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Home My WebLink About07-6980 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE NA Plaintiff vs. JEFFREY D KAUFFMAN CHARISE A KAUFFMAN Defendants No : jyr- (P78D Civil -(?,rw? 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 06179451 C N Pit LXR IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE NA Plaintiff vs. Civil Action No JEFFREY D KAUFFMAN CHARISE A KAUFFMAN Defendants 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 NA is a corporation with offices at 140 EAST SHORE DR GLEN ALLEN , VA 23059 . 2. Defendants are adult individual(s) residing at the address listed below: JEFFREY D KAUFFMAN 329 W PENN ST CARLISLE, PA 17013 CHARISE A KAUFFMAN 329 W PENN ST CARLISLE, PA 17013 3. Defendants applied for and received a credit card bearing the account number 7812602231451234 . 4. Defendants made use of said credit card and has a current balance due of $8751.60 , as of October 18, 2007 . 5. Defendants are 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 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, Defendants have willfully failed and/or refused to pay the balance due to Plaintiff. Wherefore, the Plaintiff prays for judgment in its favor and against Defendants , JEFFREY D KAUFFMAN AND CHARISE A KAUFFMAN , JOINTLY AND SEVERALLY , in the amount of $8751.60 with continuing interest thereon at the rate of 28.49016 per annum from October 18, 2007 plus costs. /AX: C. Warmbrodt,42524 WEINBERG & REIS CO., L.P.A. venth Avenue, Suite 2718 urgh, PA 15219 434-7955 412-338-7130 061 9451 C N Pit LXR This law firm is a debt collectort?mpting to collect this debt for our client and any information ob ed will be used for that purpose. Your account is temporarily suspended from OQ future charges and cash advances due to its past due status. ACCOUNT STATUS FOR: F JEFFREY D KAUFFMAN A good credit rating can help you get credit cards, a cell phone or even a job. We can help restore your charging privileges: • Use our free Check Phone service TSUSPE by by calling s-Boo-955-66oo. SUSPENDED DED • Call our friendly associates for payment options at the number above. • If you have online access, log on to your account and pay now at www.capitalone.com. • If you prefer, simply use the remittance coupon below. cawwom- what's in your wallet? The purpose of this letter is to collect a debt. Any information obtained will be used for that purpose. 0 2005 Capital One Services, Inc. Capital One is a fad®rally registered service mark. AN rights reserved. 042-Oeo5 ,o• Loan Payment information TOTAL NEW BALANCE $6,307.97 AMOUNT DUE $6,307.97 PAYMENT DUE DATE jum 19, 2006 Scud m Proo?B sma m`H'°° to Attw Ra Gp+? O•e, RS.B. e P.O. Cap?f O3n6 13.x 790217 p,(j, g. St Louis, MO 63179-0217 SLC, UT 841311-0285 Atyvtusmvke To all Cwtoaoa Rdaiow 1-800-9SS-2115 PERSONAL LOAN ACCOUNT 781260-2231451234 APR 24 - MAY 23, 2006 Page 1 of 1 Payments and Adjustments Other ChatRes 1 26 APR PAST DUE FEE $29.00 EXHIBIT 2?5 a N N PLEASE RETURN PORTION BELOW WITH PAYMENT 0W. 0000000 7 7812602231451234 23 6307970320766307974 Total New Balance 97 Minimum Amount Dne $6,30797 Payment Due Date June 19, 2006 Total endoeed $ Account Number. 781260-2231451234 Prrsxp.:rtvlnx dr4a..VR--cLi"a Apt # -.7 S" ZIP Home phone Alcemte Phone #90144567101107000 MAIL ID NUMBER a JEFFREY D KAUFFMAN Capital One, F.S.B CNARISE A KAUFFMAN P.O. Box 105087 329 W PENN ST ?1e1?1e1r???rrr???rtt? Atlanta, GA 30348-5087 NNNNNNNN CARLISLE PA 17013-2249 Plaare -eymff amount nuonberonyav cb=k or money order nadepwya6leto C3pd.10ne, RSB. and nail in t& enck aem.&Of r I VERIFICATION CAPITAL ONE NA vs KAUFFMAN, JEFFREY D 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 NA, 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. Y TAYL Notary Public 7812602231451234 A049 WELTMAN, WEINBERG & REIS CO., L.P.A. L -O 0 C rv ? t't r, z 00 r N SHERIFF'S RETURN - REGULAR f? CASE NO: 2007-06980 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CAPITAL ONE NA VS KAUFFMAN JEFFREY D ET AL SHAWN HARRISON Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon KAUFFMAN JEFFREY D the DEFENDANT , at 1944:00 HOURS, on the 3rd day of December-, 2007 at 329 W PENN STREET CARLISLE, PA 17013 CHARISE A KAUFFMAN. WIFE by handing to a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 4.80 Affidavit .00 Surcharge 10.00 ? Sworn and Subscibed to before me this day of , .oo 32.80 So Answers: R. Thomas Kline 12/04/2007 WELTMAN WEINBERG REIS By: X-V u,keputy Sheriff A.D. SHERIFF'S RETURN - REGULAR f' CASE NO: 2007-06980 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CAPITAL ONE NA VS KAUFFMAN JEFFREY D ET AL SHAWN HARRISON Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon KAUFFMAN CHARISE A the DEFENDANT , at 1944:00 HOURS, on the 3rd day of December-, 2007 at 329 W PENN STREET CARLISLE, PA 17013 by handing to CHARISE HAUFFMAN 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: So Answers: Docketing Service 6.00 .00 r Affidavit 00 Surcharge 10.00 R. Thomas Kline /a? .00 ? 16.00 12/04/2007 WELTMAN WEINBER IS Sworn and Subscibed to By: before me this day D puty Sheriff of , A. D. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. JEFFREY D KAUFFMAN CHARISE A KAUFFMAN Defendant No. 07-6980-CIVIL TERM 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 WWR#6179451 Judgment Amount $ 9,619.14 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. 07-6980-CIVIL TERM JEFFREY D KAUFFMAN Defendant PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter Judgment against the Defendant, JEFFREY D KAUFFMAN above named, in the default of an Answer, in the amount of $9,619.14 computed as follows: Amount claimed in Complaint $8751.60 Interest from 10/18/07 to 2/22/08 at the legal interest rate of 28.49% per annum $867.54 TOTAL $9,619.14 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: i i James C. War brodt, 2 Weltn erg & Reis Co.,L.P.A. 436 venue, Suite 1400 P.A.I/4-7!?h5 Pittsb15219 (412)Fax: -7130 179451 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: 329 W PENN ST CARLISLE,PA 17013 w IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. JEFFREY D KAUFFMAN Defendant Case no: 07-6980-CIVIL TERM 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, JEFFREY D KAUFFMAN 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, JEFFREY D KAUFFMAN is not in the military service. Further Affiant sayeth naught. SWORN TO AND SUB BED in my presence this day of 1-P,rlYl AnktJ X-71;QfYT Y 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. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE NA Plaintiff Case # (3-7-(o966 CM i L rc- R M JEFFREY D KAUFFMAN Defendant (s) IMPORTANT NOTICE TO: JEFFREY D KAUFFMAN 329 W PENN ST CARLISLE,PA 17013 Date of Notice: 1- ez: l O? WWR#: 06179451 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 : 1'oi U?x x- ?,(Uw?wJ (b60e)Wi4-- PATRICK THOMAS WOODMAN PA I.D. #34507 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 KOPPERS BLDG, 436 7TH AVE. PITTSBURGH, PA 15219 Request for Military Status Department of Defense Manpower Data Center 40 Military Status Report Pursuant to the Servicemembers Civil Relief Act Page 1 of 1 OCT-26-2007 13:45:01 " Last Name First/Middle Begin Date Active Duty Status Service/Agency KAUFFMAN JEFFREY 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. Auk lot V44494, 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: htW://www.defenselink mil/faq/pis/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: BBSLMCGKGZS https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 10/26/2007 r?a 4 '1R` C70 -O .G r-- -- ? CJ rrt zz ;- -- i c? -c A110..506 t7 - I N OV 05 2007 ^- L ' M IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff VS. Civil Action No. 07-6980-CIVIL TERM JEFFREY D KAUFFMAN Defendant NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the following Order or Jud ment was entered against you on /O 0 (xx) Assumpsit Judgment in the amount of $9,619.14 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: PROTHO OTARY EP Y) JEFFREY D KAUFFMAN 329 W PENN ST CARLISLE,PA 17013 CHARISE A KAUFFMAN 329 W PENN ST CARLISLE,PA 17013 Plaintiffs address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building; 436 7`b Avenue, Pittsburgh, PA 15219 1-888-434-0085