Loading...
HomeMy WebLinkAbout07-4903s IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. MARIE T SINGER Defendant No : b7 - ~f 403 Civil Te,~m 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 05904088 C N Pit SGM IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. Civil Action No MARIE T SINGER 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: MARIE T SINGER 201 E BURD ST SHIPPENSBURG, PA 17257 3. Defendant applied for and received a credit card bearing the account number 5178052325742944 . 4. Defendant made use of said credit card and has a current balance due of $2637.79 as of July 19, 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 27.740a per annum on the unpaid balance from July 19, 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 MARIE T SINGER INDIVIDUALLY in the amount of $2637.79 with continuing interest thereon at the rate of 27.740% per annum from July 19, 2007 plus costs. James armbrodt,42524 WELT EINBERG & REIS CO., L.P.A. 436 even h Avenue, Suite 2718 Pit sbur PA 15219 (41 ) 43 -7955 F 41 -338-7130 0 9040 8 C N Pit SGM This law firm is a debt collector a em ing to collect this debt for our client and any information obta ne will be used for that purpose. s The Deal You've Been Waiting For ... MOTOROLA I~AZR V3 > FREE" Wireless Camera Phone a~"~"~Ti"r"'t > BQNUS free B/uetooth® Headset (~6D Value) > FREE Shipping & Handling ~ ~ a >ccing~lar~~r~i_ WIREFLY~~ ~ ACT NOW Limited Time Offer r fOf C~j}~ pis CardhOjders Ci~~af O~~ PLATINUM MASTERCARD ACCOUNT 5178-0523-2574-2944 Account Summary Payments, Credits and Adjustments 003 SEP 10 - OCT 09, 2005 Page 1 of 1 Previous Balance 11,694.27 Payments, Credits and Adjustments E.00 Transactrons Transactions (35.00 Finance Charges =39,06 1 09 OCT PAST DUE FEE 135.00 New Balance =1,768.33 We appreaate your business and you deserve great benefits. We'd like you to know that your Minimum Amount Due (1,76833 Platinum turd benefits have been updated. For details, visit www.capitalone.com/tredittards and Payment Due Date November 09, 2005 dick on the Cuide to Benefits link. Thanks for choosing Capital One. Total Credit Line =1,000 You were assessed a past due fee of (35.00 on 10/09/2005 because yosv minimum payment was not Total Available Credit 1.00 received by the due daze of 10/08/2005. To avoid this fee in the future, we recommend that you Credit Line for Cash $1,000 allow at least 7 business days for your payment to reach Capital One. Available Credit for Cash g,00 At your service To aIl Customs Relations or to report a lost or stolen card: 1-800-903-3637 For fra online amount service and special asstoma offers, log on to: www.npitalonmmm Send payments to: Send inquiries to: Attn: Rerrsittana Processing Cnpinl One Bank Capital Onc P.O. Box 790216 P.O. Box 30285 St. Louis, MO 63179-0216 SLC, UT 84130-0285 Important Account Information Twelve unsung heroes of college athletics are competing for the honor of Capital One National Mascot of the Year -and you tan help deade who wins! Each week, the mascots go head-to-head in competition, but only one will win the coveted title and 110,000 for their school. Co to capitalone.com where you tan vote daily for your favorite mascot -and don't forget to tune in to the Capital One Bowl on ABC on Monday, January 2, 2006, to see who wins! w m Gapita~Qne~ 0000000 0 5178052325742944 09 1768330050001768331 • PLEASE RETURN PORTION BELOW WTTH PAYMENT New Balance 11,768.33 Minimum Amount Due (1,768.33 Payment Due Date November 09, 2005 Total enclosed 1 ~~ Accoanr Number: 5178-0523-2574-2944 `5"90 ~~~~ 'I~1nanC[ Charges Pkare ru reuerxti dt . for inrpartant in, fmrxatio n Ba! < rar< j $ PoAb< C,... ~ o ,s ~d ~~ gpt:< m .~< APR E PURCHASES 11,713.06 .07600%P 27.74% 539.06 CASH {.01 .07600%P 27.74% 1.00 ANNUAL PERCENTAGE RATE applied this period Plrar<pint mailing adairr and r-muit drss6<r b<! surnd blw or black us.E 27.74% S tree[ Apt. ;t Ciry Sere ZIP Home Phone Alrcrnarr Phone ~ #9028245195101605# MAIL iD NUMBER Capital One Bank ~ MARIE T SINGER P.O. Box 790216 ~s~n~rr~~stss~~ss~~s~ ro ~ 439 S FAYETTE ST St. Louis, MO 63179-0216 ~ ~ SHIPPENSBURG PA 17257-1709 ~t~~an~~sw~~~ns~~s~u~~nus~s~ns~~s~~uur~~t~~n~u~s~ ° ~ Please unite you account numbs on yow Jack o/ rnonry order made payable to Capital One Bank and mail in the enclartd envelope. r FREE*RAZR V3 ada.e~t aro2-pxaeMCe gsvnert Motorola RAZR V3 phone indudes: >Digital Zoom Camera >Bluetooth Capability >Buik-in Speakerphone >Ultra-Thin Compact Design angular careless Plans include: >Unlimited Mobile to Mobile >FREE Nationwide Long Distance >No Roaming Charges > Rollover Unused Anytime Minutes (A feature specific only to cingular Wireless!) 8 0 N N o~im; O 0] N Order Today! Call 1-800-973-0691 Or Visit www.wirefly.com/capitalone a a ~~ X cingular WIREFLY raising the bart..rll' Trte yyir~ g ' Phore tree alter malFin rebate. Ties oHe is fiYlAled Dy ktPlerYC tic., an audedzed dater for CNlglae Iykekss. Ohs sllhject b Ixtldd approrW or depoeil, and is avaaaON m ctsbnlers acivaDrlg a new Ere of service on a txro year oulbact recetie~eper gat aBe hen alaete are saved Dy cingular Yltrelesa. d you ae not in a grlgWarWfrelase arayouwit rlajor wteNe Iltler reatricDag amply' as fit IlffBr far tfahaie. offer Fxgres November 30, Z005.Orte Hey yazy. Cingle, de~ icon, Nolbver and FartsyyTags ee registered hedemeltct 2N Arpular DYlrelles, LLC. fleieirq The Bar altl the graph icon 8re service tlterNe of f}rlplllar Ntreke, LLC. Angular xGeNe and Ule Copular NArdeas logo era Dademarf6 a orapalerfld Dadanarka of Arqular Nraelass uc. O 2005 CingWar Nirelee, LLC. Ap npr~ reeved, IrlPlwnk°, popular' and Mfirefly` are responsl6le for tllls offer, and era not aHfiialed YNUI Capital One. Capl~l One doe not provide, elltlWa or guarantee, and k not agltetetl vA01, arty product a 8evt:e ahavm here. My lrademarkg nengorletl herein are sdery owned by the respective emtty. All ripens reserved. BY reDandm9 io dfis otter, ya, may Da rrnrlmurvca0ng iMOrmation about yourself to the company that provide this product -for eaample, Olaf you are a Capin One custmle. ® 2005 Capital One Services, lets. Capital One is a federagy registered service mark. NI rights reserved. periods rate. To obtain the average daily balarxe /or the baling period covered by tNa natemant, vve take the begimirp balance o1 each eegrnem each day, add any new hareattiore to eedr aepnem, and &rblrad any payments or credits. Ilf the code N appears an the front of tfas stnemem rexr to 'Balance Rate Applied To,' we dx aubvact any urpeid firence drerge included in tM balance of urh sa~rrern.) This gives w the daily balance of each segment. Then, vre add up ell the deiyy bdencea for each segment Mr the billirq period ant dvide by the total number of days In ifre biairp period. TNS gives u the average dally balance of each segment. 3. Amuar Pruntp• Bolas IAPRI. e. The term 'Amual Percentage Raie' may appear as 'APR' on the front of this statement. b. Ii tfre coos P IPrimee, L (3-mo. LIBOR), C (Certificate of Depodt>, or S (Benkcem Pnme) appears m the font of tMs srctemern next to ifre periods rateld, the periaac rates and cerreapondirp ANNUAL PERCENTAOE RATE may very quartedy and may ireroax or decreax based on the Hated Indices, ea found in The Well Street /oume/, plus the margin previoudy dscloeed to you. Thex changes will be effective on the first day of your billlrp penal covered by Your periods natemem endrp tfre months January, April, JWy ant October. c. If the code D (Prime), F (1-mo. LIBOR) or G 13-mo. LIBOR Repriced Mw1Ny) appears m the from of your rteterrent nerd to the periods retels), the periodic rates and corresponding ANNUAL PERCENTAGE RATE may vary montHy and may Increase or Oecrux basetl on tfre stated indices, as found in The Wae Street Journal, plus the margin previWdy dsdoxd DO yw. Tfrue Chengea will be effective m the fiat daY of your billing periotl each month. 4. Ass•nnr•rs of Laa•. Ovrlne acct lihenad Payment Fan. Your accent wIN be esseasM no more than two of the tees listed here tMt ocaa durirq any billing period. Untler rice terms of ywr eunamer egreemem, we reserve the right to waive or not to axeu any teen withan prior ratificetion to yw witfaut waiving car rigor to asxss the same ar dmilar tees at a later time. 5.t'Ramw}p Yau AeswR. It a memberofip fee appure an the horn of this natemem, yw rave 30 tleya fran tfre date this netemart was mei1W to you to void paying the fee or to Mve wrch tea credted to you it yw oncd ywr accaan. Durnp DNa period, yw may cominue to irse your accent wi[trar[ having to pay the membeahlp fee. To caned your accourn, you must retiry ue by calling our Customer Rdatiore Departmem arts pay your 'New Balance' in full lexdudinp tfre memberehip feel Prior to the end of the thirtY-daY Period. 6. If You Cap Yar Aeaaat. Vw can request to Box ywr eccoutt by celllrp car Customer Reladas Depanmem. Vw must denroy ywr credt carols) end accoun access checks, caned all prcaurhorized bllfirp, and ceax udrre your arxoum. It you do not cencN preauhorized dllirq arrenpeeama, we will corrdder receipt of a drsrpe ywr atatadzatiw to reopen your accent. Atldtiorelly, ywr accam vela not De dined in[il yw pay all amotnta you owe rs irtdirdnp: any tranxctias yw have auhorizeQ finance charges, pest rice tees, avedimit feu, resumed payment feed, cash atlvarae fees and any other fees asxesed to your court. yw are ruporrdde ar thex amours whether tMy appear on your accoun at the time you request to dose tM eccoun or they are incurred atbsequent ro your raquert to tloae the account. This may result in dramea afaeadno m rOUr aCCOUm eher you have your accent if it has already been clued. for exempe, it you aurtarizetl a purchase fran a mercham arts we receive the trareection tram the meniurn eher your aceoun has barn dosed, Your atxaatt will be reopened, the amartt of the charge will be added to your aCCasrt, and you will be reaPOrrdde for peymem. I1 there Is e memberdtiP fee for your accent, rite tea cant ixettkxre a be charged, to the extern permitted by law, umil the cewm balarae free been peitl in fill as definetl above. 7. Uekp yu Aee•rart.Vwr card or accent cannot be used in comectim cairn any nterret gamding trareamicre. 8. Nodes AbaR Ekaatraie Ch•ek Cmvrsion. When you provide a check as payment, you authorize u either so use infonnadon Iran ywr rdreck [o make sore-lime Wectroric furl treneler fran your bank accars or to process the paymem as a rmeck trarrsactim. Wtren vre Inbrmatim from your check to make an electronic turd srarefer, lulls may be withdrawn from your bares account ea soon as the same day we receve your paymem, and you will rat receive your check beck from your finerxial innitution. BILLING RIGHTS SUMMARY IIn Gx Of Erraro Or Otasatirars Abdul Ywr Bill) If y~iftink your bill is wrap, or it you creed more inf soon w a [ranaection or bill, write a w on a eparete sheet es •oan ae puaaMe at tfw address for Irrgririu shown an the from of tNs srctemem. We must hear from you ra later than BO days eher we sent yw the firer bill on which the error or problem eppearetl. Yw can call car Ctetarrcr Rektiau number, but doing so will rot mrformadrn ur rigfas. In your letter, give us ttre fdlowing amour[ of the wapxted roc, a descriptiorrr~ of the error and an explanation, if poselde, of why you believe there is r; or if you reetl more intormetion, a deacripdon of the rtem you ere unaurc about. you do not have to pay any ant kr question while we are irweetigerirp it, da yw are s[NI aDligated to pay the pans at yax Dill that are ret h iptenim. WNIe vue investigate you question, we arvrot report you as tlearpuent or take any anion to cdlrsct the amotrtt you question. i,t Spedal Rule For Credt Cam Purchases Ifxyou Mve a problem with tfre quality of property or MCCS that Yw purchased with a merit Gm acct yw nave triad in good felts to tmrrect the problem calm ore amaan d ~ ~ have the rigfa not to pay tfre ranaidrp property or xrvices. Vou have Chia protection only vuhen the purchax price case more then 450.00 and tfre puWrax was made in your hone Hate or witlan 100 miles of ywr mailing addrms. III we own or operate the merohant, or It we mailed yw tfre stlvertisemem for tfte property or services, all purdsxa are covered regeMeas of enoun or location of purchex.) Please remember ro dgn ell cerreponderee. t' Goes nor apply ro consumer rxn-creoYt caN accounts i Does rot apply to business ran-cradle cart! accounts Capital Ore aupporta informatim privacy protection: see car webaite et www.eepitelore.com. Gpiul One ie a federally rogiatered service mark of Gpital Ore Fnarrdal Grporction. All ngms reserved. a 2003 Gpltal One 01 LGLBAK 1. taut To Avoid A Fit~ru OltarW. 'r a. Oran Priori. you will have a mirtimun grace period of 25 deya vrithart fnerrce du m new purriaaea, new balance trereferc, new apedd purdreaea and new other durges it you pay your toter 'New Balance', in accomarroe with the Mnportem Nmlce for peymarns below, nd in time for it to be credted by your next eutemem dosing date. There is no grace period w ceah adverxx:s and apedel troreMre. In addkion, there is no grace period m any trerrsac[ian if you do rat pay the total 'New balance.' 6. Aeantlrp Flnanu prrga Trarrxctirxu whicn are rot subject to a grace period are assuxd finance Burge 1) from the date of the trareactiw or 21 horn tfre date the trarmetion is proceeded to your Account or 31 horn the first calendar day of the wrrem 6illirp period. Atldtienally, 'f you rid rot pay the 'New Balance' horn the Drcviets Nlling period h fiat, anertce durgea rmtlran to accrue to ywr upeid belarrce unit the urTZaid balance is paid in fWl. TMs mane that you may adll Duce finatae chergea, even if you pay the attire New Balance irdicetetl on the from of your natemem by the nerd rrtnemern dodrp date, but rid rot do x for the prcwoua monN. lhpaitl brence chergu are added to the appllcage xpment of your Accent. tc. k9krkraan Fnrre• OrsrY•. For each Mllirp period Mat ywr accoum is aufriea to a firence charge, a midmun teal FINANCE CHARGE of 30.50 will be imposed. H the teal firence Burge rrwWting from the application of your periods retell) is less than 30.50, vre will tantrect that amatxe from the 50.50 mirtimun and the dHererrce will 6e billed to ttq purchase segnant of your accourt. i' d. T•nparary R•dzaisn let F'drwrea f7trgd. We rcxrve the ght to not assess any or ell finance cMrgea for any given hi ling period. 2. Avarag• Dday Bslarte• Iktekrdkp Ndw Prehsanl. e. Rrertce efreroe Is caleWated 6y mWdplyinp the daily baierrce of each sellmratt of your accam le.q., cad[ adverrce, purchex, apedd trenster, end apedel puridrex) by 1M correcpardinp daily periodic ratelsl that Ms been previoudy dtrclosetl to you. At the end of eadt day during the billing period, rue apply the daily periods rate tar each aepnem of yea accowrt io the rtdly balance of each segment. Then at the end o1 the billing period, we add W the reeWta of 1lteae deny caleJetiare to arrive at your periods finance charge for each aegmert. We add W the results horn each aegnem to arrive at the total periods Rnerxx charge for ywr arxxltat. To get the daay balance for eadt aflgnem of ywr accent, vue nke [rte hepmlrp balance for uric aelrnem xd add any row trcreecdrsra grid any periods firertce dterge celWeted an the Previous day's balance for that apmern. We then subtract any paymems or creWe posted ea of that day that are allocated m tiwt aegmern. TNS plvu ire the aeperote daay balance for each aegrtens of ywr aa:ourn. rforrever, ii you paid the New Balance shown w ywr Previous natemam in fiat tar if yea new balance was zero or a crerh amount, new trarsactiore which efts to ywr purdux or special purchase segmarta are not atldetl to trte Mlly balances. We celcJate the average daily Defence by arl6rq all the dally balances together ant 6vidnq the dun by Hie number of the days in the curem being cytle. Te cNCUlate ywr total finance charge, muhiply ywr average daily balance by the daily generic rate and by the number of tleya in the Nlfing period. Due to roundup an a tlaily bads, tMre rosy be a digM variance between tHa ralculatlon acct tfre amours of frerax dtarpe actually assessed. h. If the coda Z or N eppeara an tfre from of t)ia rtatement next to 'Bderee Rste Applied To,' we multiply the Irrpattnt Hotiu: Payments yw mail to us will be credited to your accent as of the wdresa day we receive it, provided (11 yw send the bosom portion Of this natemem acct ywr check In the erclosetl reminarrce envelope and l21 ywr paymern Is recefved in car Drocesdp center by 3 D.m. L7 112 neon PT). Pleax allow at least flue 15) budrrex days roc postal tldlvery. Paymems received by re n any other location Or in any other form may na 6e crodned as of the Bey we receive them. Our budnex days are Malay throtph Saturday, exdudrp hdideys. elux rfo rat use Hades, paper dips etc. vAren prepadnp yywour peymmt. When yyoouu send u a dsck(el, yw authorize u to make Bone-time dectranfc hanater debit from ywr bank scant for the amour of the check. THa authorization appfin to ell UrecW recdvetl drrinp the billing cycle even if sent 6y someone dx. It we cemot process rice varefer, yw eutfarize u to make a charge againn ywr bank accent wing the check, a paper drab or other ham. VERIFICATION CAPITAL ONE BANK vs SINGER, MARIE T 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, MARITZA ROBERTS, 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. ~~1 MARITZA ROBERTS Notary Public S " Notary P~biic Douglas County, Georgia My Commission Expires February 29, 2008 5178052325742944 A049 WELTMAN, WEINBERG & REIS CO., L.P.A. ~° 6~ # ~~ ..~ ~ vl D ~ ~ C _~_ r. -... ~ ~~ " ;~ T --- ~ ~~ ~ : ~-. _ __ ` .., . - ~~ '~ ~'4~ t ` W ~. fJ SHERIFF'S RETURN - REGULAR CASE NO: 2007-04903 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CAPITAL ONE BANK VS SINGER MARIE T 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 SINGER MARIE T the DEFENDANT at 1140:00 HOURS, on the 22nd day of August 2007 at 201 E BURD STREET SHIPPENSBURG, PA 17257 MARIE SINGER by handing to a true and attested copy of COMPLAINT & NOTICE #207 together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge ~'''1 gI C 7 18.00 19.20 .00 10.00 .00 / 47.20 Sworn and Subscibed to before me this day So Answers: R. Thomas Kline 08/23/2007 WELTMAN WEINBERG EI By: e ty Sheriff of A.D. s IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. MARIE T SINGER Defendant No. 07-4903 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#5904088 Judgment Amount $ 2,819.79 THIS LAW FIRM IS ATTEMPTING TO COLLECT THIS DEBT FOR ITS CLIENT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. r IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. Civil Action No. 07-4903 CIVIL TERM MARIE T SINGER Defendant TO THE PROTHONOTARY: PRAECIPE FOR DEFAULT JUDGMENT Kindly enter Judgment against the Defendant, MARIE T SINGER above named, in the default of an Answer, in the amount of $2,819.79 computed as follows: Amount claimed in Complaint $2,637.79 Interest from JULY 19, 2007 TO OCTOBER 18, 2007 at the legal interest rate of 27.74% per annum $182.00 TOTAL $2,819.79 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. B f/" Y WILLIAM. T. MOLCZ ,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#5904088 Plaintiffls address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7~' Avenue, Pittsburgh, PA 15219 And that the last known address of the Defendant is: 201 E BURD ST SHIPPENSBURG,PA 17257 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. Civil Action No. 07-4903 CIVIL TERM MARIE T SINGER 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 ~, ;t.001 (xx) Assumpsit Judgment in the amount of $2,819.79 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: PR ONOTARY ~ ~~r) MARIE T SINGER ~~ 20I E BURD ST SHIPPENSBURG,PA 17257 Plaintiff s address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7`h Avenue, Pittsburgh, PA 1521.9 1-888-434-0085 IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. MARIE T SINGER Defendant Case no: 07-4903 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 afftant's belief that the Defendant, MARIE T SINGER 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, MARIE T SINGER is not in the military service. Further Affiant sayeth naught. AFFIANT SWORN TO AND SUBSCRIBED in my presence this~~ day of ~L.~ol~ 2~-7 . . _ _ ;- NOT Y PUBL `~"' ~ _ - - - ~~"~ ~'~~-``/ ~'~ . 'ennsylvania~sser~" ,° ";'^•-~ es 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 OCT-18-2007 13:49:35 ~. Last Name First/Middle Begin Date Active Duty Status Service/Agency SINGER MARIE T 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. Y1w.~tYA. J~..~,-tlt~.. 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: htt~ //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 10/18/2007 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: YPAGWQWCGT https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 10/18/2007 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff MARIE T SINGER Defendant (s ) IMPORTANT NOTICE TO: MARIE T SINGER 201 E BURD ST SHIPPENSBURG,PA 17257 Date of Notice : ~ ~ - (©~ WWR#: 05904088 Case #(j~-LI9C53 CiV1L `IEI~W1 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, WETNBERG & REIS CO., L.P.A. 2718 KOPPERS BLDG, 436 7TH AVE. PITTSBURGH, PA 15219 -~s. C~ '~ ~~~ ~~ ~ ~~'o~ ~ ~ ~- ~ ~. ~ ~ .~ :_ ~. ~; . t~_ =~- ~- =. r-a ti c~a N ~...., ...~ s~~ f F...:' _,- --r -~ ,:.7 ~~~ _~