd A Fktarrca +a<W- Grau Pried. Vw will have a mirimum grace period of 1'a take tiro Mlhng Pe^b~ ce rofeechMaegmem eadt day, add any new l y receive the traMactim iron the merchant aher your ened l b . 25 days whlran finance charge on new purchexa, riew ed purchexs and clew mbar MW a f ert e baginan9 Y fpthis ems R e , a reop r accoum wil tfte ernaanaof the dlarga vWnll Da added m your accoun, p eB, balance [rane Charges ii you pay Your tmal "New Belartce', in w ortem Naice Tor p h h m m y mon the ram o redrts. (If the Coda aN ppaa o _ be ~ Bfi i r de ror em. If there Is e memb~ershiP tea for accen% die fee will carttkae np e atxordance wfth t iemera a ia xt and in time ror h to be credted by Your rro There is ror grace period m cash advarxxs date closin rxx luded in the itc arxx charge r y utpaid arbtract an of each segment~Thi~ ~ II th dsde ile~ Incas to eaM touxua be~ eohas been P ~e n^ fJl as defined above. . g end special vertsfere. In additim, there is M grace period the total "Now ot d if + yy e xgmerrt. ror tiro billi eriod aM 6v{de by the tool segment rig P, 7. llakq Yore Aeasad.Your card or accent cemo[ 6e used in cmMCtim wiM enY imerrvn gam rig o n you P V m erry trarcactim lance " b rturrber of days in the filling period. This gives us the nt h 1r8rtaaG[IaM. . a segme b. Acmiq Fatanea ~9°• TransamloM sduch are raI average dally balance of eac d are assessed fiMnca rriarge 11 3. Ataaal Ptrearaga Rals: IAP111. ri " 8. Notiea AhonR ENrborie Gtaek Cartvsncn. When you authorize us tither m o o atrblect to a grace pe from the date of the vansactim or 21 from the date the may appear as a. The term "Amuel Percentage Rete t i " ' ram your chock to make aone-rime ~ infonne6m f tranxctim is procexed to your Aceaad or 31 frwn the . s netemm m the hoot of th APR If M r b f l l l L I _ tia~Whenr twe ~ pa p x firer calendar tlay o~'New Balancefl~ir~ani [IyAdditi~lly, a did not if ~~ d . frari of n m S the appeare m P mel IBartkced tiro robe e k t aMac yment as a drec ess t x Inromratim iron your check to make an electratic p y you Nnlrg period in tuff, flrerxx• dterges corttksre to accrue to tNS natemax next to the periodic ratelel, p ANNUAL PERCENTAGE MTES dkt fund «aM4r, fade may be withdrawn from your bank ywr upend balance nail the urpeid balance is paid in full, TMa means the[ you may still owe fiMrxx charges, even if rates and correspat g may very quertedy and may increax or decrease based t d in T amt°erd~you~ will rim mceivye youradreCk Duck iron ~ L you pay the entire New Balance indceted m the front of the Md natemem closing date, but 6tl m b oa m the natetl rn6cea, ere discbaed o you. JonaMl, plus the margin prevtady f d fiMnmal irreDMan. y our your nateme V rat do so for the Previous momh. urpeid fnnnce charges our Accwm m of V~~ dn°m TM~ drorges writ be effectr eAodic~sfietem dill periatl covered by Your P BILLING RIGHTS SUMMARY s Or OuestioM About y Of & i W . y are added to the approeble xgme t c. Mirkratrn Fnanea ODerps. For each bagng perio0 that 'n the mmths Jartuarv. ADriI, JWY aM October. F 11-mo. LIBOR) or 6 13-mo. If the code D (Prime) lln Cox ~ r m ore eed rr If you think bat is wrag, or h you your acceutt is er6jrsct to a finance charge. a mirmnun teal FINANCE CHARGE of 80.50 wgl De imposed. It [he , c. LIBOR Repriced MmdeY) appears m t ~iran~~t~ peri eno6c rete{sl the ceparate~ sloe[ esrsan a popiblle art drotaddreas mr tael finance charge rewaring fran the appicetim of your we wfll subtract that 50 ) is Ins than $0 [ di l p , nmm~em~ and cort ANNUAL PERCFIITAGE RATES may ~ aM~ m Me iras of tMs natemem. We must inqunes es ~ a a r ~ ~ . , e a c re perio amoum iron the 80.50 midmun and the taNerence will De vary manMy and m~~nc ~~ ~~ $I~J~~! plra es d i Yaf can ppeared pe error oe problem a wLr~ t ist bill m fi t la billed to the pumhase segment of your accent t d. Tsnporary Reduction kr Planes Qrrga. Wa rexrve the n i P cv , state the mar 'n revlouslY 6adosed [o Thews changes Y°° vAa 6e eHecnva on the first deV of Your billing period no caN ear (]ntomer Relatims number, but doirq x ve preserve your dgma. In your letter, give us the idlowing the ddlar t number ve 'oM [o not assess erry Or BII fnnnce charges for any g b a ch magh. , tormatan: your Mme and accoun a tlescriptim of the ertor our of itro suspected error i rig period 2. Avarge OaaY ealaras Ikt°Lafkq New prdnanl• Fora. 4. Aasasvnans of Leta. Ovarlird[ and fialrrtad Payrrnartl Your accara vela be assessed no more than two of the fees , am and an expanatim, rt pr>saide, of why you believe there is a descripim of i ro a. RM[MY charge la celculated by multipyirg the dagy of yarn accent 1e.9.. Cash balance of each se9r^am listed here trot atxxx during any billing period. Under the vice reserve uro right to wr wnomer agreement f mrat m, error, or if need maw in Y°u the hem you ere tnaurc eban. You do rat Mve to PaV any ou b t i , dverxx, purchex, apeael treMfer, end spedel purdrex) the crorreaponding daily period{e retels) that has been b , y terms o waive or rat to asaen any fees vddrorrt Prior notification m the same or similar ht u y rtg rt, amaxrt in queatim vehile viva are invaetigat ~ s s y prevfoudy disdoxtl to you. At the end of each tlay during to saxes you withaui waiving our rig time u we cernot your question mvesugare in question. While we h the billing period, we aPpY the dagy ceno6c rate for each h f . ter )) ta TRanawitp Yw Aooeut. If a membereh{D fee 5 e report you as delinmrern or take any actlm to cdlect t eac segmrmt of your acCUad to the tleilY balance o we add tp end of the billing period h T . ppearc m tiro frart of des stnemem, you Nava 30 arrant you question. , han at t e aegmem. the casaba of dteee daily calaaetitau w arrive e[ your h days from, the dale this natemaN wee mailed [o you to aying the fee or to have such fee cre8led to you avdd i,t Spedal Rule For Credh Card Purcheaea e odic fiMnce cMr for each aegmem. We add up t rt the tarsi periodic ri g re p it you cancel Your account. During rtes period, you may ve em to ar sults from each sa fiMrce charge for your anx:ant. To gat the dagy balance caninue t0 tin your sccroum wlthorl[ MWng to Day trro To cancel your accoura, you must fee mceuts Ii you have a problem with tM quality of propenV or xrvtces the[ yw purchased with a credt ceN end you ror each sepnent of your accoum, viva [eke the beD!I^IM reectaM t . P rne notify tin by Gelling our Cunraner Rdrdirau Depertmem Mva tried in good faith to correct the pobem with the i ra balance ror each EegmeM antl add snV raw rid arty ppeeriorLc finance dterge Calculated m the previous then subtract any W ' and pay your New Belarae" in Lit lexdudirq the emDerehip 1ae1 Prior to the end of the thinY~aY Padod. ng merchem, you meY haw the ripftt rat to pay the remain emoud due on ds: DrapertV or services. you have rills d e s balance for that aepnem. day paymema or cre6ta posted as of that ay tMt are allocated l e n b s. If You CI9N Yea AoaOUd. Vou can request to dose our accaas Dy celllrq our Customer ReMtloM un protectim obly when the purchax price was more $50.00 std der pucMx was made in your bane sate or anc y a to Nat xprrrcrrt. TNS gives ua aro separate de it you paid tiro However m y pepennlam. You must destroy your crelfit certlls) and wttbln 100 miles of your melkng atldrms. (If eve own or ti , . ror each segmam of ywr accw Now Balance shaven m blur previran eutemem in fJl for accent access drocks, cancel all preauthorizatl billing, yea eclxun. If yw do rat cencd x ueir d ro operate the mercham, or It vise mailed you advertiaemem tar the PrtpenY or xnvices, all purchaxa it yea new 6elanee wee zero or a cmdit emomt), Mw urthaae or apaeial q an cea preauthorizetl billirrp arrarrgemerws, w° will eonaider are coverall regardasa of amour a loudon of purchsx.) trarreactian which post to your p purtltax aegnems are rat added to the daily balances. We ll recdp of a surge your a1d11eri:aDm m reopen Ywr your acrbran vela rot be dosetl AtlBnaallY eccamt Plxx remember to sign erg correspondence. y calculate rice average dally balance by eddrq all itro da balances together and 6vidrg the wan by tfte raanber of . , umfl you DeY all amwrna VW owe ua irrdu6np: enY ast ea d t pons nor ePMY m consume ran-credN card accounts the days in the curem bilFrg cycle. To celWa[e your tael muhipyy ywr average daily balance by the char e fi herg , p traMactiars you have authorized, fiMrce due fees, overiimh fees, returned paymem fees, cam ! Daes not aDPly to busixss ran-cladd card accamts g , Mrxre daily periodc race and by the number of days in tlro dlhrg advance fees and any mbar fees aesesaed to your amousa whether s f th n: see our ti period. Due to raxdirg m a dagy Dania, there may bee between else cMadadon eM rice amours of h ri or e e accenn. Vou are respatNNe they appear m your aceoum at tiro time you request to o Capial One apporta intonnetim privacy protec website at vvww.caprteltne.com. ance t va slig fnnnce barge actually eaxssed. ment hi t f clox the etx9un or they are ktwrre0 srbeequent to your regcen to dose tiro accwm. Tt:a may reauh in Captal One is a federally rapineretl service mark of Capial pre HMfxael Corporation. All ngms exrved. ° 2003 s sta e t b. If [he code 2 or N appear m the fran o nee to 'Balance Rne Appietl Ta," we multipy tiro ____.,.. cMrgee ap~eadrg on Y°ur eccaan aher you have ._._ .,.,.,.,,.. ,. ha dMed or the reocerera of CeimN ~ O7 LGLB,4K Irtpdtrd Ne[iea: Paymaas you mail m us will be eredi[ed to your arroratt as Oi the bu8iness day vue receive: it, prowaed 111 Y°u satd the Dmmm ponim of rtes su[emem and your drock In tfro endoxd reminarce mvelopa and 121 your paymrxn is received in our Drocessirg Getter Dy 3 p.m. ET 112 ram PT). Please allow et least flue l5) Duaintesa days ror postal Oellvery Peymeme received DY ua a[ enY aher locetim or in any aher foM meY rrot be cmdted es of the deV we recd uthonie rw m~in°ka a ortemiime ectmraY'e [ er~naler adebit f yourgbaiaii~W~ Pleex do rat use staples, paper ckps etc. when preparing your paymem. When you aeM us a tirocklsl. You a eccarnt fa the amountt of the dreck. This audariznim eppgea to all checks eceved during the dliing eyrie even if earn 6y someme elx. If we cemm process the treMior, you eudarize ua to make s charge ageinn your Dank account using the dvack, a paper drab or aher item. VERIFICATION CAPITAL ONE BANK vs PIPER, DONALD E 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, TRACY TAYLOR, Authorized Agent, of CAPITAL ONE BANK, Plaintiff Herein, that he/she is duly authorized to make this Declazation, 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. T~A J TAYL Notary ~ is MYRA FRih;CLE ' Notary Fupiic Gwinnett Co~mty Gaorgia My Commission Expires Juiy 31st 2009 5178052171625102 A049 WELTMAN, WEINBERG & REIS CO., L.P.A. W ~~ e "69. ~J ( _~ .rt~ J>:: :~~ N c-~ ..../ 7 N C...3 ~, 0 tT'" 'T"7 ~'7 ~~_~) :) ~ f ~ ;"I'I :~ SHERIFF'S RETURN - REGULAR CASE NO: 2007-02537 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CAPITAL ONE BANK VS PIPER DONALD E JASON VIORAL Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon PIPER DONALD E __ the DEFENDANT at 1857:00 HOURS, on the 15th day of May 2007 at 80 VICTORY CHURCH ROAD GARDNERS, PA 17324 CINDY PIPER, WIFE by handing to 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 9.60 .00 10.00 .00 37.60 Sworn and Subscibed to before me this day So Answers: R. Thomas Kline 05/16/2007 WELTMAN WEINBERG REIS By. D uty Sheriff of A.D. ' ,• •~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DNISION CAPITAL ONE BANK Plaintiff vs. DONALD E PIPER Defendant No. 070-2537 CIVIL TER STIPULATION OF THE PARTIES FOR PAYMENT AND FOR THE ENTRY OF JUDGMENT BY CONSENT FILLD ON ?BEHALF OF Flaintiff COUNSEL OF RECORD OF THIS PARTY: Michael J. Dougherty, Esquire PA. I.D. 76046 Weltman, Weinberg, & Reis, Co., L.P.A. 325 Chestnut Street, Suite 501 Philadelphia, PA 19106 215-599-1500 WWR#05801930 THIS LAW FIRM IS ATTEMPTING TO COLLECT THIS DEBT FOR ITS CLIENT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. s 'l IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK, Plaintiff vs. Civil Action No. 070-2537 CIVIL TER DONALD E PIPER, Defendant STIPULATION OF THE PARTIES FOR PAYMENT AND FOR THE ENTRY OF JUDGMENT BY CONSENT TO THE PROTHONOTARY: Kindly enter Judgment in favor of Plaintiff and against the Defendant, Donald Piper, above-named, in the amount of $1,638.66 pursuant to the Stipulation of the Parties for Payment and for the Entry of Judgment by Consent, as follows: 1. Defendant admits indebtedness to Plaintiff in the amount of $1,638.66 with continuing interest thereon at a rate of 6.00% per annum plus costs from June 4, 2007. 2. To secure the repayment of said indebtedness, Defendant agrees that Judgment by Consent will be entered in favor of the Plaintiff and against the Defendant, Donald Piper, in the amount of $1,638.66 plus continuing interest thereon at the rate of 6.00% per annum from June 4, 2007 and costs. ~ a '~ 3. Plaintiff agrees not to Execute on its Judgment so long as Defendant causes to be delivered to Plaintiff the following payments in full by 12:00 NOON on the following dates: (a) $70.00 due by June 30, 2007; (b) no less than $70.00 per month due on the 30th day of each consecutive month thereafter until the Judgment amount plus accrued interest and costs are paid in full. 4. All payments are to be made payable to the order of "Weltman, Weinberg, & Reis" 5. All payments due under this agreement are to be received at the offices of VVeitman, Weinberg & Reis, Co., L.P.A., 325 Chestnut Street, Suite 501, Philadelphia, PA 19106. 6. In the event of default, each payment received shall be first attributed to costs, interest and then to principal. 7. Time is of the essence of this agreement and should the Defendant fails to have in the hands of Plaintiff or Plaintiff s counsel any payment in full within five (5) calendar days of the stated due date, then Plaintiff shall be immediately free to issue Execution as well as pursue all other remedies, in law or in equity, to collect the full balance of the Judgment entered hereunder plus appropriate additional interest and costs. 8. No act or omission of the Plaintiff, nor of anyone alleged to be acting on its behalf, shall constitute a waiver, estoppel, or any other excuse for non-performance of any duty undertaken by the Defendant in this Stipulation which the parties agree is final and complete. ~/ •"~ 9. Intending to be legally bound, the parties set their hands and seals this Z 7 day of~, 20 ,I''~ . THIS LAW FIRM IS ATTEMPTING TO COLLECT THIS DEBT FOR ITS CLIENT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. WELTMAN, V~INBERG & REIS CO., L.P.A. By: Michael J. ,Esquire PA. LD. 76046 Weltman, Weinberg, & Reis, Co., L.P.A. 325 Chestnut Street, Suite 501 Philadelphia, PA 19106 215-599-1500 WWR# 05801930 Donald Piper By: OYICi ~ , r ~ ~ ~ ~~.. ~OG~J~ Defendant ~ ~ ~~ ~ ~ bdr ~ ~0.0~ ~- /n 4n'`~' r n ~ a ~., C ...~ ~,~y, ~ ~~ ~_ ~~~ ~ ~~ t~ rr ....~ < ~ R - ~ t~ ~O o ~~ Q .~ ~ ~ a ~ ~. ~ =~ ~- ., ~- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. Civil Action No. 070-2537 CIVIL TER DONALD E PIPER Defendant Michael J. Dougherty PA I.D. 76046 Weltman, Weinberg & Reis, Co., L.P.A. 325 Chestnut Street, Ste 501 Philadelphia, PA 19106 215-599-1500 NOTICE OF JUDGMENT OR ORDER AS TO DONALD PIPER TO: ( )Plaintiff (xx) Defendant ( )Garnishee You are hereby notified that the following Order or Judgment was entered against you on (xx) Assumpsit Judgment in the amount of $1,638.66 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 ( ) Default ( ) Verdict ( ) Arbitration ( ) Award (XX) By Consent Prothonotary WWR# 05801930 By: 5 ~- PRO ONOTARY (OR DEPU 0 v sta. r` ~".~ i ~J