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Home My WebLink About07-6963 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK n_ Plaintiff No: UVi( Terin VS. TIM HARRIGAN 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 06205129 C A Pit LXR IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. Civil Action No TIM HARRIGAN 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 6851 JERICHO TURNPIKE #190 SYOSSET , NY 11791 . 2. Defendant is adult individual(s) residing at the address listed below: TIM HARRIGAN 13 BUTTERNUT LN MECHANICSBURG, PA 17050 3. Defendant applied for and received a credit card bearing the account number 4862362433973412 . 4. Defendant made use of said credit card and has a current balance due of $1496.10 , as of October 18, 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 12.900% per annum on the unpaid balance from October 18, 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 , TIM HARRIGAN , INDIVIDUALLY , in the amount of $1496.10 with continuing interest thereon at the rate of 12.900% per annum from October 18, 2007 plus costs. James t/W rmbrodt,42524 WELT W INBERG & REIS CO., L.P.A. 436 S ven h Avenue, Suite 2718 Pitts ur PA 15219 (412 43 -7955 FAX: 41 -338-7130 062 51 9 C A Pit LXR This law firm is a debt collector atte p ing to collect this debt for our client and any information obtaine will be used for that purpose. 1 ?"Peoplepu online u A better way to Internet. • Mddl r0r9ls"12 moetln9-a Wvslsssl I -SW-587-9669 • • ' Mention Offer Code: DOLLAR •? Visit www.peoplepc.com/go/dollar UNLIMITED INTERNET ACCESS PeoplePC Online offers the features you would expect from higher-priced Internet Service Providers, including: ® Virus Protection powered by syrnerstec- ® Pop-Up BlockerTM 1?j Spam Controls ®* Smarter Smart Dialer Technology r ?g More Email Addresses ® fo Intemet Call Waiting Aooosmt Prevwus Balance $1,048.75 Payment, Credits and Adjustments $.00 Traffiactions $38.00 Finance Charges $14.49 New Balance $1,101.24 Minimum Amount Doe $1,101.24 Payment Due Date January 11, 2005 Total Credit Lin $200 Total Available Credit $.00 Credit Line for Cash $200 Available Credit for Cash $.00 Atyourem-Am To all Coswma Rahtam, car to zgmn a Imt or sadm au& 1-800-903-3637 smd iwryius uc Attm Rmh P one eoodsing CapihdOneswrkft Capiwonesw. P.O. Has $5147 P.O. Has 85015 Ri&raomd, VA 23276 Rirl mm4 VA 2'$265-5015 Important Accwmt lnfarmafmm It's Capital One Bowl Week time again! Tune in to ESPN, ESPN2, and ABC starflgg December 14 lot the best in -season coDep footbaIl action, to-on yule £maite teams ht for bowl chsmpiomhtps, and for college football's ultimo prize: the BCC$S National C "t And on New Year's Day, be vac to tune in to to watch the Capital Out Bowl and sit which mascot is crowned the Capital One National Mascot of the Yea! PLATINUM VISA ACCOUNT NOV 12 - DEC 11, 2004 4862-3624-3397-3412 Page 1 of 1 Payments, Credits and Adjustments Tnianctiom 1 11 DEC CAPITAL ONE MONTHLY MEMBER FEE $3.00 2 11 DEC PAST DUE FEE 35.00 You were assessed a past due fee of $35.00 on IV1112004 because your minimum payment was not received by the due date of 1211112004. To avid this fee in the fume, we recommend that you allow at least 7 business days for }oiu payment to reach Capital One. EXHIBIT FinanaCharges Pdas Avrmffje dcifrr:mpatas risl6r i- iZ ?? Harr a. PerrFt wr p PURCHASES CASH $473.90 . SSOL93 . 03534% 1190% 05425% 19m% $5.02 $9.47 ANNUAL PERCENTAGE RATE applied this peaod 16.70% PLEASE RETURN PORTION BELOW WITH PAYMENT 011e• 0000000 0 4862362433973412 11 110124 0150001101244 New Helene $1.101.24 Minimum Amount Due $1.101.24 Payment Doe Date January 11, 2005 Total enclosed $ L ::1 Aeoomt Number. 4862-3624-3397-3412 N-f WxwTmr.lint.rt?w-W.&aga kh-worH--Ma*wi, $Mee Apt s cu7 snot 21P Ham, Phone Altmmm Phm #9034710516826166# MAIL ID NUMBER Capital One Bank TIM HARRIGAN P.O. Box 85147 13 BUTTERNUT IN Richmond, VA 23276 MECHANICSBURG PA 17050-7943 w _ Lt?tLslltttI I 111,t61111 161 Unsl6nns111111 11111 16161 Pkem%Vrdeymvaomownwaieromyawchwiormmmyordvanal-fisymbktoC#dslOneAantendmailinJ6rewrl de.,J*c r VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA. C.S. 4904 relating to unsworn falsifications to authorities, that he/she is WA?- - (NAME) authorized agent of Capital One Bank, plaintiff herein, that he/she is duly authorized to make this verification, and that the facts set forth in the foregoing Complaint are true and correct to the best of his/her knowledge, information and belief. WWR# rr- + -x D SHERIFF'S RETURN - NOT FOUND CASE NO: 2007-06963 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CAPITAL ONE BANK VS HARRIGAN TIM 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 HARRIGAN TIM but was unable to locate Him in his bailiwick. He therefore returns the OnMDT.A TTTTT' f_ TVYTTOV the within named DEFENDANT , HARRIGAN TIM 13 BUTTERNUT LANE NOT FOUND , as to MECHANICSBURG, PA 17050 DEFENDANT IS IN DRUG ALCOHOL REHAB. FACILITY. Sheriff's Costs: Docketing Service Not Found Surcharge So answers fr J? .. 18.00 9.60 - 5.00 R. Thomas Kline 10.00 Sheriff of Cumberland County .00 ? 42.60 WELTMAN WEINBERG REIS 12/14/2007 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. TIM HARRIGAN Defendant No. 07-6963 CIVIL TERM PRAECIPE TO REINSTATE COMPLAINT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: JAMES C WARMBRODT, ESQ. PA I.D. #42524 WELTMAN, WEINBERG & REIS, CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 W WR#06205129 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff VS. Civil Action No. 07-6963 CIVIL TERM TIM HARRIGAN Defendant PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. WELTMAN, WEINBERG & REIS CO., L.P.A. JAODT, ESQ. PA WEERG & REIS CO., L.P.A. By: rsBuildinng 271ng 43Pit(41#06205129 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. TIM HARRIGAN Defendant No : 07 - (pq (p3 0A.V I t 1"M COMPLAINT IN CIVIL ACTION FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt,42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 Seventh Avenue, Suite 2718 Pittsburgh, PA 15219 (412) 434-7955 FAX: 412-338-7130 06205129 C A Pit LXR q0'j COPY FROM R Ee O Ra in TAY whereof, I here u VW SW of said Cou at Carl g, a. ..,,1q.-.sue tv IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff VS. TIM HARRIGAN 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 06205129 C A Pit LXR IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff VS. Civil Action No TIM HARRIGAN 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 6851 JERICHO TURNPIKE #190 SYOSSET , NY 11791 . 2. Defendant is adult individual(s) residing at the address listed below: TIM HARRIGAN 13 BUTTERNUT LN MECHANICSBURG, PA 17050 3. Defendant applied for and received a credit card bearing the account number 4862362433973412 . 4. Defendant made use of said credit card and has a current balance due of $1496.10 , as of October 18, 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 12.900% per annum on the unpaid balance from October 18, 2007 . A copy of Plaintiff's STATEMENT is attached hereto, marked as Exhibit "1" and made a part hereof. 7. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed and/or refused to pay the balance due to Plaintiff. Wherefore, the Plaintiff prays for judgment in its favor and against Defendant TIM HARRIGAN , INDIVIDUALLY , in the amount of $1496.10 with continuing interest thereon at the rate of 12.9001 per annum from October 18, 2007 plus costs. James .(/W rmbroar-, 41z , W INBERG & REIS CO., L.P.A. WEL 436 S ven Avenue, Suite 2718 Pitts urg , PA 15219 (412 43 -7955 FAX: 41 -338-7130 062 51 9 C A Pit LXR This law firm is a debt collector atte p ing to collect this debt for our client and any information obtain will be used for that purpose. peoplepc- online 11%? A better way to Internet. a` ../ v •? • PRINAoce%rstor lertbaSat flalarltleM-a4tpaatllat 1-888-687-9669 Mention Offer Code: DOLLAR . Visit www.psoplepc.corWgWdol1ar UNLIMITED INTERNET ACCESS PeoplePC Onkie offers the features you would expect from higher-priced Internet Service Providers, including: V Virus Protection powered by syrnarl[ecTM 18 Pop-Up BlockerTm Spam Controls 40 Smarter Smart Dialer Technology 4p More Email Addresses ®? Internet Call Waiting ?ChW Awo= Sw m y Previas Balaoa i1,o4t 75 Payments, Credit and Adjmtmeatc f 00 Tnmctiow (3800 Fmsnoe Charges $14.49 New Bshmw $1,101.24 Minimum Amami Due $1,101.24 Pgment Due Due Janmry 11, 2005 TOW Creda Lice $200 Tom! Avd" Credit S 00 Credit Liao for Cash $200 AvaS sHe Creda for Cash $40 Atyauraerrke To aB Cu mar Rdwiaw as b iepwt. kd err "m e-k 1-800-903-3637 Sad pay.-s u s-a ampbio a Cwp6 P.O. 5147 .le0eeta.:ae. ==-- PBuz 85147 P.. Baer SSOSS Ridm-4 VA Z276 Ridwee4VA23285-" ImpoztantAccumInfo>mat m h's Copiul One Bow] Week time again! Time in w ESPN, ESPN2, and ABC aatrog Deoemba 14 fur the bat is -snson oe&F footbaIl acoaa, to•aa your favonve teams for bowl aad far College foo"', utdmoe prize: the BCS Na oaai Cha=11. Aad on New Yees Day; be sue m toot in m rd the Capiul One Bawl and see which no mm is cowned the Cspiul One Nadoml Maluot d 6v Yeah. PLATDq M VISA ACCOUNT 4862-362+3397-3412 NOV 12 - DEC 11, 2004 Page 1 of 1 Paymesta, Credlm and A4oetmmm Tranac6m 1 11 DEC CAPITAL ONE MONTHLY MEIvIBER FEE $3.00 2 11 DEC PAST DUE FEE 35.00 You were awelad a put due fee of $35.00 ou 1VIV2004 be== your minimum payment wn aot reaeiaed by the clot deer of 1 211 112 0 0 4. To avid this fee in the A=m we recommend that you avow at lent 7 bocnex days for your Pl7aeta to reach Capad One. EXHIBIT numm Charge Plo-r?arrawrxtas& f .iatlartawt a Patann-r wiali r f It, C-NIKV ¢j , r m PURCHA.SPS 847190 035346 12.90% 85.02 CASH IM93 . 054217( 19480% 29.47 ANNUALPERCWrAGERATEapptsedthsp =d 16.70% PLEASE RETURN PORTION BELOW WIl$ PAYMENT v :--whWom, 0000000 0 4862362433973412 11 1101240150001101244 New Babma $1.101.24 pla- piw.aT.q.dim?l4..ya i.ge, kLoeigfdr..,,e¦b:.E Minimum Amomt Doe (1 10124 9a.- Apt. a Payment Dm Date Jammy 11, Zoos Ckf Totd eodoeed i I HamaPms AtmuPho. AomouNamber. 4862 36243397-3412 I? #9034710516826166# MAIL ID NUMBER Capital One Bank ¦a? TIM HARRIGAN P.O. Box 85147 IIIuIIInnnIIn1III o 13 BUTTERNUT LN r Richmond, VA 23276 m I? MECHANICSBURG PA 17050-7943 IIIIIInfill IIIfill OIIIIIIIIIIIIIIIIII111/11IIIIIIIIUIIIIIIII J%areturnery-rAmowam-bvwywa &MEerrImleyardCmadepajoWtoCagoddOaeAamiandm ilaIthemdawdeawJv a VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA. C.S. 4904 relating to unsworn falsifications to authorities, that he/she is?--_S-(? Z ` (NAME) authorized agent of Capital One Bank, plaintiff herein, that he/she is duly authorized to make this verification, and that the facts set forth in the foregoing Complaint are true and correct to the best of his/her knowledge, information and belief. WWR# 0 ? O O D O R? Co r. ? 1 4 c) r 1f C1 `G SHERIFF'S RETURN - NOT FOUND CASE NO: 2007-06963 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CAPITAL ONE BANK VS HARRIGAN TIM 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 HARRIGAN TIM but was unable to locate Him in his bailiwick .. ....rT w Tv?m r TT/lTT("?LHe therefore returns the NOT FOUND , as to the within named DEFENDANT 1'A RUTTERNUT LANE HARRIGAN TIM MF.ruANTC'SRURG. PA 17050 DPP MnTHRR. DEFENDANT MOVED OUT A YEAR AGO ANn HTS WHEREABOUTS ARE UNKNOWN Sheriff's Costs: So answers ?..-- Docketing 18.00 Service 10.00 Not Found 5.00 R. Th as Kline Surcharge 10.00 Sheriff of Cumberland County .00 ??a24/b 'v/ 4 3. 0 0 WELTMAN WE INBERG RE I S 05/27/2008 Sworn and Subscribed to before me this day of A.D. a IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. TIM HARRIGAN Defendant No. 07-6963 CIVIL TERM PRAECIPE TO REINSTATE COMPLAINT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: JAMES C WARMBRODT, ESQ. PA I.D. #42524 WELTMAN, WEINBERG & REIS, CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#6205129 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. Civil Action No. 07-6963 CIVIL TERM TIM HARRIGAN Defendant PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. WELTMAN, WEINBERG & REIS CO., L.P.A. By: JAMt;S L A BRODT, ESQ. PA I.D. # 2524 WELT AN, EINBERG & REIS CO., L.P.A. 1400 K pper Building 436 Se ent Avenue Pittsb , PA 15219 (412) 4-7955 WWR #6205129 lxr O THE Tt; .y 2 0 0 9 FIAy 14 Fri i i : k, 6 Cic P X100;3 Sheriffs Office of Cumberland County R Thomas Kline Qt CnubrjEdward L Schorpp Sheri Solicitor Ronny R Anderson Jody S Smith Chief Deputy OFFICE F TAE S4ER1FF Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 06/08/2009 06:21 PM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on June 8, 2009 at 1821 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Tim Harringan, by making known unto Michael Blume, adult in charge 1117 Bridge Street New Cumberland, Cumberland County, Pennsylvania 17050 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $58.60 SO ANSWERS, ram ice. June 09, 2009 R THOMAS KLINE, SHERIFF 2007-6963 Capital One Bank V Tim Harringan Fil FL-'.",i'F!,?F OF THE PPONHICNO TAPY 2009 JUN I I PM 2: 04 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA), NA Plaintiff VS. TIM HARR.IGAN Defendant No. 07-6963 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. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#06205129 Judgment Amount $ 1,756.48 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA), NA Plaintiff vs. Civil Action No. 07-6963 CIVIL TERM TIM HARRIGAN Defendant TO THE PROTHONOTARY: PRAECIPE FOR DEFAULT JUDGMENT Kindly enter Judgment against the Defendant, TIM HARRIGAN above named, in the default of an Answer, in the amount of $1,756.48 computed as follows: Amount claimed in Complaint $1,496.10 Interest from October 18, 2007 to August 18, 2009 at the legal interest rate of 12.90% per annum $260.38 TOTAL $1,756.48 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. Molczan, Esquire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#06205129 Plaintiffs address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 1400 Koppers Building, 436 7U' Avenue, Pittsburgh, PA 15219 And that the last known address of the Defendant is: 13 BUTTERNUT LN, MECHANICSBURG, PA 17050 IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA), NA Case no: 07-6963 CIVIL TERM Plaintiff vs TIM HARRIGAN NON-MILITARY AFFIDAVIT Defendant 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, TIM HARRIGAN 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, TIM HARRIGAN is not in the military service. Further Affiant sayeth naught. AFFIANT ti SWORN TO AND SUBSCRIBED in my presence this day of L4 NOT Y PUB COMMONWEALTH OF PENNSYLVAPJIA Notarial Seal Wayne A. Jones, Notary Public City of Ptitsburgh, Allegheny County My Commission Expires June 29, 2010 Member, Pennsylvania Ass, ation of Request for Military Status Department of Defense Manpower Data Center rips;. Military Status Report Pursuant to the Servicemembers Civil Relief Act Page 1 of 2 AUG-18-2009 10:35:53 '< Last Name First/Middle Begin Date Active Duty Status Service/Agency HARRIGAN TIM 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. y6t Fit 414_ A?? 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: httD://www.defenselink.mil/_faci/t)is/PC09SLDR.html WARNING: This certificate was provided based on a name and Social Security number (SSN) provided https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 8/18/2009 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. TIM HARRIGAN Case No. 07-6963 CIVIL TERM Defendant IMPORTANT NOTICE TO: TIM HARRIGAN 13 BUTTERNUT LN MECHANICSBURG, PA. 17 50 Date of 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 PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE 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. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA. 17013 (717) 249-3166 WELTMAN, WEINBERG & REIS CO., L.P.A B atthew Urban P.A.LD.# 90963 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 Seventh Avenue, 1400 Koppers Building Pittsburgh, PA 15219 Phone: (412) 434-7955 6205129 A PIT LXR 2009 SFP -2 PI 1. 59 *i4.m Po ATM 4a2 31 to 5 ?` a3oia? Okk?, U"d IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA), NA Plaintiff VS. Civil Action No. 07-6963 CIVIL TERM TIM HARRIGAN Defendant NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the following Order o Judgment was entered against you on q (xx) Assumpsit Judgment in the amount of $1,756.48 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 HONOTARY PUTY) TIM HARRIGAN 13 BUTTERNUT LN MECHANICSBURG, PA 17050 Plaintiffs address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 1400 Koppers Building, 436 7 h Avenue, Pittsburgh, PA 15219 1-888-434-0085