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HomeMy WebLinkAbout07-6853IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK -- Plaintiff No: DI- W3 Civ -T; :r vs. COMPLAINT IN CIVIL ACTION MICHAEL P ZLOGAR 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 06215969 C N Pit BNT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. Civil Action No MICHAEL P ZLOGAR 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: MICHAEL P ZLOGAR 6270 HAYDON CT MECHANICSBURG, PA 17050 3. Defendant applied for and received a credit card bearing the account number 4862362590955012 . 4. Defendant made use of said credit card and has a current balance due of $2110.58 , as of October 12, 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 28.4900 per annum on the unpaid balance from October 12, 2007 . A copy of Plaintiff's STATEMENT is attached hereto, marked as Exhibit "111 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 , MICHAEL P ZLOGAR , INDIVIDUALLY , in the amount of $2110.58 with continuing interest thereon at the rate of 28.490% per annum from October 12, 2007 plus costs. James Warmbrodt,42524 WELT WEINBERG & REIS CO., L.P.A. 436 )bu nth Avenue, Suite 2718 Pit gh, PA 15219 (41 4-7955 F -338-7130 06 15 C N Pit BNT This law firm is a debt collector atting to collect this debt for our client and any information obtai d will be used for that purpose. w I lOnea PLATINUM VISA ACCOUNT 4862-3625-9095-5012 MAY 24 - JUN 23, 2006 Page 1 of 1 Account Summary Payments, Credits and Adjustments Previous Balance $1,468.82 Paymeata, Credits and Adjuatmeuts 00 Transactions $35.00 Finance Charges $35.96 New Balance $1,539.78 Minimum Amount Due $1,539.78 Payment Due Date July 22, 2006 Total Credit Line $1,000 Total Available Credit $.00 Credit Line for Caah $1,000 Available Credit for Cash $.00 Atyoursuvice To nB Cud- R&tkm, or to rVort a lost er.tolm m& 1-800-903-3637 Seadpaymmuto. Send lnqvuisft Ann, Rrmitnooe Prommins Capitai one Bank Capiw oft P.O. Ba 79=6 P.O. Bur 30285 St Law, MO 63179-0216 SLC, Vi 8413"" 1niortant Account Information Take control and start paying your bill online for free. Eliminate the hawks 0 wndng checks, finding aotmpq and eating em+elopes Everything you need to access, review, and Pay your bill is available online. Our webehe offer you a oDnvenxnt, ample, and aeame way to manage yotr account Viet www'cq%alone eom and register your account to start amplifying your life today. peoplepu online A better way to Irltemet. 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' 1-877-778-1207 Mention Offer Code: OPAL Or visit www.peoplepc.com/go%opal V PLEASE RETURN PORTION BELOW WITH PAYMENT V :aPffalow 0000000 0 4862362590955012 23 1539780080001539783 New Balance (1.539.78 Minimum Amount Due $1,539.78 Payment Due Date July 22, 2006 Total endowd $ ?1 Aocoaot Number. 4862-3625-9095-5012 Transactions 1 23 JUN PAST DUE FEE $35.00 You were mewed a put due fee of $35.00 on 06/23/2006 beauae your minimum payment was not received by the due date of 06/23/2006. To avid this fee in the future, we recommend that you allow at least 7 business days for your payment to reach Capital One. Poe. freM.eeS?aldxn -A-61.6V. trbmeur1M.-Hef ink Save Apc4 Gq Se- ZIP Home Ph- Al[em.m Phone 0 Pm-1Addne #9017530773827066# MAIL ID NUMBER Capital One Bank f? MICHAEL P ZLOGAR P.O. sox 790216 1111111118111111111111 a, 6270 HAYDON CT St. Louis, MO 63179-0216 o MECHANICSBURG PA 17050-8104 Isllsutlluullltalts6tlluutltlntlltllnntlltllulnltl ? >? 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Abmh-tD-Month pug With no term commitment is $14.95 for PeopkPC Aaxlerated; Sa95 for Peq*K Online willwi t acceleratatechndoW Offer ain leble to we 6" strbeaiers at least 18 yeam of age and may not be redeemed with any other offer Offer abed to dahge at any ems. Raw techaital support avelede for $1.95 per minute tYaor PeoplePC Collins AccebrkW, certain Cur page tied and graphics YM load faster when compared to standard dial-up Internet service. Athol mauk may vary . Service not will a in d amore. Access teal, taxes and other fee and misndwis may apply Piero technical support available fa $1.95 per meate. For questions, al toll-(me at 1.888.5TRYNI W. 02805 PecpleloC Inc. PeopbPC Online, and the PeoplePC Logo are negateied nadernarla of PeoPIePC, Inc- %demand; am lomperee of thir respective owners. All Rights PWierwd. Servge not available in d areas. Aoom tees. taxes, and offer tote and restrictions may V* Telephone toll surges may apply, aver dung alai peoode, You am mom" for date n initg VMdw a ail to one of au acoem numhem will mat in telephone roll diverge. Accuse may be limited, saw* drgtg tam of past usage Did-up numbers may he changed d PeopbPCS tiix ,11, 1. Cort nucam tae abject to tensed Woadaec N use is aged to PeopaPC OnineS Services Agrnment and Aaeptaab Use Poky. 56K Is the madnurn speed of service; actual speed may very. 0 2005 PeoplePC I= AM Righie Rmeerved. PeoplePC Once and fm logos we trademerla of PeoplePC in the U.S. 61d 0*W cDOmML 0 2006 Capital One SwAme, Inc Capital One is a federally moamed f nice mark AN Vela marvel s a? i O ?QdNS pp I N mN Will howaa mYenam Brea peeled of row eoorJal pwrl+aea •?rd ro?Y+o?sr yam total 'New Balree', in e Important Norm for payrn s bebw, D be aadted by your nee assistant t Is no grace period m cash admnaa ore. In eddies, therm Is ro tram padod H You dD rot Pay th tosl'New It. Amemang FYantee Change. Tranacdans With am nor frmemdata of?Ahewhaaetlona a 2ydfimh de da?0 Cutlet) trm action Is processed to your Account or 31, from the *at derldar day of the cu mm 6itp Pedod. AddltlorW, H_you =r.!= Balrma horn is peNaa bap e carpe. continue to acme m Wanes eta th egad yov upald balantm Is paid In ave. Tlia meat Y atr owe arrme cwpm, awn H you =N htru di yot Pay the tat by by ew Bairns meat m tie data, but did nos do so for the p 4ous umMt l paid ,00, rte added m me grant of yam Amour. t c. liianw FYrww?Obrr?p. Fa sect 6itp psdod dot moral F#iAIICECipWa KtwEaotff $$. lb 0.50 vN bbep?gYttmp tlmed If tthu psmb3ettam s do M.. l0 60, inns tar °A.Btenc that` mart from ms $0.50 6a0emptetimt? aa n dsad the dHaanmm err be bred m me pudws Ferwa?l+aa. We roamva Yr td Tmrparry Radealirh n =;D rot are any or r " se crrpes for any given 2. eragpatfodgalanme 1 N.w ralmaaeaI. a. Ffihreo camp b calCNOW M mg4:;:q to daaY belarice of acre aeonwt of tram nmout (s.a.. malt aaermrh a plat arrant m tit haWnm of eaM etFrnmr- TTnen at ffe and of the pmbd, vre add rep th results of thee ti ftmilaASlas Nam=Mw at year up the r iron each a , t to a at the total Ack Inane dw fir yam assort. To pat to dsgy balantm for escm ssa of yam aooetrt, we t" me balimdrmp balance for each aeamtrt and add any raw transactions and airy amat agrmat. roro. raanpe mrlaLOed m the praMaan days for We ten sbtmri my payments posted of that diet am .111-ted m?U e(prant Two u rpaayrae telly halahm f« each agprrert of yam accts mt. Ilohnwver, H you pelt dal kl w Bairtm an- m year preNae atasantant n Ai (« hFyar rrw b .11,h era zoo a , asdit or r shad, mw mwrantMr tale m vat aadws sandal taanr I(i?c - to ach ailp nit, and st ct paaWtama (H In code N M statement rue m'Bdan = Amnad To.' fw Acs sblmet any Vpad irons change Ildll I in th bounce of each 1 TNa glove u ft dally bNanrce of each add dail belances esch -9 mi 1ae bland pMed anndd dwde by to mu n rel- o} days n the bMng period This Ows u the a day balartm at each aegmen. 3. Amend Rraas fAPRI. a. Th term 'ArwiN Fwmnrt+0e Raa' may appear as APR' m to front of fhb a =1, b. If to code P prime), L (3-mo. LISM, C (CerdAcrte of Deposh), a S (Bantrard PmYns) appeam on be had of thin .taanrNnt nod to the periodic MMW, tie mmlolfe MUM end ANNUAL PERCBlrAOE RATES nuy wry qunesay may Increase a decrease based can the eased I dics., apfoouWndan Tim WIC Srse Jouing 7hem dner??eethe w/wesnelNCawrm disclosed to phr hr!ro vmkd covered by.yar Psdadc.autantannt ahdrp urea ss"m""rrme atwo mnp t1e petoac mMl, tans TP9may E and and ANNUAL PHIC decrease b 'taw in ga Iidmsy , a 4a td w.F &rdW Jp°dW pI: the mmyn pwrAmrly disclosed to you. Thee danpr ttr be eM - " m to Iris dry of Yom hNYq Prlod "a "rX 4. Ammer err of Late, Owrtmle and Retained !=F.= Year socont Wan be ano=W no mom thank geed here me ohms darling airy MOM period. Under the tams at Yom customer agnrnem, are reserve is night to wave or not m area any Ism Warr orbs notlS-dm m you vAtlsr v Wvkp ore dgh to seem tc erne or simper 4c=:1W sar6. 11 A of INS H• wnW 60 wgntip fie BPP"ppmm m 1h dfmm ata this of. eat ttatemane, we c m Vou tow 30 aM fiem to ft fee to tow r ow s aged to you to evdd csi such fee rewire to d You H you carosi your account axnp Una Deelod. You any mnanars to rte yet` ,secant WlAnut hvkp m pay the notifybbyy calling t tll stomersRla r Deparunent ots end bpeaaldyour New Beluee- In her (maiudirtg th B. H Va Cbe Yw Vou can Why pe? plyaasrm amomrs by Z air Cmantsnee "ademete doer oeparemanr. You rant demy you credit card(s) and 'comas •ccaaa dre, crmod IN p mudioa zed bring, and Dace Yor amart. It you do not caned reca?ipt?nifz dsrge ywrraYa? WrMSanp rmulydoerur smart. Ad,itirrlly, yw Hornet vvlg not be dosed umdi You Wv r rnarx. you owe u Morro: say trwecdo s you tow auBmaAzed manse drrpm, past due fees, ovmilnit Ism, Mounted payment fee, men ach- fees and any ohm fi m seamed to your .ewer. Ym am reapmriNS for err rearm weever drim ddoas the smahira rosy amnknmad sin gt request m to yam haprs m doe to acccun. 1 N rosy writ In detor appearke on war sceost after tree tow Moco nt H H has already bean Coed. For eermmtpb. authorized a prdw , Nom a nertlant and vre mcelw the transaction from to merc art after year account hem heart closed, yam amour wan be raopasd, the amour Df the of - will be added to year aocau t, rW Wyouu tvr be reapasI I for payment. H them is a mmmmroanafip be for year amont, the fee vA comae to be chanced, m the nmahr psmimad by low, uaa the Gomel[ balarw ties been Paid In IA a cleaned above. 7. U?aYt}a Year Aewat.Yar nand a acrnue can at be u in con exert warn ant. Inmates: w.d* p 8. /roved Abet Fleabane Cheek 0mimmiles, When you proN • chack as pa , ocii, I you ?a on alter m tow YNa fund aden from yam your orb • t elam e fund trade fro. m yrar basic tion, account W w to e paaw the pa yo r tarts transaction lam ws sae Mamatlon flmmrnmyam to mks an N account i sir be* fed mensfer, hr may be a datdra wW has yor barns psyme , ?m as the -ro day year recast yam WYmmront, and you vrer not raranve yam dsdc bacc from yam Rtsria Irrkuen BLL1JN0 RMn SUMMARY (in Cram 01 Enos Or Qwafe Abort Your BE) If you I" Yalu bill b Wrong, a If you reed nem ntamaaan me trrear.4m a ban, ands m u m s rpareta shat a sett as paasitla at to addrae for itpalW dw- m 1h from a this sstm ant. We meant hear fieet You no later than 80 days afar we am ym the ins ban an, Wish the emer a pmblan append. You can d car Customer Rebtlas member, but doing a Cur nat pramaw ern don In Year West, giw ran the taaow+w ih Your tuns and aocaad number, the dollar arson of th auyeced armr, a desaipaan of th error and m eeplarotimn, H posaade, m you begeve "MIS m amt a It You name more • of the hern you ore issue .bets. You do rot hew m ? any amount In question Willa vm am kris dgase In, but You ore rtlI to pay the pars .4 You that are not In qua M. kvvwmaaee year g erne, -- malt n y- ws «ta?e cry action to nMct Ms I,t Spadal Was For Cash Card Ft rdisses If you Iran • temblmn vNb fist quity of Property a smMosa me you ytaffn a credit card and you tow ided In 1pod tahb to rmm et the RnMan n with to memdant, you may how the dgm net to pay fie ra we" protection MY MR to yPa 1 p1n Ywm hew tiads nan aFia'01, pmrese err nsde in war home state or 'W", 0ilea of yw rrnyng snider. 0f War ~ a aliment to maresM.?l?1! ndbd vm the adwrdawss?e mty a rMma, r pacer pl or location er as W 66f to aim of pmadwe.) all t Dees ref *A* b meunan nm-tlemt rainy accmlna I Doge as SAWY m bu5est ao --* CW IC OUMS one supports ntamaion pdvacy pmscam; .se our One is a indemilly mrwm marls of Capiul WNW one CMIPM1th01n, AN rtd" emerwd s 2003 LBJUC the day. In to Mat brnp cycle. To calculate yam total dare pm dwps, m ltiplipom average ddy berme by do Witter protect. M dic e W rwQa rOO m m i daily basis, Users may bthe be aig aags wdniananw?a between this calculation and the maws of finance b. If *a sods Z a N appssss-m stl a fiat el ris mmm?rrt Moot m 'Bdame Rate Applied To,' era miuldply the r`ancoeed r PNW M you err m u tar be ao6eea m ymr aocaut a of th William, dry We realer h goaded (1) you sand thebDtrm patlm of rob sumsem and your clack n - mwebpe and (2) Yotr V=-V. b recdved n air woesdre omtm by 3 P.m. kT (1t mm Fr) I'bae row n ban iw (6) Wave days is poeal ONvery. Paynvats received by u at any other locos a lan brm may not be asdibd_ a of ms atlayy we mmM than. Our WYSr aye me Monday though Sa urdsy wooW lgaays Rees a not ue .tole, Prerr nip etc. Wsn pmr124r peymam. Wien you end u • dneckW tree ardtetizs u m make • ens-tee siecarric transfer debit lien atxoun for Urns amtwtt a ih deck Thin aMhaixaion m r deck. afwd dukq me bit coo even Hem by someone sine. If van came process I'm U= 7 IS. rModze us to make a chip aa' your bw* account using the cline A a paper draft a offer hem. 4-- _ - VERIFICATION CAPITAL ONE BANK vs ZLOGAR, MICHAEL P 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, DUDLEY TURNER, 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. Notary Public 4862362590955012 A049 WELTMAN, WEINBERG & REIS CO., L.P.A. UDLEY : w. _? 07 Request for Military Status Department of Defense Manpower Data Center ID Military Status Report Pursuant to the Servicemembers Civil Relief Act Page 1 of 1 OCT-23-2007 04:19:10 'K Last Name First/Middle Begin Date Active Duty Status Service/Agency ZLOGAR MICHAEL 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. lot jj4, A?M_ 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" U$L 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/?is/PC09SLDR.html WARNING: This certificate was provided based on a name and Social Security number (SSN) provided by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID:ZWMKOYDLER https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 10/23/2007 ?,? ? ?, o ?? 4 ? ?? s W? ? ?? z ??-- t :,, ? ,? ; z;? ? u w ?- ?rr'` ??j? G ?' ??3J O .A, SHERIFF'S RETURN - REGULAR CASE NO: 2007-06853 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CAPITAL ONE BANK VS ZLOGAR MICHAEL P 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 7T_(l(1TD MTrTJALT. D the DEFENDANT , at 1602:00 HOURS, on the 6th day of December-, 2007 at 6270 HAYDON COURT MECHANICSBURG, PA 17050 by handing to RICHARD ZLOGAR a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge >z/f?/ol 9- 18.00 11.52 .00 10.00 .00 39.52 So Answers: R. Thomas Kline 12/07/2007 WELTMAN i.TTnTTTBERG DENS Sworn and Subscibed to By: before me this day of A.D. rt IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. MICHAEL P ZLOGAR Defendant No. 07-6853 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#06215969 Judgment Amount S 2359.34 THIS LAW FIRM IS ATTEMPTING TO COLLECT THIS DEBT FOR ITS CLIENT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. ;r' 66 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. Civil Action No. 07-6853 CIVIL TERM MICHAEL P ZLOGAR Defendant TO THE PROTHONOTARY: PRAECIPE FOR DEFAULT JUDGMENT Kindly enter Judgment against the Defendant, MICHAEL P ZLOGAR above named, in the default of an Answer, in the amount of $2359.34 computed as follows: Amount claimed in Complaint $2110.58 Interest from 10/12/07 to 03/11/08 at the legal interest rate of 28.490% per annum $248.76 TOTAL $2359.34 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: WILLIAM T. MOLC?KN, 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#06215969 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: 6270 HAYDON CT MECHANICSBURG,PA 17050 IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Case no: 07-6853 CIVIL TERM Plaintiff vs. MICHAEL P ZLOGAR 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, MICHAEL P ZLOGAR 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, MICHAEL P ZLOGAR is not in the military service. Further Affiant sayeth naught. AFFIANT of AND SUBSCRIBED in my presence this /,,?%y NOT r?:y C-i 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. ,. IL IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff Case #0 -1 -(o??'J C iUiL ltl??"1 MICHAEL P ZLOGAR Defendant(s) IMPORTANT NOTICE TO: MICHAEL P ZLOGAR 6270 HAYDON CT MECHANICSBURG,PA 17050 ? Date of Notice: WWR#: 06215969 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 BY: iv'J1µa-ri t?x??QvtN?'?- PATRICK THOMAS WOODMAN PA I.D. #34507 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 KOPPERS BLDG, 436 7TH AVE. PITTSBURGH, PA 15219 R-;quest for Military Status Department of Defense Manpower Data Center Aak Military Status Report Pursuant to the Servicemembers Civil Relief Act Page 1 of 1 OCT-23-2007 04:19:10 Last Name First/Middle Begin Date I Active Duty Status Service/Agency ZLOGAR MICHAEL 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. V, 6 , it y6t 101 0144, D?? 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: hM://www.defeiiselink.mil/faq/nis/PC09SLDR html WARNING: This certificate was provided based on a name and Social Security number (SSN) provided by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID:ZWMKOYDLER h4s://www.dmdc.osd.mil/scra/owa/scra.prc_Select 10/23/2007 0 -61- 00 rb 4.1 :? r w IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff VS. Civil Action No. 07-6853 CIVIL TERM MICHAEL P ZLOGAR 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 /q (xx) Assumpsit Judgment in the amount of $2359.34 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: 41e: W17Z PR HONOT R PUTY) MICHAEL P ZLOGAR 6270 HAYDON CT MECHANICSBURG,PA 17050 Plaintiff's address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7'h Avenue, Pittsburgh, PA 15219 1-888-434-0085