Loading...
HomeMy WebLinkAbout07-6880 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff VS. SUSAN C SMITH AKA SUSAN DEIMLER Defendant I I -? 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 06179784 C N Pit SGM IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. Civil Action No SUSAN C SMITH AKA SUSAN DEIMLER 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: SUSAN C SMITH 1262 W TRINDLE RD MECHANICSBURG, PA 17055 3. Defendant applied for and received a credit card bearing the account number 5178052498648795 . 4. Defendant made use of said credit card and has a current balance due of $1263.60 , as of October 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 28.490% per annum on the unpaid balance from October 19, 2007 . A copy of Plaintiff's STATEMENT is attached hereto, marked as Exhibit 11111 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 , SUSAN C SMITH , INDIVIDUALLY , in the amount of $1263.60 with continuing interest thereon at the rate of 28.490% per annum from October 19, 2007 plus costs. armbrodt,42524 WELT EINBERG & REIS CO., L.P.A. 436 eh Avenue, Suite 2718 James )43-7955 Pit b, PA 15219 (41 ) F : 438-7130 0 1797 N Pit SGM This law firm is a debt collector a?ting to collect this debt for our client and any information obta d will be used for that purpose. 1/ Calon ^e Amount First 3 months half-price 97 h* 4$"Wma.#W"ftsr =FREEAcceleratoe -?" roar, sea e1po air after 12 fassides SIGN UP TODAY! ' 1-877-778-1207 Mention Offer Code: OPAL Or visit www.peoplepc.com/go/opal Previous Balance $858.89 Payments, Credits and Adjustments SOD Transactions $29.00 Finance Charges $21.03 New Balance $90&92 Minimum Amount Due $90&92 Payment Due Date Jaly 03, 2006 Total Credit Line $500 Total Available Credit $.00 Credit Line for Cash $500 Available Credit for Cash $.00 Atyourservice T. all Customer R&uoes or to reportalost or stolen ark 1-800-903-3637 Send pxrmcm to Seed mg4uis to Attu: Rrsnitana Prooeuing Capital Ott Beek Caput One P.O. Bas 790216 P.O. Box 302&5 St Louis MO 63179-0216 SLC, UT 84130-0285 Important Amount Information Take control and start your bill online for free. Eliminate the hassle of writing choke finding stamps and sealing envelope. Everything you need to acoeay review, and pay your hill is available online. Our weteshe offers you a convenient, simple, and secure way to manage your account Veit www.aPh1I0De.0Dm and regista yo,M account to start simplifying your life today! peoplepc- online A better way to Intemet. PeoplePC OnNne offers the features you would expect from higher-priced Internet Service Providers at half price for the first 3 months! ® Email Virus Protection ® Pop-Up BlockerTM Spam Controls ,so ?% Smart Dialer ® [W More Email Addresses ® * Internet Call Waiting PLATINUM MASTERCARD ACCOUNT 5178-0524-9864-8795 MAY 04 - JUN 03, 2006 Page 1 of 1 Payments, Credits and Adjustments Transactions 1 03 JUN PAST DUE FEE $29.00 You were assessed a Past due fee of $29.00 on 06/03/2006 because your m+-+n+ Payment was not received by the due date of 06/03/2006. To avoid this fee in the fitture, we recommend that you allow at least 7 business days for your payment to reach Capital One. EXHIBIT Finartm Charges Pk" .w reverse ndefar infort mt informatim ? nW dd Periola A ? dP _ ?C$ ?`? r r r, s PURCHASES $869.02 .07805%P 28.49% $21.03 CASH $.00 .079096P 28.49% $.00 ANNUAL PERCENTAGE RATE applied this period 28.49% V PLEASE RETURN PORTION BELOW WITH PAYMENT ?0000000 0 5178052498648795 03 0908920025000908925 New Balance $90892 Minimum Amount Due $908.92 Payment Due Date July 03, 2006 Total enclosed $ Aeconnt Number. 5175-0524-9864-8795 Pr-y.int.n?rag Z&-arL>e,eair??r. br--Vahua,W k;sk Sertet Apt.; uty S_ ZIP Home Phone Ab- Phone Ezaaedd+.. #9015593279283517# MAIL ID NUMBER Capital One Bank SUSAN C SMITH P.O. Box 790216 ?11n1ut111n1u1tt11 ?e 1262 W TRINDLE RD St. Louis, MO 63179-0216 c MECHANICSBURG PA 17055-4517 loll un11ntl111m11t1trlife nIIII I II1t11refill Ollie If II II PleaseunterwarmantmemberonyomcbsctAmoryordermadepTabletoCapital OneBm,.iandrailintheendaredenrro a r peoplepr- online A better way to Intemet. UNLIMITED INTERNET ACCESS SIGN UP TODAY! 1-877-778-1207 Mention Offer Code: OPAL Or visit www.peoplepc.oorri/go/opal PWPWPC is solely MVMSb a for this offer, Mind is not aHietad with Capital One. Oat W One does not provide, ardora or guararae, NO is not affiliated with, any product or service shown hers. Any badwnarka mentioned how are wifely owned by the respective wally All rights rewwmi By responding to this offer, you may be conmunicwurg infonris on abort yourself to the company tat provides this product - for mmpie, flat you are a Capital One customer. •PeopW Accelerated: First 3 months of service are bled at 54.97 a mmtt $9.85 a math ttermNer. 12wad commitment natured for PeopWIC Accelerated. Mash-to-Moak paiceg with no scum commitment is $14.95 for PeoplePC Accelerated $995 for Pep*K OKne witout accdwala technology Offer availelple to new dial-tip, at keg 18 yeas of age and may not be ndeerned with any other offer Offer subject to change at any this. Phone tecMicel support avallade for $1.95 per minute. tWIth PeoplePC Online Accelerated, certain Web page tan and graphics will bad faster when compleed to standard dial-up Internet servioe. Actual realts may very. Service no availabb in all areas. Access fees, taws and other fee Mind mallpictions; may apply. Phone technical support avaiable for $1.95 per meats. For quaetims, call toAiroe at 1-8W5TRftW. 02806 PeoplaK Inc. PeoplePC Qua and the PeopleK Logo we registered tredwrwke of Psoplei Inc. Tradanants we properties of th* respective owners. All )ages Pmwied Service not available in ON res. Awes fees, tans, and *0lsa and rstritlpra may spiely Telephone tool charges may apply even dung W pert• You are fapdal le for determining whether a Call to one of our access nmba i will matt in telephone td charges. Axes may be fhiited, especially dung tires of pat usage. Dial-up nurnbere nay be dnaged at PeoplePCI daaston. Continuous use subject to timsdd protedIm Al use is sbiect to PeoplaK Onine's Services Agreement and Acceptable lls Policy. 56K is to maainam speed of service: actual aped may Vary. 0 2006 PeopW'C Inc. AN Rights Reserved. Peopi Online and Me logos are trademarks of PeoplePC in the U.S. and other countries. O 2006 Capital One Services, Ix. Capital One is a ledwaly regiwe ed senfa mark. AN rights reserved. Ta. Gras Paled. You vrlal taws a minimum grace period of 26 Nye without lime tlrr e m n w d NIIq Dpa cow b k F ?b l p e pu rhea, row balahm Hernias, new egarLr Wahaes and row ode= ri q e arhoe ea traraedaro m err drags H you pay ysr total 'lbw Berme', h or or*". (H the pay bdw, poorer tbdce a am atatanwn rem u r mid In b r it m bo cra*W by mtwmK guartract any up dosing dme. There Is no gece, period on nth advrmes of soh s?hwd. cud special pwnafere. In addidm, them Is a arse period aegnwn. TTmn, v on wry trwmwdm H you do rot pay the total 'tbw segment for the It 8 O N ? N ' OW O nit b. Aswrbp Fireman Oegs. Trarracto a vribh are not "Vamp daly'l nb)ect to a Vq Pebd ae amend anehoe doge 1) 3. Answl T frwn the dour of the vwmacd m or 2) firm the data tan .. l1r = nt A transaction is processed to your Aeraut or 3) from the APR' or, the Awt caladsr day of the cwt, bFinp pwfpd, AdM.*y, H ou did imt tar 'Mw B f fi h l a b. If the code P 1 y e errs wn t e pre one p y osng Pwhe . In full, fkrrme dugs conk nit w scan w m Deposit), or 5 this statement yw uVSid blame u d the upad bd- I. bald 1. fill. retm and corn Ins mew dw you may sal owe lnace charges, even H may vary gusr you pay tr en ft New Banco, indicated an the front of Your stem m by the neon, summers ciahlrg dams, but did m the sated I .bass), pfer 1 not de so for the W&vkKn mosrR Urpad M drips are sddsA b tar a pplC a6 16 oegnwa a Thee dmrnpw baling Period c ? ? ? ? ? ? • posted tinat •r c. For ? i =r-accaaum ¦ biect Ilhs char p charge, • naninturn D If the ode D c if the Rods I I a If the tool F7NNCE pW p E o f a.60 w0 b l e Y p o e H UBtKi Rprloe dr ra n w l U n p p p f a a o ywr aricA rw 4J lsl . 30 60 i p e a ws ,wevi abase[ tart snout fee the 00.60 nhkirsm sad the dff sea wit be and cwropose vary mosdiY a baled to to purchase eptmsK of aoccui td Terefig Radssla b Fairs gi s Vale mean th stated kh6ce, IN g s e riV m rot oar sty or sal Brame drips fix sry plush rondo qe We ba affsety average dally, balance for the is statanna ft, era take the seam, each day, add any rmw m, and aWOaet acs gNnenu spare on the inmt of tlda Rate Applied To; era also charge iMUded In the balance we u the defy balance of eater al the dNyy bdW- for ash d and dNde by the total g im" This gi- us the c segnem. pre Rate' may appear as my can lost day of eriodc warren erring 1y cud October. UBOR) w O (3-mc. is on the from w your ateb), the psraode noes IUMAOE Teo way a dsaaase basd m rim WON Sows jxtrwi pkw to you. Tfrs rdnarnpeh I a your hlal'g periotl a. Asset of tab, Wwlsdt woo Reamed ?aymwt Fam. your aacant wit be ennead no men than two of the ban anted here that ocrtr dukg any ballets period. Linder the temm of your customer agreement, cues re.erve the right to wralw or not to arse any fee wlthex prior notification, to htthen velvkg our right to sees the same or almlar a • istm tits. 6. You Assist H a membership fee appears m to fried of tan statemenht, you haw: 30 day. man to doe tan statement vrs nhaled to you to avoid =the fee or to haw such fan sanded to you if you nlmd your account. During too period, you may continue to use your accost wlthoa bang to pay the mambenhip ties. To areal you account, you must rotlty us soy no orr Qrtorner Rwatiorr Depanmmt and payraylops New ealsrm' in fir Wicli ring the d ew Chan Yw prior, to the and of the you can thirty day pedod. N yea aceo.n by calling our Cutemer one e DeP.whom. you rout dearroy your credit card(.) and asset aecam chocks, arms s.1 preadhorized hirg, and cans your acsun. It you do not cared mwudorized emhlganems, wro Mil earider Hof aA??y,y your account tie to mopes your y yea sccoun wit ran be clued IN you pay all amounts you owe us kmkmkq any traraaons you hew autmdzed, lrnancei c ergee, past due foe, owdkM fen, mtumad payment fees, sewn advace fees and any other tom a.memo to your arras. you am re.OOrsI, , for them amounts; whether they appear m Von account at the time you mrFmw to don the account or they am khcursd subsequent to Yomr rogmmw to dos the account. Tns may malt In Uhsrgn uNPeanra an yw acamt aha You hew you account H It has akeady been dared For erwrrole. f You aWmrlzad a pule than• n rcfmrnand wue account t has been so tbeen c dlot flsan the merdr, afmr your thclosed. yam eoedrr -11111 be red, the avian Of the cihsrye Will be sdde0 to yam Moorta amour, adYetr vi?al be Impossible for payment. H there is ¦ riwrmwalmp fee for your lelmul[, the fee wi ankle to be c homed, to the wmwr patdtud by Isw, and ym socou, melrnes Iw bran paid In fill as cleaned above. 7. Uakg Your Aamut.Yw card err aasut can of be used in amrhrhedlwn with any btarot gembiq trw 8. lots. About payment, Biwarmle do a audioam. When alt you ion as oa you a - r to preen • acheck use Information loan y r you to mks ke s osti tars M s ec ast c die find Herter from h your bank socou, a to precast e MYhmar, s • trek trrrecsoa When we urn =::m n fiern yam ch k to make tit alacpontc find prrier, tads maybe vuhtdrswn from your boor account as soon s the Gene day tm rerdw ywr p.ylnant, and you cur not feral" your dick = from yam anhwnciY k'n.USdorm. WILING RKHT'3 SUMMARY (In Cos Of Emus Or Questions Abort Your Bag If you 1Nnc yam bal is wr-ra err if t'ou'red more Infarmatlon can a trarsoctm bal, wile to u o a aparm slow, s soon as possible at the addren far kqukiss shove m the from of dos staternent. We must nos fioln you a lateramor err probl tlnn BO emohsPaweap ten y,ocanthe 1rst H m wnfh tm rod. You Cal or C rtomef flotations number, but doing m vi rot peashas your, filings, In your ctAav*V r twinsei Voter ame and account humb be s, to defier snout of the suye acted error, a deedpdcn at to arts and - w ilanodon, if poslNe==.n beeva tharo is error, or H V. need more description of the here you ero tats abort. you de nisi hew to pay any amour In question vfae vve ero M?msdoad'r H, but yw are .A obligated to prey the pans of yw hit the ero not In qA"-. vale we yam ghrsden, we cannot, report you n rislnPrwm or ta any action m colect the room you gcestlm. 4,1- Special rule For Credit Card purchaser; If you hove a problem with the quality of property or sonices that you purchased vM a credit card ad you hoe tried in good tafeh to rbwal the problsn wM the merlin, you may how the fight not w pay the renaHng amount on m the pmpe'ty or seNces. Ym have No Menma prfoe wasroe 1Nn 00tmosYy afro to Puea and tr of your r was made In ywO her star or opWn 100 t or if vre if We ailed Vo Yom Of we ova or operate operate the merchant, melad the aMadamem for the pmperty or service, W ptadwa cowired regardless purchase.) to sign off means of purchase.) Please re rb t Does roc apply go me'arur wawtreda -W sccou to z Doom oat apply A) buxleass Am-& ceW semorta pdvacy protection: me our so service mark of Capital rise reserved a 2003 O1LOLBAK t. Fate A-rage Daly Inimme c (bmakriy N ..? a. ro baige rge is is alalnad W a. Bur w, of you saps, (o.a., nth balance s ado sgn advwm, Padre, spacial trarM, and special purch=O by the anegsnN diy p ftft masts tart M been p-Ap sly to you. At to eel of each day the being perod, - apply Me Psbdc ram for -on am - of your mashnt m tM 6sarha of mdh sgnmtThan a, and a the psmiod, we add up the . of them delay alaLder to aria a ?eac h sale for to vi the tour( Rho from fkhwm drape for you aoeorr. To get to drip beams for mch seat m of your aeoou,, we take the begrnig blame fan each sea, - cud add shy aw, trarnc?soa and aypa?bde lkulm drge caloulstad m the prev(oi Nye balerlRm f r Vast saghws. We than subtract: shy psymats or cede poamscl as of test day that are alocatecl to that segment. This gWS u the "I nee delay balroee sept? s hot V scows. However, H you Pmld to you preNohr shstmar h fill for H yam acs milwom wea zero c • ?n arms), acs purchaser wMlrh pow b You Memnon, to " or special dally, ?ah celo4r the averages dally balance, by ad3g dthe ? y b-h m tspslor and dhlArig the sm by the nsrimr of the drys let she errs, bins cycle. To calculate your twl lblao drrpm, muh1; Voar awm n dw§y bd- by to NM pabhae rte ad by the number of days in the big pesod. Due m rcming on a dW beds, acs may be a I wriaae betw,en this alcdurfm and the amps, of b. H the hsde Z c N rs fiom of his siaeehnan row to 'Blom Rao Applied To: cum rrsatlpry the balm srte? : Payments you mM to as wM be casdesd to your account a of tr business; day cues racNw h, pmNdsd (1) you sad to harm poNm of the statement as your o3ra envelope and (2) you q in+immrtt Is 7cot hynnot b ar weoelrm owner by 3 p.m. ET (12 mom Pr). Pose allow of roan 1w (5) bmekrs day. is postal tldvery. Paymws Feoelwd by a at wry Wkrrr looaton or wry wasurspma lwana cynaadutsd_ we of the de vie ecohm then. Our buskrs days an hkrdhy 1Naudo Saturday, omgWnp lrildaya. a de rr[ us. stalls, Ccwh ckThlsauter(z"."aegpiis 1o al docks w x. n fer inn amen[ a the aecaid adrg the blip cycle own It mart by samara . it we cannin process ter transfer, sulhodze us to make a drags apart your bw* account ueing the deck, a paper draft a other ham. VERIFICATION CAPITAL ONE BANK vs SMITH, SUSAN C 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, 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. TRACY T Notary Public 5178052498648795 A049 WELTMAN, WEINBERG & REIS CO., L.P.A. ???sA h vNS V ` JI - 0 . ,x^ 5 SHERIFF'S RETURN - REGULAR CASE NO: 2007-06880 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CAPITAL ONE BANK VS SMITH SUSAN C AKA SUSAN DEIMLE 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 SMITH SUSAN C AKA SUSAN C DEIMLER the DEFENDANT , at 1600:00 HOURS, on the 4th day of December-, 2007 at 1262 W TRINDLE ROAD MECHANICSBURG, PA 17055 by handing to CHRIS SMITH, HUSBAND 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 18.00 Service 5.76 Affidavit .00 Surcharge 10.00 / p1 .00 `\ 33.76 Sworn and Subscibed to before me this day of , So Answers: R. Thomas Kline 12/05/2007 WELTMAN WEINBERG REIS B A.D a IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. SUSAN C SMITH Defendant No. 07-6880-CIVIL PRAECIPE FOR DEFAULT JUDGMENT 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 W WR#6179784 Judgment Amount $ 1,387.87 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. 07-6880-CIVIL SUSAN C SMITH Defendant PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter Judgment against the Defendant, SUSAN C SMITH above named, in the default of an Answer, in the amount of $1,387.87 computed as follows: Amount claimed in Complaint $1263.60 Interest from 10/19/07 to 2/22/08 at the legal interest rate of 28.49% per annum $124.27 TOTAL $1,387.87 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: \ f James C. Warmb dt, P.A.I.D.# 4252 Weltman,Wei er & Reis Co .,L.P.A. 436 Sevent Ave ue, Suite 1400 Pittsburgh A 1 219 (412)43 955 Fax:4 -338 130 179784 Plaintiff's 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: 1262 W TRINDLE RD MECHANICSBURG,PA 17055 IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Case no: 07-6880-CIVIL Plaintiff vs. SUSAN C SMITH 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, SUSAN C SMITH is not in the military service. Affiant further states that this belief is supported by the attached certificate from the Defense Manpower Data Center (DMDC), which states that the Defendant, SUSAN C SMITH is not in the military service. Further Affiant sayeth naught. SWORN TO AND SUBSYRI ED in my presence this a?4dhday of -A /I YLJ ARY PU LIC 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. r IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff SUSAN C SMITH Defendant (s) IMPORTANT NOTICE TO: SUSAN C SMITH 1262 W TRINDLE RD MECHANICSBURG,PA 17055 Date of Notice: WWR#: 06179784 Case # 0-1_ &Se'6 CIVIL. 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: :7ik - YKG? 04 fuel tau4-- PATRICK THOMAS WOODMAN PA I.D. #34507 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 KOPPERS BLDG, 436 7TH AVE. PITTSBURGH, PA 15219 E,equest for Military atus V Department of Defense Manpower Data Center Military Status Report Pursuant to the Servicemembers Civil Relief Act Page 1 of 1 OCT-26-2007 13:45:31 < Last Name First/Middle Begin Date Active Duty Status Service/Agency SMITH SUSAN Based on the information you have furnished, the DMDC does not possess any information indicating that the individual is currently on active duty. Upon searching the information data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the current status of the individual as to all branches of the Military. I/I. 9?A4- /it AA?_ 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/f4q`/pis/PC09SLDR.htm] 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: BBSMCLVHUXB https://www.dmde.osd.mil/scra/owa/scra.prc_Select 10/26/2007 `# . P 8 00 ? rv c7O 00 'I QZ "? l IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. Civil Action No. 07-6880-CIVIL SUSAN C SMITH Defendant NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the following Order or J dgment was entered against you on (xx) Assumpsit Judgment in the amount of $1,387.87 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: PROT ONOT DEP TY) SUSAN C SMITH 1262 W TRINDLE RD MECHANICSBURG,PA 17055 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 - 4b IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. SUSAN C SMITH Defendant No. 07-6880 CIVIL PRAECIPE FOR SATISFACTION OF JUDGMENT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt PA I. D #42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#6179784 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. Civil Action No. 07-6880 CIVIL SUSAN C SMITH Defendant PRAECIPE FOR SATISFACTION OF JUDGMENT At the request of the undersigned attorneys for the Plaintiff, you are directed to satisfy the above-captioned Judgment. WELTMAN, WEINBERG & REIS CO., L.P.A. By: James C. W rm rodt PA I. D #42 4 WELTMA INBERG & REIS CO., L.P.A. 1400 Ko pe Building 436 Se Avenue Pittsbu , PA 15219 (412) 4-7955 WWR #6179784 Sworn to and subscribed before me this 14TH CN::? October, 8 ARY PUB COMMONVVEA1.Ti-: F i s`rL?; pi a; Nota ii a, HP!idi J. Kelly N ; , public E City Of Pittsburgh, Alie+'1h'J rt County N k My Commission F_4)im.; ?'A(Y.. 4, 0109 €4 Member, Pen. , ;+ani ; Psso iatic : i F,h;t,r'izs n 44. 00 N ?n _ V