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Home My WebLink About07-6207IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff No: 07- t a.Dq l;lvi ( perm vs. DIANE L RAMSEY COMPLAINT IN CIVIL ACTION 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 06169898 C N Pit DKB IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff VS. Civil Action No DIANE L RAMSEY 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: DIANE L RAMSEY 624 HOLLY PIKE MT HOLLY SPGS, PA 17065 3. Defendant applied for and received a credit card bearing the account number 5178052505774527 . 4. Defendant made use of said credit card and has a current balance due of $1182.75 , as of September 26, 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 28.240% per annum on the unpaid balance from September 26, 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 , DIANE L RAMSEY , INDIVIDUALLY , in the amount of $1182.75 with continuing interest thereon at the rate of 28.240% per annum from September 26, 2007 plus costs. James Warmbrodt,42524 WELT WEINBERG & REIS CO., L.P.A. 436 e enth Avenue, Suite 2718 Pit sb rgh, PA 15219 (4 ) 434-7955 F 12-338-7130 0 16 898 C N Pit DKB This law firm is a debt collector att pting to collect this debt for our client and any information obtain rd will be used for that purpose. Now witit FREE Accelerator '. for the first fZ monthir-a *Go value a " D7 a month for flrst 3 months; $9.95/mo. dwealter SIGN UP TODAY! 1-888-587-9669 Mention Offer Code: EMERALD Or visit www.peoplopc.coMgo/emeraid ?V? !fie Aooount Previous Balance t823.00 Payments, Credits and Adjustments $.00 Transactions $29.00 Finance Charges $18.02 009 peoplepc- online %.-/ A better way to Irltemet. Peopk PC Online offers the features you would expect from higher-priced Internet Service Providers at half price for the first 3 months! ® Virus Protection Powered by symantec- ® Pop-Up Blockertae * Spam controls ® S Smarter Smart Dialer Technology ®! More Email Addresses ® ?p Internet Call Waiting PLATINUM MAMRCARD ACCOUNT 5178-0525-0577-4527 FEB 15 - MAR 14, 2006 Page 1 of 1 Payments Credits and Adjustments Transactions 1 14 MAR PAST DUE FEE New Bala= $970.02 You were assessed a past due fee of $29.00 on 03/1412006 because your minimum payment was not Minimum Amount Due $970,02 received by the due date of 03/14/2006. To avoid this fee in the funae, we recommend that you payment Due Date April 14, 2006 allow at least 7 business days for your payment to react Capital One. Total Credit Line $500 Total Available Credit $.00 Credit Line for Cash $500 Available Credit fa Cash $.00 At your sm-Am To tall Ctwto Rdation w to report a lost or stolen ou* 1-800-903-3637 Smd pgmmm to Send inquirers to Atm: Resnit4me Pmowing Capital One Bank Capiw One P.O. B w 790216 P.O. Bar 30285 St Lauis, MO 63179-0216 SLC, UT 84130-0285 Important Account information Please review the enclosed privacy information and retain it with y ow account recor& Also Malt www.capttalone.com/credrtcads and click on the Visit the Guide to Benefits link to lean about your latest Visa. err MasurCard. account benefits. The desmpuom in this online guide replace any information you received in the past For a printed copy of the Guide to Benefits, call the Customer Relations number on the back of ytnu cad. $29.00 Finance Charges Ptsuesm revene ruirfor iarpwmd uj*matan Bds 1a dr PeriaJGr C-Z- AV Rog ,?prtrJa) A raGr N PURCHASES f83L65 .0773MP 26.24% 818.02 n CASH 8.00 .07737%P 28.24% 8.00 ANNUAL PERCENTAGE RATE applied this period 28.24% V PLEASE RETURN PORTION BELOW WITH PAYMENT QW&WOM, 0000000 0 5178052505774527 14 0870020025000870021 New Balanu $870.02 Minimum Amount Due $870.02 Payment Due Date April 14, 2006 -- Total enclosed $ ? Account Number. 5178-0525-0577-4527 P4arprort -T g Ihw arAw wedA q.kk--gr W- -W -k .L Sxet Apt # Gg S= ZIP Home Pleas Ab-t, Phone • Fau7 Add- #9007472620012792# MAIL ID NUMBER Capital One Bank DIANE L RAMSEY P.O. Box 790216 239 PINE GROVE RD GARDNSRS PA 17324-6946 St. Louis, MO 63179-0216 Pkau uniteyew awount number m yaw dw-k err money order madePsya6k to CapitalOruBan.Eandmail in the enrlarrd emu-Jofc r peoplepc- online u A better way to Internet. UNLIMITED INTERNET ACCESS SIGN UP TODAYI 1-888-587-9669 Mention Offer Code: EMERALD Or visit www.peoplepc.com/go/emeraid PwoePC is ad* responsbb fortis offer, and is not aAlkriad with Capital Ore. Capital One does not provide, endorse a guaranies. and is trot alifated with, any product or servce enure here. Awry t ademerka mentioned heteb are solely owned by that respective Entity. All rights reserved. By responding tO thin over: you may be comm micatins periomhatiah about youraeM to the company that provides this product - for example: that you ore a Capital One astarer. 'PeopW)C Online: Ftat 3 rtorals are billed at $497 per mash; $9.95 per month thereafter. 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You are resporslMe for delerminkg wfegml a cal to o s of our access numbers wf result r telephone toll charges. Access may be linked, sepecdly dun v times of peak usage. Dial-up numbers may be chanrged at PeoplePC's discretion. Conlinwrs use subject to timmirt pxacackm All use is suhjedt to PeoptePC Online's Services Agreement and Able Use Policy. Sint a the maximum speed of service, actual speed may wary. 0 20108 PeopW C Inc. AN Rights Reserved. PeopieK Online and its logos am trademarks of PeoptePC in the U.S. and other cmntries. 0 2008 Capital One Ssrvices? Inc. Capital One is a federally registered service mak AN rVft reserved. 111 ri¦ lei 8 O 1 N ' N l O ^? t; kV parodic rm. Tc 6tsm the average dally, lode nn for the = aalod mverod try the etaeanaa, we take the berahk . ma of each sepnam each day, add any new transwilons m aadh sprwR and milmact any Wym•hts or cretin. Of the code N appears all the bore o1 War soamm next te'Bslance PAN Aqpppplipeedd To; vve arc subtract arty unpaid trance dsrys ktdtded in the balance of each segrnr eer.) This gives all the u to daily bdwm of each saimant. seam to to bbWrq add parbdd mW dvide by the wtd number of days In the hwrq pew This gives u the awr+ye daily balaroe of eadt segment. 3. M..1 ?eaatsis Ragas IAPN4 a. The tent 'Anneal Percentage Rats' may appear as APR' on Aar from of die matement. b. If the code P (Prime), L (3•nm. LIBOR), C (Certificate of Deport=, a S Mankcsrd Prirmhe) appears on the hod of tiro stalamsm next to the parodic ratels), die oeriodc rates and ANNUAL P61C9lTAG MT may vary q ale my' taease or decease based m the stated khdiam, as found in The Wier Strata doarW, plum to maker prMOUrly dscioeed m YOU. These clmrpse yr r afro w o the fro ley of your ,rakg pMod oowwd by Yale periodic statement ending r the mhmdr Ja uarY, ApN, July and October. c. If the code D (Prbe). F 0-mo. IJB010 or O (3-mo. LIBOR Repriced Mond" appe?e on the from of your statemau next m the petiole rauW t1r par arhd ANINAL PBiCEM11 V.odic maY raon and lc a W Am d in TAM YYaY aSpow , plum and kdioes, the murder Dray diarJoasd m Yar• These darpes vhi be stleeave on to that dry of yea dig period each morth. 4. A mmumat of Late. Ov~ mW Rammed F Ommar Fans. Your acemm vrl be assessed no more than two at the fees goad here den owe during any Willing perlo& Under the terms of your customer agreenam, We reserve the dim to walw or not m mamm any fees vfMart prior ratification w you walnut waiving our right to mamas tM same or sYdlar less at ¦ I" tlme. 5.tRrrAv Yale Aeaw L H a membership Ise, appear an the from of this statement, you how 30 days fmm the dome 0" strterem was mailed to you to avoid paying the fee or to haw such fee credited to you if you cancel your aeooutt During des p•fod, you may cord ms to tee yew account v:item MWg to pay the mmWestrp fee. To caned yaw accaad, you must notify oat by calling our Customer Re"" Department slid Now Balance' in full (excluding the & H m You CrarYw prior to the ond of Amurd. You can?equWrsst"m closie? Yyyaourr account by calling oat Cumomer Ilelrtlam Oapartment. You rota destroy Your credit cam(s) and account aura decks, cancel d presudhoszed big, and tease Wrq you accord. If you do not cancel preaudedzad baWg anamparnems, we vfil consider reopen Your mcappt of a charge yaw authorization to accost. AddUaaNy, yaw accaud wi sea W dosed until you pay as amounts you owe u khdudlna any trama deals you hew audnrzed, finance charges, pow due fees, overikmt foss, .enrol payment fees, cash advance fees and any other tam assessed to your sccou t. You are responsible for ithase mamas vdeter they appasr on your atx:aa at the time you rewaw m dose the account or they am earned ahbsequerht m to account. This may die nknp o your account after You hover _ yoW atrsut H k has ekemly been dosed. For sxrpr, w arherked a tandems, fro a merchant gid vve the unnsaoinn Team the mate em after Your aernat has been cord, ymr secant well be reopened, the arrant of the chmp wi be added m Voter sooors, rdyou wi be rspasfois for paymrw. H do is a mamb.aap fee for your sooort, the fee Wi rnmlme m W dw , m tie aomt pemimed W bw, uu the aooart balers se boon pek in .M M daAed abawe. 7. =Y==Y. 4Yaioarwt cannot be ucdm a. Neu- Abet EWw.tb Chalk Oorwanias What You provide ¦ delft as, pap wM you authorize u elfhe w use kdomadon from yaw dock in make a ono dims, dsetrone MW i s ON from Yew bare accord or to W:an the per as a leek tear imcdom. What we tee ktWmudon from Yaw eAeck to make an deetmre find trawler, hrds may be vvtadrown from Your bank asaat as soon as the same dry vole recaFw your ===not rscoh, ymw ci bock from BILLING RIGHTS SUMMARY fin Cafe Of Emote Or Ouesdons Abase Your BE) If hale thrk your bW Is worhg, a H you need mom riprmdan on a trrwctim or W, who to tr on aa f seen" alast as torn as possible at the address kX1uId" reean on that from at tlia smo mmL We owlet hear ham you no Imsr than SO days after We rem you the trot big o viarhh to am or lomblan appeared. You can fall w Curmer Fialahirro number, but doing so vA not preserve yotw ridns. In vote Istler, dvw u to fobWkg I Your mums tld srrars render, to dollar am sew of tea suspected error, a descr,pron of Ye snor and an etplartlah, H Pte. ofWry You belarm there is an error, or if you need more kriarnadah, a deecdpden of the hem you are unsure about You do not taw m pay any emotes In question Wheat we ore Yn_tlordrta it, but You am so fe pay the l? of yw bN that ae not In q avil .re Invenrsa your guasdon, wo Cnnot rota y q =am or eke any action to odKt line 4,t Special RW For Credit Card Purchases If you hove a problem with tne quality of property or servos then you ptrdaaed wdM a credit taro and you hew tiled In good faith to tolled to prklsn nfth to Ileechad, you rosy phaewpertthe y right wnot to pay the remaining ilhis, plows dus 0 an the the NusdhaseNoes. You have ee than protocgo cry vthen the ?m6 r6kcs more $60.00 and the purchase, vas b yaw brow arm or Wihr 100 grin Of blur maling addren. Of via own or operate the nardum4 or if we mWbd you the advertisement for to property or nevi es M ptrdhaaes err ahverod spsder of anartt a Wino of pudase.) Please renhanber m apes d ampadernca. t Ones not air y* to mnaome roe-craft cad accounts t Does nor appry m busnew non-craft raid aeawarts One supports vionnedolloll p^riivacy p-*m sse our Ilancia W Colporation PM rights tad. 9 20033 err OILOLBAK t 8'_;; res Paled, You wiN have a mkrran grace paned of 26 days Wither tkrrhee drape on now Purdue, new balers UwwbM row avsria purchases and clew amen dhilges H you pay voter toal 'New Sdsm e', in aexerdrhn wide Ur ,rrgortert taotlne for paY^ants Eabw, end in tee for It m be traded by Yale rom am m m dosing date. There is no. gran period m cash edvanesa and apmw tnaleft . in addidory them Is no rum period m try 7ses' rn H you do not pay the total 'New b. aAearviloill Fill Closings. Transactions v"oh me not mt mm s Rr? Period enomnos dwgs 1) from the ban to den of its, tea n or the trae.dw to actt way of the to va yga. A2) 2) from Arrant a 3) from the fief calendar r o dry the wn blipomrlod Addidon H did od pay thefirvience 'Now dharges hon dr Pevim r your 1rW Wqe old ths bsW gib paiarlorue to d in . UrPdd Tlrm mete rho you pay, Aar antl er r=-. and m the -K of H you Ne yotr statement by the non at previous on tatft err doakg der, but did nL not ad le for the previous mark rhpf fbrnom uohm" ere added N e the sagmera at your rio that tc. a6irraa FkrsssnhC?rbJ?srsrct?P•Far each reek billing period that acoour& mbal RNNICF t7gMmliGE orfig W_?iww ba?fFp-mssd. If the Wall panic re(sl r b..ilam O o, w. v ?ewli a6uereaix lent t amount from the 40.50 rmkhisrun mW the difiwahn wi be bird to the purchase se?hat of valor aoraue. t d. Temporary R al mMYh Ih Kenn dZ- We reserve t w dolt to nor aasasas try or ail 11 drrpn for OW dv+ 2. A ti= -g gaily s-slas I... Nov Prole I. s. Final" charge is nla/med by mddoyfnp the dally balance of each augment of your accoum (e.g., cash advance, purd•es, psolei mmallm, and spacial pudeae) by the oorr=, daily periodic - set No been WAou y o you. At the and of each day durkp the biing Qafod, em apply the daily Pehlodic ro for each ahgmat a Var scan" le tM defy of each aegmhem. Then at fits and of #v@ bung I I f , ve add W the raw . of then frsily daitlae to aniw n hale pebdic fkaee dwp for each agnat. We add UP tM real paroodic reatb from each segment m sow at the tksnee cl algm for yaw sonar. To get the delay balance for each no W of your account, aavr?tole the bedrrrg an 1khs C hangs caloasoederw ? parneyvfone payments or lea dso possag te irma of tlrt t e i day that awe Youoetl to that asphar a. This gwe u the separate dally balance for each ss()msm of your ausuhart Hw vva, H You 0d de New Balree atavvh m yaw Prevfaa aterrmmert r hit (a H yaw new balance Was zoo a a credit amanq, now trahasLlior vAsch pest to your puduse or pored Peden aepmerars am not added to the deny balances. We calculate the mvapp diy!:. by adding ail sat tidy balances mpthm and dvklkg the sun by the rnWsr of the days r"wror big cycle To calculate ymr tall roam large, red" your average daily bsarroe by tM ddy redo I rem and by the number of days in ibm birg pedo . Due to rending on s ddy bmnb, may be a eight ffixe wfd l hsanrcpem ? esthis . amsasd and the angst of b. If the rode Z or N appeam m the from of ma statanero and m'Salls. Rate A= To; vm multiply iM deck Ypafat Il""n Payments you and to u V41 be , - 1-d to your aooom as of to buatrsss day we locales In, provided (1) you MW IM boom porran of rig 8141 410011 NO your r tie arJased raatnahce arvmWpe and (2) Your ppnmt In received In w roollselling caner by 3 p.m. Er (12 moon PT). Press allow at Ism tw (5) b.keas dryo for prand payments reaWed by u at try o vK lecdan or in any oria tome rosy not be cos I - as of tM Gy we receive than. Our busksa days am MadaY fhaM exdudrN Ya• Ross do not u e stapM, WPSr dbs,etc. whem.p=drhg Parr p7wlector rt. YYlwn You sad w a dhseleW, you adedze us m nabs a carne dseuare manna Gbit Mule bare traarr, you auMdze aeeounrt for to anwd ut 1M check This aPPass m ail received drlrg the big cycle own H mart by someone are. If war cannot process ON us m make a large against your Wok soooen using to clm*G a paper draft or other item. VERIFICATION CAPITAL ONE BANK vs RAMSEY, DIANE L The undersigned does hereby verify subject to the penalties of 18 Pa.C.S. Section 4904 relating to unworn falsification to authorities, that he/she is, MAISHA DAVIS, 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. MAISHA DAVIS No ublic MYRA PRINDIE Notary Pudic Gwinnett ,ny Commission Ew e Georgia s July3ist 200q 5178052505774527 A049 WELTMAN, WEINBERG & REIS CO., L.P.A. T -0 W (') *", a r' ? F •• M 00 d r ' ,?,,,,? (Y F ( W ^t. d V R. THOMAS KUNE Sheriff EDWARD L SCHORPP Solicitor One Courthouse Square Carlisle, Pennsyivania 17013 RONNY R. ANDERSON Chief Deputy JODY S. SMITH Real Estate Deputy To: Pos t Agency Control No. ?y hrl (?L L Y Date: Address Information Request Please furnish this agency with the new address, if available, for the following individual or verify whether the address given below is one at which mail for this individual is currently being delivered. If the following address is a post office box, please finish the street address as recorded on the box holder's application form. Name: l kAlL L 1.?}w? Last Known Address: d ?? L L y Pj K C I certify the address information for this individual is required for the performance of this agency's official duties. For Post Office Use Only () Mail is delivered to address given. New Address () Not Known at Address Given ?/S Oi?-?v?l R ad??° Lo f () Moved, Left No Forwarding Address le (} No Such Address O Other (Specify) Box holders' Street Address Agency Return Address Postmark/Date Stamp Please fax results to the Cumberland County Sheriffs Office. Number (717) 240-6397 Address Information Request (Required format) Exhibit 352.44b ?r ?!n z ??wN?f zS? i dr r i3sa1K7/?I'e??L /?. / LYcSStw? vc,S w L?c L" VtA 4- r/, 7? ?cq -w6)- 97c- SHERIFF'S RETURN - REGULAR CASE NO: 2007-06207 P E COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CAPITAL ONE BANK VS RAMSEY DIANE L KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon RAMSEY DIANE L the DEFENDANT , at 2014:00 HOURS, on the 9th day of November-, 2007 at 75 BONNYBROOK ROAD LOT 2 CARLISLE, PA 17013 by handing to DIANE RAMSEY 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 31?? Sworn and Subscibed to before me this of 18.00 10.56 .00 10.00 day So Answers: R. Thomas Kline 11/13/2007 WELTMAN T.TEINBERG RET^ By. A. D. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff VS. DIANE L RAMSEY Defendant No. 07-6207-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#6169898 Judgment Amount $ 1273.34 THIS LAW FIRM IS ATTEMPTING TO COLLECT THIS DEBT FOR ITS CLIENT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff VS. Civil Action No. 07-6207-CIVIL TERM DIANE L R.AMSEY Defendant TO THE PROTHONOTARY: PRAECIPE FOR DEFAULT JUDGMENT Kindly enter Judgment against the Defendant, DIANE L RAMSEY above named, in the default of an Answer, in the amount of $1273.34 computed as follows: Amount claimed in Complaint $1182.75 Interest from September 26, 2006 to January 3, 2008 at the legal interest rate of 28.24% per annum $90.59 TOTAL $1273.34 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: /" ? /'W E. ?/? WILLIAM T. MOL AN, 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#6169898 Plaintiff's address is: 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: 624 HOLLY PIKE MT HOLLY SPRINGS PA 17065 . J IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. DIANE L RAMSEY Defendant TO: DIANE L RAMSEY 624 HOLLY PIKE MT HOLLY SPRINGS PA 17065 I-0 L a ^ 8 Date of Notice: Civil Action No. 07-6207-CIVIL TERM IMPORTANT NOTICE 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 NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 WELTMAN, WEINBERG & REIS CO., L.P.A. VB RODT, ESQUIRE 2 INBERG & REIS CO., L.P.A. ilding s u venue A 15219 (4 169898 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. DIANE L RAMSEY Defendant TO: DIANE L RAMSEY C/O ANDREW SHAW, ESQ. 200 S SPRING GARDEN ST STE I I CARLISLE PA 17013 Date of Notice: 1- 1)1) _a U Civil Action No. 07-6207-CIVIL TERM IMPORTANT NOTICE 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 NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 WELTMAN, WEINBERG & REIS CO., L.P.A. By: PA WARMBRODT, ESQUIRE WE , WEINBERG & REIS CO., L.P.A. 271 ;sb, s Building 43 Avenue P A 15219 1 55 # 6169898 IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Case no: 07-6207-CIVIL TERM Plaintiff vs. DIANE L RAMSEY Defendant 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, DIANE L RAMSEY 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, DIANE L RAMSEY is not in the military service. Further Affiant sayeth naught. AFFIANT SWOR T AND SUBSCRIBED in my presence this eo?aay of t C.=-:j_ Od COMMONWEALTH OF PENNSYLVANIA Notarial seal ARY P Wendy L. Gault, Notary Public City Of Pittsburgh, Allegheny County My Commission Expires July 15, 2o1o Member, Pennsylvania Association of Notaries 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. P.equest for Military Status Department of Defense Manpower Data Center Military Status Report Pursuant to the Servicemembers Civil Relief Act Nq1W Page 1 of 2 JAN-03-2008 05:38:15 - Last Name First/Middle Begin Date Active Duty Status Service/Agency RAMSEY DIANE L 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. 14 hhi? lot. 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/faci/r)is/PC09SLDR.html WARNING: This certificate was provided based on a name and Social Security number (SSN) provided https://www.dmde.osd.mil/scra/owa/scra.prc_Select 1/3/2008 .Rimquest 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: GPEYDTASJF, https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 1/3/2008 CrN rn cri -c IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. Civil Action No. 07-6207-CIVIL TERM DIANE L RAMSEY 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 $1273.34 plus costs. ( ) Trespass Judgment in the amount of $ plus costs. ( ) If not satisfied within sixty (60) days, your motor vehicle operator's license and/or registration will be suspended by the Department of Transportation, Bureau of Traffic Safety, Harrisburg, PA. (xx) Entry of Judgment of ( ) Court Order ( ) Non-Pros ( ) Confession (xx) Default ( ) Verdict ( ) Arbitration Award Prothonotary By: PRO ONOTARY EP Y) Andrew Shaw,Esquire 200 S Spring Garden St. Ste 11 Carlisle, PA 17013-2578 Plaintiffs address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7`" Avenue, Pittsburgh, PA 15219 1-888-434-0085