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Home My WebLink About07-2886IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. SUSAN MASON WAYNE J MASON Defendants w 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 05829398 C N Pit SJS IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. Civil Action No SUSAN MASON WAYNE J MASON Defendants 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. Defendants are adult individual(s) residing at the address listed below: SUSAN MASON 811 ALLENVIEW DR MECHANICSBURG, PA 17055 WAYNE J MASON 811 ALLENVIEW DR MECHANICSBURG, PA 17055 3. Defendants applied for and received a credit card bearing the account number 4121741348601852 . 4. Defendants made use of said credit card and has a current balance due of $1454.54 as of April 09, 2007 . 5. Defendants are 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 25.900a per annum on the unpaid balance from April 09, 2007 A copy of Plaintiff's statememt is attached hereto, marked as Exhibit "1" and made a part hereof. 7. Although repeatedly requested to do so by Plaintiff, Defendants have willfully failed and/or refused to pay the balance due to Plaintiff. Wherefore, the Plaintiff prays for judgment in its favor and against Defendants SUSAN MASON AND WAYNE J MASON jointly and severally in the amount of $1454.54 with continuing interest thereon at the rate of 25.9000 per annum from April 09, 2007 plus costs. ~r- f+ - James C Warmbrodt,42524 WELTMAN; EINBERG & REIS CO., L.P.A. 436 Seen h Avenue, Suite 2718 Pittsk}izrg PA 15219 (412),''43 -7955 FAX:%41 -338-7130 058939 C N Pit SJS This law firm is a debt collector atte,~np ng to collect this debt for our client and any information obtain~d will be used for that purpose. .~, First 3 months hall-price '' a mort8r $8.95lmo. tltereafter SIGN UP TODAY: ' 1-877-778-1207 Mention Offer Code: ONYX Or vtsR www.peoplepc.com/go%nyx Capita/Ipy~• VISA ACCOUN'P 4121-7413-4860-1852 Accotmt S Previous Balance 5981.02 Payments, Credits and Adjustments ;.00 Transactions ;35.00 Finance Charges ;21.81 New Balance ;1,037.83 Minunum Amount Due (1,037.83 Payment Due Date October 19, 2005 Total Credit Line (1,500 Total Available Credit ;.00 Credit Line for Cash ;1,500 Available Credit for Cash ;.00 At your service To c ]l Customs Rel.tion: or to report a to:t or rtolm nrd: 1-800-955-7070 For free online account service and spcaal automer offer, log on to: W W W.mplt91011GCOm Send paymentr to: Send inquvies to: Attn: Remittance Processing Capital One Bank Capital One P.O. Box 790116 P.O. Box 30285 St Louis, MO 63179-0216 SLC, UT 84130-0285 Important Account Information Twelve unsung heroes of College adiletics aze competing for the honor of Capital One National Mascot of the Yeaz -and you can help deade who wins! Each week, the mascots go head-to-head in competition, but only one will win the coveted tide and ;10,000 for their school. Go to rapitalone.com where you can vote daily for your favorite mascot -and don't forget to tune into the Capital One Bowl on ABC on Monday, January 2, 2006, to see who wins! rn uc'i AUG 20 -SEP 19, 2005 Page 1 of 1 Payments, Credits and Adjustments Transactions 1 19 SEP PAST DUE FEE (35.00 You were assessed a past due fee of;35.00 on 09/19/2005 because yom minimum payment was not received by the due daze of 09/19/2005. To avoid this fee in the future, we recommend thaz you allow at least 7 business days for }roar payment to reach Capital One. Finance Charges Pkare.ru reronrr ndejor important information Ba! rear Perm Cwrrspoadmg FINANCE yp!vdto >atr APR ~I~RGE PURCHASES f991.53 .07096% 25.9096 (21.81 CASH f.00 .07096% 25.90% 3.00 ANNUAL PERCENTAGE RATE applied this period • PLEASE RETURN PORTION BELOW WITH PAYMENT ~~a 0000000 0 4121741348601852 19 1037830050001037839 New Balance ;1,037.83 Minimum Amount Due ;1,037.83 Payment Due Date October 19, 2005 Total enclosed ; ~~~ Accoant Numbs: 4121-7413-4860-1852 P!<mep.int mailirsg adhus~b e-mailtbmgu brl wring bl wb/a<k iak 25.9096 Scr«i Ape # Gty Sate ZIP Home Phone Altematt Phone #9026394389781665# MAIL ID NUMBE$.~ SUSAN MASON TR~Lr"`°' T Capital One Bank ,~ WAYNE J MASON ~I ^ P.O. Box 790216 ~s~u~n~r~~t~nu~t~~ `o 811 ALLENVIEW DR St. Louis, MO 63179-0216 ~ ~ MECHANICSBURG PA 17055-6190 ~t~~uu~~uu~~~url~r~u~~uut~t~m~~t~~uns~~t~~u~ts~t~ ° ~ 003 peoplepc®online u Abetter way to Internet. PeoplePC Online offers the features you would expect from higher-priced Internet Service Providers at half price for the first 3 months! ® Email Virus Protection ~~ ® Pop-Up BlockerT"" Jl~ `~/ Spam Controls n~l• 4 Smart Dialer ~ (yJ~ Phisher Security Internet Call Waiting Pfeare unite yaw acmurst rsumber on yaws rJxrk or money or&r made payable to Capital One Bank and mail in the enclared envelope. peoplepc®online u Abetter way to Internet. UNLIMITED INTERNET ACCESS SIGN UP TODAY! 1-877-778-1207 Mention Offer Code: ONYX Or visit www.peoplepc.corn/go/anyx PeoplePC is solely resporlsibk: for this offer, and is no[ affiliated with Capital One. Capital One does not provide, endorse a guarantee, end is not aftfiiated wkh, any product a service sltwvn here. Any trademarks mentioned herein are solely owned by the respective entity. Ad rights reserved. By respaMing to this offer, you may be tpmmlmicafing irforrtlakon about yolusek to the company that provides this product -tor example, that you are a Capital One customer. `PeoplePC OrYine: Fist 3 maltlts of service are billed at $4.97 a monM; $9.95 a morrttt thereaffer. Offer available to new dial-up subscribers at least 18 years of age and may not be redeemed wiM any other offer. Offer subject to change at any time. Phone technical support available for $1.95 per minute. For questions, call tod free at 1-877-778-1207. Service not available in all areas. Access fees, taxes, and other fees and restrictions may appty. Telephone toll charges may appty, even during trial periods. You are resporlsiWe for determining whether a call to one of our access numbers will resuk in telephate tell charges. Access may be limked, especialty during times of peak usage. Dial-up numbers may be changed at PeopkiPC~ discretion. Cominuous use subject to teneout procedures. !UI use is subject to Pe~ePC Onlirre's Services Agreement and Acceptable Use Policy. 56K is the maxirtxlm speed of service; actual speed may vary. ® 21x18 PeoplePC Inc. All Rights Reserved. PeoplePC Online and ks logos are registered trademarks of PeoplePC in the U.S. and other countries. ® 2006 Capita One Services, Inc. Capital One is a federally registered service mark. AN rights reserved. 0 0 O0; ~ ~N periodic rate. To obtain the average daily balance for the Nllirq pedod covered by tMs natamem, m take fife begimirp balarce of eaM xpnern each day, add any new treraactiorte to each eepnern, and subtract any payments credin. (lf the code N appears m the front of this natemeM rtexi to 'balance Rate Applied To,' vce also subtract any lxpaid firarce darpe included in the balance of each aegmem.) This gives us the daily balance of each aegmern. Then, vve add tp all the logy balances for each segmem for the billing pedod and 6vitb by the total rnanber of days in ins billirg period. TNa gives us the wrage dally balarce of eaM segment. 3. Amral Parewitya fltea lAPfll. a. The term 'Annual Percentage Roe' may appear as 'APR' an the front of this natamem. b. If the code P IPdme), L 13-mo. LIBOR), C (Certificate of Deposits, or S IBankrartl Prime) appears on the irarn of tMa ata[emem next to the perioBC ratelsl, the pedodc rates and rnrrespmMkq ANNUAL PERCENTAGE RATES may very quarterly eM may ircreax or decreax baxd n the stated inrficea, ea found in The Web Sbcet Jouma/, plan the margin previously daclosed to you. These chengea will be effective m the fire[ day of your billing pedod covered by your periodic natemeni ending the month January, APriI, July end October. c. If the code D IPdmel. F 11 -rtw. LIBOR) or O 13~rio. LIBOR Repriced Monthly) appears m the teen of your statement nett to the pedo4c ratelsl, the periodic rates and cartespondirg ANNUAL PERCENTAGE RATES may vary monMy eM may Increase or decreax Daxd w the stated indcea, as fond in The Wea Strcef Jorxml, plus vn~ margin previously 6adoaed to you. Thex chengea II be effective on the first day of your dllirq pedod eaM mornh. 6. Atsamerp W Lrte, Ovaririia artl flehmed Paymra Fees. Your acewm vAll De assessed rc more then two of the fees lined here that occur during any billing pedod. Under the terms of your wnaner agreemem, we rexrve the fight to waive or riot ro asxss any tees withan prior rcuficetion to you without waiving our dgM to aexsa the same or similar t a later ame. 5. flsnewing Yarn Aecout. If a membersHp 1x ppeare on the free at this natamem, you have 30 deya from the date this natemrxa wee mailed to you to avoid peykig the tee or to have ardt fee credited to yw if you carnal your accoun. Dudrq this pedod, yw may carmnue to use your acetxxa whhout laving to pay the memDe~ p tea. Ta cancel your accotnt, you man n tify 6y calling wr Customer Relations Departmrxa and pay your 'New Belarce' in NI (exclrafirp the bership teal prior to the end of the Shiny-day pedod. 8. If You pofe Yav Aceeaa. You can rertlren to dose your account by celllrtg our Customer Relation Departmem. Vou mart denroy your credit cordial and account access Meeks, caned all preetrModzed billing, and ceeae uainp your ecrwtrit. If you do not cancel preeuthodze0 filling errarganrrrns, we will correider recelpi 01 8 tlarge ywr etrthodzaoon to reopen ywr accent. Adadonlly, ywr account wilt not ha closed until yw pay ell emoums yw owe ua ircltrdng: any transsctiarts yw haw euthodzed, fnatce Merges, Pan due fees, owdimit fees, rewrned payment fees, cash adverce fees and any ether ixe assessed to ywr accent. Yw are reapenide br these emraaas whether Mey appear m yex accent et the time you request to close the acewa or they ere incurred aubsequen[ to ywr requen to clox the eccoun. Tfus may reaWt in charges eppeadrq on ywr acceen ahar yw haw ywr accaert it it has already been closed. For example, if yw arrthodzed a purchax from a merchant and we ceiw the transsction ham fife mercham ahar your ccara has been dosed, your secant will be reopened, the arnant of the Merge will be added to your xcant, and you will 6a reaponelble for payment. If there la a emberahip fee for your aceount, the fee will conrinue to be charged, to the exiem pertnkted by law, omit the account belarce has been paid in hgl as defined above. 7. Uakg Ytar Aceauat.Vwr card or accent cannot be used in connection with any imertat gemdirg irertaactlma. 8. Noliee Abed flecbania CMek Crrtvrscn. 1Yhen yw provide a check as payment, you autMdze us tither to 'nformation from your Mack to make aorta-time electrode hrd trarislar from your bank accent or to process tla paymrmt as a check trarroactian. When we use informatim Irom your check to make an electrode fund trarufer, funds may be witlxhawn ban your bank acetltxtt as soon as the same day we receive your peymern, and you will not recdve your Mack beck teen your financial institution. BILLING RIGHTS SUMMARY Iln Cax Of Errors Or Gueniorra Aban Ywr Billy If yw tfrnk your bill is wrorg, Y yw road information m a trarreecnion or bill, wdie to us an a separate shit as coon as poetida at the address for 'rtpidea ahovm on the frtnt of this natamem. We must hear from you rp later then e0 days ahar we sent you the first bill on which the error or problem appeared. Vou can cell our Cunaner Relniom rwmber, but doing so will rct preserve your rigMa. In your lever, give us ilo fdlowing informatm: your name and account number, the ddler sum of the suspected error, a descdpdon of the ertar and an exdanation, 11 posaide, of why you heHeve Mere Is errer, or it you road more inlonnatian, a tkacdptim of the item you are unsure abort. Vou do not hew to pay any amount in quesion wfgle wa are investigating it, but you are Hill adigatetl to pay the pads of your Dill that are rat question. Wtale we inveaugete your question, we cervict report you as ddiraltrent or take any action to cdlect the emant yw question. i,t Spedal Rde for Credit Card Purchases If you have a problem with the quality of property or services that yw purchased wiM a credit card and yw have tried in good faith to cerrem fife problem wiM tla mercham, you may fbve [he fight not [o pay the remairgrq amtxnl due on the property or xrvicea. Vou haw this proteaim ody when Ute pumhex price was more then 450.00 and the purehsee wee made in ywr fame state or witlgn t 0O miles Of your maigrq address. (If we own or oper rtext era ~ e, or If vve mailed you the prrgertY or xrvicea, all purchaxs are rxteered relprdess of amoum or location at purdiaae.) Pleex remember to sign ell correspondence. t Does opt app/y m consumer eon-credit cart/ accornrs t Does not app/y to business zwn-erecter ceN accamts Capital One supports intoanation privacy pmtr:ctim: sx our webste at www.ca larc.com. Capital One is a to rally regisered xrvice mark of Capful One Fnrcial Corporation. All ddtta reserved. 0 2003 Capital One Ot LGLBAK 1. lbw To Avoid A Fatarga Charge. i'a. Graea Prod. Vou will have ragemidmum grace pedod of behr~icewvaarnh rew ape~iiel porch seeantlwnew'otlter Merges if you pay your fetal 'New Balarce', in accerdarxxt with the Importsm Nmice for payments below, ant in time for it to be credted by your rext nnemmt doairq date. There is ro grace pedod an cesh advarxxa and spatial lrerafere. In addition, there is rc grace pedod on any transaction if you tb rrot pay the total -New balarce.- b. Aeerafrg Fbanca Qurga. TranSamiora which are rot object to a grace pedod are asxaxd firar,ce tlarge 71 from the date of the vartaaction or 2) from [he date the tranxction is processed to your Acroum or 31 from the fink calendar day of the wrtrra hillktg pedod. Addtionally, if you rid rie pay the 'New Balance' from the previous dllbg period in full, flnexr cherpes rxxakare to accrue to your tnpaid Delarce nail the urpeid Delarce is paid in full. This means that you may Hill owe firbrxx Margea, even if you pay the entire New Balance kidicated an the frrnt of your natamem by the rcxt natemera doairtg data, but did not Oo x for the previous mornh. Urpaitl finance charges are added to the apdMade aepnem of your Aceount. tc. AHkikezin Fnanee Ch~q. For xM bgRrtg pedod that your aceexa is abject to a finance charge, a midmum tctel FIN4r1CE CHANGE of 50.50 will he impoxd. If the teal finance charge resuhirg from tlo application of your periodic retels) is leas roan 50.50, we will suMract that amount from the 50.50 midmtm and die difererice will De billed to the purMax aegrnerH of ywr xcotn[. td. Tatrpvery fleduetian kn Fkanea Charge. We rexrw the ght to ever asxae any or all finance chergea for any given 2. Avrag~i D y Balrwa Iktdudkq Naw gralmasl. a. (acerice merge Is calwlated Dy mtidplyirq the dally balance of eaM segrtrent of your aceourn le. g., cash dvarrx, purdax, special tremier, end apadel purchaxl by tM certeaponding logy padodc rotate) tMt has been prevlwaly diatloaetl to you. At the end of eaM day tludng the billing period, we apply the daily periodic rate for eaM aepnent of your eccara m the daily balance of eaM aetsnem. Tlrm at the end of the hillirg pedod, we add rp the reaWta of thsse elegy ulCWatiea to srdve e[ you pedotlic finance large for eaM xpnem. We add uprthe resWta from eaM aegmem to arrive at fife total periodic finarce charge for your accern[. To get die logy balance for eaM sepnrxn of year accent, we take die DeglnNng halerce for eaM eagmem end add any row ttarmctiorn rid any Ixdodic trance charge calculated on the previous day's balance for Mat eegmraa. We then suMract any paymema or credits Posted as of tM[ day Mat are allocated to Mat xtTriern. TNa gives us the separate deity balance for each segnent of your accent. However, if you paid the New Balance sfown on ywr previous sretemratt in 1WI (or if your new 6alertce was zero or a creth amount), new vanssctiora which prat to ywr purdax or special pun7tase segmeMa era rot added to the daily baarces. We calculate Me average daily 6elarvx by addrtg ell fife daily balances together and dvi6rq the sum 6y the number of the days in Me wrtern billing cycle. To celcWate ywr total finance Marge, mukiplyy ywr average daily belarce by the daily pedodc rete end by the number of Mys in da billing period. Orre to roun6ng analogy basis, there may be e nlgm vadarce 1>Btvleen tNa calculation end the amotnt of finrice charge actually esseased. b. If the code 2 or N appears m the front of this natemant rcxt to 'Balance Rate Apdied To,- we multidv the Irryetara Notice: Paymerns yw mail m W will ce credited to ywr atxntxtl as of the Grain9s day we receive it, provided nl yw send the bottom portion of this statement ant your dteck in the enclosed remittance envelope and 121 ywr payment is recelvetl In wr Drtxzssirp carter by 3 p.m. L7 (12 ram PT). Please allow at lean flw 15) business days for poaul delivery. Paymems received Dy us at any ahn location or in any other form may ever be credaed as of the day we receive them. Our btxuness days am Monday Mreuph Saturday, exdudrq Midays. Please do rot ux napes, paper dips etc. when prepedng ywr paymem. When you xid ua a drx:k(sl, yw etrtMdze us to make aorta-time electrode tranakr debit from ywr bank vent for the amwrn of the check. Tltia autfodza[im applies to all docW receved during fire billing cycle even if gem by sommrte elx. It we cenriot process tie reenter, yw errthodze us to make a Marge againn your bank accaxrt using the deck, a paper draft or other hem. VERIFICATION CAPITAL ONE BANK vs MASON, SUSAN The undersigned does hereby verify subject to the penalties of 18 Pa.C.S. Section 4904 relating to unswom 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 aze true and correct to the best of his/her knowledge, information and belief. i'"" ~ TRA T LOR ~~-.. Notazy Public ~(y9y ._ .J ~ '~ ~ ~_~V +V ~~.'~ yy l..~i.~~'i~TV~, ~L..V~1.A ~i l 1 .: .. iAi L.734CP'1 r~/~41 {1 i~4I 1, `J i ` ~.~ 4.~ rY' F G~ c i~, Ll~r ~ 4121741348601852 A049 WELTMAN, WEINBERG & REIS CO., L.P.A. ~ n ~ A, a C-, ~.' ~~ ~ ~ }~~ ~~: ,. r~. tea r ~~ v~ , -=~ ~~ -~ c n ~ -~ ~.:J SHERIFF'S RETURN - REGULAR CASE N0: 2007-02886 P ,, • .a COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CAPITAL ONE BANK VS MASON SUSAN ET AL 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 MASON SUSAN DEFENDANT the at 1008:00 HOURS, on the 18th day of May 2007 at 811 ALLENVIEW T)RTVF MECHANICSBURG, PA 17055 SUSAN MASON 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 18.00 Service 10.56 Affidavit .00 Surcharge 10.00 5~3~ ~v"7 ~,,, 00 3 Sworn and Subscibed to before me this day So Answers: R. Thomas Kline ` 05/21/2007 WELTMAN WEINBERG REIS ~ ~ By: - eputy eri f of A.D. SHERIFF'S RETURN - REGULAR CASE NO: 2007-028$6 P ,'. • COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CAPITAL ONE BANK VS MASON SUSAN ET AL 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 MASON WAYNE J the DEFENDANT at 1008:00 HOURS, on the 18th day of May 2007 at 811 ALLENVIEW DRIVE MECHANICSBURG, PA 17055 SUSAN MASON, 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 6.00 Service .00 Affidavit .00 Surcharge 10.00 3~~ -~o ~ C~..,, 00 1~` 6.0 0 Sworn and Subscibed to before me this day of , So Answers: r R. Thomas Kline 05/21/2007 WELTMAN WEINBERG REIS Deputy Sherif A.D. ~! IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK, Plaintiff vs. Civil Action No. 07-2886-CIVIL TERM SUSAN MASON WAYNE J MASON Defendant PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter Judgment against the Defendant, SUSAN MASON WAYNE J MASON above named, in the default of an Answer, in the amount of $1580.46 computed as follows: Amount claimed in Complaint $1454.54 Interest from Apri19, 2007 to August 9, 2007 at the legal interest rate of 25.900% per annum $125.92 TOTAL $1580.46 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 W R RODT, ESQUIRE PA I.D.#4 24 Weltman ein rg & Reis Co., L.P.A. 2718 K pers B dg. 436 Se enth enue Pittsb rgh, A 15219 (412 434 955 WW # 5829398 Plaintiffs address is: V c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7`h Avenue, Pittsburgh, PA 15219 And that the last known address of the Defendant is: 811 ALLENVIEW DRIVE, MECHANICSBURG, PA 17055 Y IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK r v Plaintiff Case # -~ ,~~ ~~ WAYNE J MASON Defendant (s ) IMPORTANT NOTICE TO: WAYNE J MASON 811 ALLENVIEW DR MECHANICSBURG, A 17055 Date of Notice: WWR#: 05829398 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 PATRICK THOMAS WOODMAN PA I.D. #34507 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 KOPPERS BLDG, 436 7TH AVE. DTTT~RTTR['tH _ PA l 5219 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK l Plaintiff Case # ~~ ~ ~~~ `~ SUSAN MASON Defendant(s) IMPORTANT NOTICE TO: SUSAN MASON 811 ALLENVIEW DR MECHANICSBURG, P~A l1~7055 ~J y~- Date of Notice : 1 V 1 X ,fib' ~,7~ ~~0 1 / WWR#: 05.829398 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 PATRICK THOMAS WOODMAN PA I.D. #34507 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 KOPPERS BLDG, 436 7TH AVE. DTTTCRTiA(:LT UA ~ ~i 7 ~ 9 Request for Military Status Department of Defense Manpower Data Center Military Status Report Pursuant to the Servicemembers Civil Relief Act Page 1 of 2 AUG-15-2007 10:19:47 C Last Name FirstlMiddle Begin Date Active Doty Status Service/Agency MASON SUSAN 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. ~r r~. ,err-~- 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. §§ 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: #~ttp•//www defenselink mil/fa4/pis/PC09SLDR.htm1 WARNING: This certificate was provided based on a name and Social Security number (SSN) provided hops://www.dmdc.osd.mil/scra/owa/scra.prc_Select 8/15!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: CIFGCNMOFU https://www.dmdc.osd.miUscra/owa/scra.prc_Select 8/15/2007 Request for Military Status Department of Defense Manpower Data Center Military Status Report Pursuant to the Servicemembers Civil Relief Act Page 1 of 2 AUG-15-2007 10:20:01 < Last Name First/Middle Begin Date Active Duty Status Service/Agency MASON WAYNE 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. rta~r~.1~.~,-a~-- 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. §§ 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 html 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 8/15/2007 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: CIFHNNQWFO https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 8/15/2007 IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DNISION CAPITAL ONE BANK, Plaintiff vs. SUSAN MASON WAYNE J MASON Defendant Case no: 07-2886-CIVIL TERM NON-MILITARY AFFIDAVIT 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, SUSAN MASON WAYNE J MASON 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, SUSAN MASON WAYNE J MASON is not in the military service. Further Affiant pis day ,,~m~;.~,,.c_ -. - ..,. ~.. 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. ~_ ~ ~k ~ ~' ~ ~ 6 ~' ~ °~ ~ L `;'. >r l:~.,... ~, ~,,f ~ ~ c~ ~ ~~ ~•,~ 4:a r';,~ ^Yi ~~ ~ ~a~, ,~- IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK, Plaintiff vs. Civil Action No. 07-2886-CIVIL TERM SUSAN MASON WAYNE J MASON Defendant NOTICE OF JUDGMENT OR ORDER TO: ( )Plaintiff (xx) Defendant ( }Garnishee You are hereby notified that the following Order or Judgment was entered against you on 8 '! 00 (xx) Assumpsit Judgment in the amount of $1580.46 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: 5 ~, D PRO ONOTARY (OR DEP ) WAYNE J MASON 811 ALLENVIEW DRIVE MECHANICSBURG, PA 17055 Plaintiffs address is: c/o Weltman, Weinberg 8c Reis Co., L.P.A., 2718 Koppers Building, 436 7`s Avenue, Pittsburgh, PA 15219 1-888-434-0085 ~ } IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. SUSAN MASON Defendant No.07-2886-CIVIL TERM PRAECIPE FOR ENTRY OF JUDGMENT BY CONSENT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan, Esquire PA I.D. #47437 WELTMEN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412)434-7955 WWR#05829398 .~. , IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CNIL DNISION CAPITAL ONE BANK Plaintiff vs. SUSAN MASON Defendant Civil Action No. 07-2886-CNIL, TERM PRAECIPE FOR JUDGMENT BY CONSENT TO THE PROTHONOTARY: Kindly enter Judgment against Defendant, SUSAN MASON, in the amount of $1454.54 plus costs, based upon the consent of the parties. CONSENTED TO: WELTMAN, WEINBERG 8c REIS CO., L.P.A., By: G~/ , . Attorney fo lainti SUSAN MASON, BI ~ f ~~ Defen t WWR#05829398 ~. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DNISION CAPITAL ONE BANK Plaintiff vs. Civil Action No. 07-2886-C1VIL TERM SUSAN MASON 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, SUSAN MASON, above-named, in the amount of $1454.54 pursuant to the Stipulation of the Parties for Payment and for the Entry of Judgment by Consent, as follows: Defendant admits indebtedness to Plaintiff in the amount of $1454.54 with continuing interest thereon at a rate of 6% per annum plus costs from June 25, 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, SUSAN MASON, in the amount of $1454.54 plus continuing interest thereon at the rate of 6% per annum from June 25, 2007 and costs. 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) $50.00 due by June 20, 2007; (b) $50.00 due on the 20th day of each consecutive month thereafter until the Judgment amount plus accrued interest and costs are paid in full. ~,. ~,. r 4. All payments are to be made payable to the order of "CAPITAL ONE BANK" All payments due under this agreement are to be received at the offices of Weltman, Weinberg & Reis, Co., L.P.A., 2718 Koppers Building, 436 Seventh Avenue, Pittsburgh, PA 15219. 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 fail 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~eomplete. 9. Intending to be legally bound, the parties set their hands and seals this _day of , 20 WELTMAN, WEINBERG & REIS CO., L.P.A. By: William . Molczan, squire PA I.D. #47437 WELTMEN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR No. 05829398 ay: De endant, SUSAN MASON +'E~ t~ A ~ ~ a t, C"~ ~ C"~J G --' ~. ~ rt~ -.-- .~~ a t G ~ 0.' k t f~ ~.e~a p~'~y~~ ,~ , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CN)L DNISION CAPITAL ONE BANK Plaintiff vs. Civil Action No. 07-2886-CNIL TERM SUSAN MASON Defendant NOTICE OF JUDGMENT OR ORDER 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 $1454.54 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 SUSAN MASON 811 ALLENVIEW DRNE MECHANICSBURG, PA 17055 By: S PRO ONOTARY (OR DEP