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HomeMy WebLinkAbout07-5091 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff S "- " l vs. COMPLAINT IN CIVIL ACTION JILL L ZEHRING Defendant 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 05879492 C N Pit BNT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. JILL L ZEHRING 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 c 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: JILL L ZEHRING 442 STONEHENGE LN MECHANICSBURG, PA 17050 3. Defendant applied for and received a credit card bearing the account number 5178052379279603 . 4. Defendant made use of said credit card and has a current balance due of $1337.67 as of July 30, 2007 . 5. Defendant is in default by failing to make monthly payments when due. As such, the entire balance is immediately due and payable to Plaintiff. 6. Plaintiff is entitled to the addition of interest at the rate of 25.900$ per annum on the unpaid balance from July 30, 2007 A copy of Plaintiff's STATEMENT is attached hereto, marked as Exhibit "1" and made a part hereof. I i' I ~ 7. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed and/or refused to pay the balance due to Plaintiff. Wherefore, the Plaintiff prays for judgment in its favor and against Defendant JILL L ZEHRING INDIVIDUALLY in the amount of $1337.67 with continuing interest thereon at the rate of 25.900 per annum from July 30, 2007 plus costs. James Warmbrodt,42524 WELT WEINBERG & REIS CO., L.P.A. 436 eve th Avenue, Suite 2718 Pit sbu h, PA 15219 (4 ) 4 4-7955 F 4 2-338-7130 0 879 2 C N Pit BNT This law firm is a debt collector at~e~ing to collect this debt for our client and any information obtai a will be used for that purpose. } = ~ peoplepcra online u Abetter way to Internet. ~ ~ Surf up !•fl '' ;fir fa~i+er'~t ~ ~ PRA Aoos/ersbr tortlrs6ratf2swnlAl-afe0gt-f 1-888-587-9669 • Mention Offer Code: DOLLAR Visit www.peoplepc.com/go/dollar ~DYIe• Accotmt Previom Balance (899.84 Paymems, Credits and Adjuamean f.00 Trui-eiom (29.00 F'inanrt Chages (19.35 Nea• Balance (948.19 Minimwn Amount Due (948.19 Payment Due Date Jannay 27, 2006 Tool Credit Line f300 Total Avail~le Credit l.00 Credit Line for Cash (300 AvailaNe Cred'u for Cash f.00 UNLIMITED INTERNET ACCESS PsoplePC oniMs offers the features you would expect from higher-priced Internet Service Providers, including: Virus Protection powa,ea by symantecTM ® Pop-Up BlockerTM Spam Controls ®~ Smarter Smart Dialer Technology - ~ More Email Addresses Internet Call Waiting PLATINUM MASI'ERCARD ACCOUNT 5178-0523-7927-9603 NOV 28 -DEC 27, 2005 Page 1 of 1 Payments, Credits and Adjustments Tra>mactiom 1 27 DEC PAST DUE FEE (29.00 Your reyueat to dace your account has been received. Your accowrt trill be dosed when it readies a f0 babum Until theq you will eomimie to receive sdtemenu and must mntimie m mate ptymentr. AB terms and wndibom of the aaouffi will apply while a balance remains Please remember to crrt your cards and asrtcd all charges which saomatinlly bill to your aeoonm. Ace a valued Capital Oa auroma, you are eligible to receive a Gee Year-End Summary fa thin epedfic arroum that reesps your 2005 charges, provided your aocottnt i, in good aunditrg and yon have made transaRioaa durug the calendar year. Plwe eaB 1-877-794-4487 before Januay 31, 2006, to reicve your copy for this account. Orders will be mailed out by the end of Febrnuy 2006. At your service We appredate yoe¢ business end yon deserve great benefm. Wed lift you to know that yaa To u4 Cuao®ar Retiwn w m copal a kst a .ooMa ard: Phttinum cad bene5u have ban updated Far detaik, visit rvww.aspidone.com/atdiscarda a~ 1-800-903-3637 didt on the snide w Benefvs link. Thanks for choosing e>~mlt one. Far 6a odiae seaaeat souls sad speaisl asstoma alias. log a to www.aapYaioonaom Send P7•~ lo: Sad isquiria to Aaa: Reroitsna Pmmdag CspihlO-Beak Csp'mlOne P.O. Boa 790216 P.O. Ba 30265 St Loris, MO 63179-0216 SLC, ITr 84130-0285 Lmnatant Aooonnt Information It's Comta'Nl One Bowl welt tune again! Tam in to ESPN sad ~E$$pp 2 smog on Deumba ~1 for the best in pat-season college football anion to xe your favorite cams 5Ggghhtt fa bowl dtampionshipa And on Jamlay 2 a 1 pm (ET), be see to tune into ABC to watch the Capital One Bowl live from Orlandq Florida! 0 N You were a-eased a poet due fa of (29.00 on ]2/27/2005 ber~se ywa minimum payment was not received by the due date of 12/27/2005. To avoid this fee in the fiurae, we recommend that you allow at least 7 bvsiuas days for yoeu payment to cosh Capital One. E ~ ~t. Finance Charges PYaaesar revertrssdr)6r iarpsrtaat is~6nadisa B.z..a..~r. Pn:Ir C°^1's ~m CAARGE ,w PURCHASES (909.16 .0709ft~ 25.90K f19.35 CAg}[ f.00 .07096% 25.90% f.00 ANNUAL PERCENTAGE RATE applied this period • PLEASE RETURN PORTION BELOW WITH PAYMENT ~~ 0000000 0 5178052379279603 27 0948190023150948194 New Balasa (948.19 Mimslam Amoom Due (9/8.19 Payment Doe Dare JaWay~, 2006 Totslendoeed f AaomaNambc 5178-05217927-9603 PGmrp.:,t nealnesau a+y ~-~a.ira.6.~a ~,~l.6aa.il.~iak 25.909~i Saeea ~ 4 av sua zrP Herne Phone Ahaom Phone • pmdAddeaa _ #90362493210491596 MAIL ID NUMBER Capital One Bank s.~ JILL L 2EHAING P.O. Box 790216 ~t~u~~~nui~t~~ut~~ o I~ 442 ST0IJEHENGE LN St. Louis, MO 63179-0216 ~ ~ MECHANICSBURG PA 17050 ~i~~uu~~un~~~nr~~i~u~~unr~i~ni~~i~~nui~~i~~u~n~r~ ° !Heart vaifsyms auoant mm8er tar yes rGart a ewary cedar awde paya8k to GpitalOru Bask sad nail is the eacbrad mvrJofe. r .... K .• VERIFICATION CAPITAL ONE BANK vs ZEHRING, JILL L The undersigned does hereby verify subject to the penalties of 1$ 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 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. ------ z, ` TRA R Uvonda S. Brooks ' k Notary Public Douglas County, Georgia My Commission Expires ~` F'ebruaty 29, 2008 otary Public 5178052379279603 A049 WELTMAN, WEINBERG & REIS CO., L.P.A. n'' • ~~ , :. ~~A i `V C._ ~' r =~ -~o N ?,~. N .~- ~.~ ~~ ~ ~}~~' - C.3 r :~ SHERIFF'S RETURN - NOT FOUND CASE N0: 2007-05091 P COMMONTWEALTH OF PENNSYLVANIA ` COUNTY OF CUMBERLAND CAPITAL ONE BANK VS ZEHRING JILL L R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT ZEHRING JILL L but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT & NOTICE the within named DEFENDANT ZEHRING JILL L 442 STONEHENGE LANE NOT FOUND as to MECHANICSBURG, PA 17050 CURRENT RESIDENT HAS BEEN THERE OVER A YEAR. DEFENDANT DOES NOT LIVE THERE. Sheriff ' s Costs : So answers • --~°' _ > ';:: -- Docketing 18.00 ,..--~`"~ .-'rY '~' Service 19.20 / /' Not Found 5.00 R. Thomas Kl' e Surcharge 10.00 Sheriff of Cumberland County .00 9/d~'o~ G~ 52.20 WELTMAN WEINBERG REIS 09/18/2007 Sworn and Subscribed to before me this day of , A.D. {~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. JILL L ZEHRING Defendant No. 07-5091 CIVIL TERM PRAECIPE TO REINSTATE COMPLAINT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt, P.A.I.D.# 42524 Weltman,Weinberg & Reis Co .,L_.P.A. 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 (412)434-7955 Fax: 412-338-7130 WWR#05879492 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. Civil Action No. 07-5091 CIVIL TERM JILL L ZEHRING Defendant PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. WELTMAN, WEINBERG & REIS CO., L.P.A. By: ~ James C. Warm odt, P.A.I.D.# 4252 Weltman,Wei rg & Reis Co .,L.P.A. 436 Seventh A enue, Suite 1400 Pittsburgh, 5219 (412)434-7 Fax: 412 -7130 WWR #05879492 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. JILL L ZEHRING Defendant No: 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 05879492 C N Pit BNT . ~~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. Civil Action No JILL L ZEHRING 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: JILL L ZEHRING 442 STONEHENGE LN MECHANICSBURG, PA 17050 3. Defendant applied for and received a credit card bearing the account number 5178052379279603 . 4. Defendant made use of said credit card and has a current balance due of $1337.67 as of July 30, 2007 . 5. Defendant is in default by failing to make monthly payments when due. As such, the entire balance is immediately due and payable to Plaintiff. 6. Plaintiff is entitled to the addition of interest at the rate of 25.900 per annum on the unpaid balance from July 30, 2007 A copy of Plaintiff's STATEMENT is attached hereto, marked as Exhibit "1" and made a part hereof. r r„ 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 JILL L ZEHRING INDIVIDUALLY in the amount of $1337.67 with continuing interest thereon at the rate of 25.900 per annum from July 30, 2007 plus costs. James Warmbrodt,42524 WELT ,';WEINBERG & REIS CO., L.P.A. 436 eve~nth Avenue, Suite 2718 Pit sbu ; h, PA 15219 (4 ) 434-7955 FA~: 4 ~2-338-7130 05187992 C N Pit BNT This law firm is a debt collector att~em ing to collect this debt for our client and any information obtaix~e will be used for that purpose. 1 ' peoplepcr~ online U Abetter way to Internet. J s~rtyo to •, , 5x fastert4~7 ~ FREE A~tstnr forfha riat t2trrmtlut-. xeo value! 1-888-58T-9669 ~~ • • • Mention Offer Code: DOLLAR _ _~ Vtsit www.pt9oplepc.comigo/dollar UNLIMITED INTERNET ACCESS P9soplePC Online offers the features you would expect from higher-priced Internet Service Providers, includ'mg: V rus Protection powered ~v symentecTM ® Pop-Up BlockerTM' ~j Spam Controls ®~ Smarter Smart Dialer Technology ,~ ~ More Email Addresses ~ ~ Internet Call Waiting ~~j~. Account Previatrs Balattu 1899.64 Paymtma, Credits and Adjuatmema 1.00 Tnnsat3iona (29.00 Finance Chuges =19.35 PLATINUM MASTERCARD ACCOUNT 5178-0523-7927-9603 NOV 28 -DEC 27, 2005 Page 1 of 1 Payments, Credits and Adjustments Tssnsactio~ 27 DEC PAST DUE FEE 129.00 New Balance 1948.19 Yom request to dose yom account has been raxived. Your artoum will be dosed when it reaches a 10 balance. Mmitnwn Amount Due 1948.19 Untrl then, lent will mntimte m receive statements and must eontimte to make payment. All tarns and Paymtot Due Date January 27, 2006 conditions of the aecoum will apply whsle a balance remains. Please remember to cut yore cads and cancel all dtarges which avtomatieally bill to your aeeomtt. Total credit Line Total Available Credit S3oo 1.00 As a valued Capihl Otte customs, you are eligible m receive a fret Year-E~ Summary for this Cred'a lane for Cash f.30p speditc aaonnt that recaps your 2005 dtarges, provided your actgtm is in good standing and Available Credit far Cash 1,Op you have made transactions during the calendar year. Please call 1-577-794-4487 before January 31, 2006, to reserve your copy for this aaoum: Orden vein be mailed wu by the end of February 2006. Atyour service We appret5ate yore busiruss and yon desem great bendtta We'd like you to know that yore To eaB Customer Relations or to report a lost a stden ov& Platinum cad benefits have been updated. Fa details, visit www.capitalooe.conJaedittads and 1-800-903-3637 d~atic on the Guide to Betxfits ]ink Thanks fa dloosing Capital O~. Fa free ostlirte aorount saris sad special customs offer, log oa m: www.tapitaboe.com Send pgrssans to: Send inqu'via to: Arm: Raoittartm Proassiug Capital One Bank Capid One P.O. Bas 790216 P.O. Boa 30285 St Louis, MO 63179-0216 SLC, UT 84130-0285 Imoorrant Aaount Information EX° Fina[tttChtatges PlrsrrJarrnernndrfarisefortant iaformatian B.lnwr.a Per;sdc Gsrrym slmj ~~` spyhla R sebr dPP taL c PURCHASES x909.16 .0709696 25.90% 119.35 e CASH x.00 .0709691 25.9096 x.00 ANNUAL PERCENTAGE RATE applied this period 25.90% It's 6x1 One Bowl week time again` Tune in to ESPN std NI atartittg oa December 20 for the beer in poa-arson college fowbaB acrion to see your fawriu team ffiigqht lot bowl dtampionsitips. And on Jatmary 2 at 1 pm (ET'1, be am to tune into ABC m warrh the Cap'aal One Bowl live from Orlando, Florida! • PLEASE RETURN PORTION BELOW WITH PAYMENT ~ea 0000000 0 5178052379279603 27 0948190023150948194 Pkaapirst mail;Al addrsr aas~n r-aritr6o~rs kloa+aiax d~Lsr err-taat irsk New Bttbula 1948.19 Minimum Amoum Due 1948.19 Sa«t Apr. • Payment Due Date January 27, 2006 Gry Stier ZIP Total enclosed s Home Ptane Alternate Pboer AcwweNumber. 5178-0523-7917-9603 P.a,a Aaare.e !~ N9036249321049159A MAIL ID NUMBER Capital One Bank ~ JILL L ZEHRING P.O. Box 790216 It{ullluutlrllutll o ';~ 442 STONEHENGE I19 '" t!'~ MECHANICSBURG PA 17050 St. Louis, MO 63179-0216 ,~ tr ltlittttlitttrlllttt{Ittttlltttatltlrrriirtlttrttliriletirtlrl Please write yosc armarst rsumber on yoro rba:F w monry aon asadr payablr to Cafital OnrBarsE and mail in t/x rnclmrd rrruelopr. You was assrssed a past due fee of 129.D0 on 17/27/2005 benttae yore rninirnwn payment was not received by the due date of 12/27/2005. To avid thie fa in the f»ture, we recommend that you a-OW at ]east 7 business days for yOtc payment t0 reach Capital Ont. 1 ,. VERIFICATION CAPITAL ONE BANK vs ZEHRiNG, JILL L 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 Declaration, and that the facts set forth in the foregoing Complaint in Civil Action are true and correct to the best ofhis/her knowledge, information and belief. i ~~ TRA R ~ t..0~ otary Public 5178052379279603 A049 WELTMAN, WEINBERG & REIS CO., L.P.A. i'.Jvanda 5. Brooks Notary. public Douglas County, Georgia 1Vdy Commission Expires Febniary 29, 2008 O 4 ~~{ V Q f r--a i ti G-1 ~y L.J ,.1 ~h1 K t , q y " ' ~.'... +~...j ~~n } 1. ..,~ (:... ~ T1 ~~~ SHERIFF'S RETURN - REGULAR CASE NO: 2007-05091 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CAPITAL ONE BANK VS ZEHRING JILL L MICHAEL BARRICK Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE ZEHRING JILL L was served upon the DEFENDANT at 1838:00 HOURS, on the 16th day of April 2008 at 107 MAY DRIVE APT 1 CAMP HILL, PA 17011 TTr r nr.+r rr~TUrr 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 ~/.2 P~o~ ~,,., 18.00 30.00 .00 10.00 .00 / 58.00 Sworn and Subscibed to before me this day So Answers: r i R. Thomas Kline 04/17/2008 WELTMAN WEINBER S ~~. i By ~ i/~ epu She iff of A.D. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. JILL L ZF,HRING Defendant No.07-5091 CIVIL TERM PRAECIPE FOR ENTRY OF JUDGMENT BY CONSENT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: Matthew D Urban, Esquire PA I.D. #90963 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#5879492 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. JILL L ZEHRING Defendant Civil Action No. 07-5091 CIVIL TERM PRAECIPE FOR JUDGMENT BY CONSENT TO THE PROTHONOTARY: Kindly enter Judgment against Defendant, JILL L ZEHRING, in the amount of $1477.00 plus costs, based upon the consent of the parties. CONSENTED TO: WELTMAN, WEINBERG & REIS CO., L.P.A., By: Attorne for Plaintiff JILL L ZEHRING, By ndant WWR#5879492 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. Civil Action No. 07-5091 CIVIL TERM JILL L ZEHRING Defendant STII'ULATION 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, JILL L ZEHRING, above-named, in the amount of $1477.00 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 $1477.00 with continuing interest thereon at a rate of b.0% per annum plus costs from date of judgment. 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, JILL L ZEHRING, in the amount of $1477.00 plus continuing interest thereon at the rate of 6.0% per annum from date of judgment 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) $75.00 due by 6/15/08; (b) $75.00 due on the 15~ 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 "CAPITAL ONE BANK" All payments due under this agreement are to be received at the offices of Weltman, Weinberg & Reis, Co., L.P.A., P.O. BOX 5430, Cleveland, OH 44101-0430. 6. In the event of default, each payment received shall be first attributed to costs, interest and then to principal. 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. 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 thisla~ day of u~- 20 o~j WELTMAN, WEINBERG & REIS CO., L.P.A. By: atthew D Urban, Esquire PA I.D. #90963 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR No. 5879492 By: ` endant, JILL L ZE `. C? '=~ i ~~ ~ ~ r~ ~ . tr3 .,~ ,:: w ~~ ~7 ` 0~ Fr 1. ~ "'C ~~~ .~ , ~, • .t ~' ~ a `vLL { ~ ~' `._ 3 -~~ c3~ '~ .,,._ T~ .....y IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. Civil Action No. 07-5091 CIVIL TERM JILL L ZEHRING Defendant NOTICE OF JUDGMENT OR ORDER TO: ( )Plaintiff (xx) Defendant ( )Garnishee You are hereby notified that the following Order or Jud ment was entered against you on to D (xx) Assumpsit Judgment in the amount of $1477.00 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 JILL L ZEHRING 107 MAY DR CAMP HILL, PA 17011 By: PR HONG (O EPUTY)