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HomeMy WebLinkAbout08-3928IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (US A), N Plaintiff VS. ADAM M GORDON Defendant No : O -F- 3 9.2.? Cio-.P -r.- 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 1400 Pittsburgh, PA 15219 (412) 434-7955 FAX: 412-338-7130 06648717 C N Pit SMI IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (US A), N Plaintiff vs. Civil Action No ADAM M GORDON 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 (US A), N is a corporation with offices at 15000 CAPITAL ONE DRIVE RICHMOND , VA 23238 . 2. Defendant is adult individual(s) residing at the address listed below: ADAM M GORDON 111 MAPLE DR MECHANICSBURG, PA 17050 3. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXXXXXX6164 . 4. Defendant made use of said credit card and has a current balance due of $3257.64 , as of April 30, 2008 . 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 27.600% per annum on the unpaid balance from April 30, 2008 . 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 , ADAM M GORDON , INDIVIDUALLY , in the amount of $3257.64 with continuing interest thereon at the rate of 27.600 per annum from April 30, 2008 plus costs. James C. Wa rodt,42524 WELTMAN, WEIN ERG & REIS CO., L.P.A. 436 Sev nth A enue, Suite 1400 Pittsb gh, 15219 (412) 34-7 5 FAX: 2-3 -7130 06648 17 N Pit SMI This law firm is a debt collector attempt Mg to collect this debt for our client and any information obtained will be used for that purpose. GW NOT PAYING YOUR DEBT SOM13 what's in your wallet?' DOESN'T MAKE IT GO AWAY. In fact, even if we report your account as charged off, you'll still be responsible for paying your debt. So why not call us to see what we can do together to keep you from receiving such a serious mark on your credit record? We're here to help. Please contact us to find a solution that's right for you. You can make a payment with our ig check by phone service or speak to an associate by calling 1.800.955.6600. Make sure you call or pay the amount due on your statement within 30 to keep your account from being dharged off. ® 2006 Capital One gervicer, Inc. Capital One u a federally rgAtered service mark. ALI rights reserved 500013-08503 FINANCE Previous Balance Payments 6 Credits CHARGE Transactions New Balance Minimum Payment Due Dab $2,619.83 - $0.00 + $65.67 + $39.00 = $2,724.50 $724.50 Oct. 05, 2007 Aug. 10, 2007 - Sep. 10, 2007 Page 1 of 1 e nMA'e 041 AT L;W THS AMIWNT Visa Platinum Account 1662-M-ODa3.6164 Your Account Information TOTAL CREDIT LINE $2,000.00 TOTAL AVAILABLE CREDIT $0.00 CREDIT LINE FOR CASH $2,000.00 AVAILABLE CREDIT FOR CASH $0.00 Finance Charges (Passe see reverse for important iniormatbn) aB ppl two rate APRi? CF HARGEE Purchases $2,661.16 0.07712% D 26.15% $85.67 Cash $0.00 0.07712% D 26.15% $0.00 ANNUAL PERCENTAGE RATE applisd this period: 28.15% ® At Your Service 1•/00,003.3837 To exit Custorw Re.Sdm ortD neat a lost orsi*n card: ® bend Wyk to: Capital One Bark • P.O. Box 70884 • Chenille, NC 28272.0984 Your account is six payments behind. ff we charge off your account due to late payments, we will report the chargedotf status to several national credit bureaus, and the Purchase APR as reflected on this statement vnll be applied to all your outstanding belances. Ad now to prevent this from happening. Pease pay the amount due on your statement or give us a call at 1.800.955.6600. Well work with you so you can take control of your account and start rebuilding your credit with Capital One. "Important Notice" Under the tams we previously disclosed to you, your account is now eligible for an increase in Annual Perceritage Rates (APRs) effective immediately. However, Capital One has elected not to raise your APRs at this time. Plceae be advised that If you fail to keep your account in good standing, Capital One reserves the right to raise your APRs In ft future. Payments. Credits & Adlustmernts Transactions 1 03 SEP PAST DUE FEE $39.00 ® Saint! Inquiries to: You were assessed a past due fee because your minimum payment was not received by the due date. To avoid Capita One • P.O. Box 30285 • Sao Lake City, UT 84130-0285 this fee in the future, we recommend that you allow at least 7 business days for your minimum payment to reach ® Have a question about a charge on your statement? Capital One. PIS refer the Billing Rights Summary on the bads of evu Bff your statement or visit www 6056 506 1 07 9 070910 PAGE 1 of 1 01DM6056 PLEASE RETURN PORTION BELOW WITH PAYMENT OR LOG ONTO WWW.CAPITALONE.COM TO MAKE YOUR PAYMENT ONLINE 0 4862362200836164 09 2724500165000724505 CW1WC 'I wharsinyour wallet?' New Balance Minimum Payment Due Date $2,724.50 $724.50 Oct. 05, 2007 PLEASE PAY AT LEAST THIS AMOUNT Amount Enclosed Capital One Bank P•9. Bex 70664 Irlrrlrrlrllrrrllrrlrl Charlotte, NC 26272-0664 L11dIrrLrdtlladnldlLnLILLJnLdlrrLdrdLtdl Account Number: 4862-3622-0083-6164 Please print address or phone number changes below using blue or black ink. Address Home Phone A/temate Phone E-mail address @ #9025480373112206# MAIL ID NUMBER ADAM M GORDOH 131 MAPLE DR MECHANICSBURG, PA 17050-2765 urlllnrllluulrlrlluurlrllutlrllnrlrluullurllrlrlr Please write your account number on your check or money order made payable to Capital One Bank and mail with this coupon in the enclosed envelope. ADAM M GORDON 1. Him to Mai a Flounce CharBa. t it Grace Parked YMw11 hm • minimum grace pebd 0125 dap without Muse clwga on maw Puehases, new balancers- MoU, morn epwW p dr aed aw adw ctharges ryou psyycur bW'Naw Balances, In accordance with Ale Important Nonce for payments below, and In lbws for it to be credited by your payment de daft. Then Is ro grate Period on Gosh adwancew and specs banafsm, In sedlkn, thra IN no, pace Period on cry banrdkn If you do not Pay the tM "New I ,=.. b. Accruing Fbana ChWO. Tmn"cd" ~ re not harp IM dgW Btu Mtllm a 2)) ftm to ddWthe me1) Ummo ion is Mosstd to your Amount -S) hen to first celerdar day of to c mart blip perked. AddltlmYy, ayou did not pay the New SwkmW Mom die privielous billing period in ful, Mama dhergea cor& a to tome b your unpaid balance will tte unpaid balance is pad at full. This means that you may CB owe Once chahga, even M You pay the snake New Balance Indicated 0111210 from of your statement by to psynsd de duo, but did cad do so for to pravlous mane. Unpaid mtemba dergas sm added to to applicable mgrent of your Accourt t c. M' -, Forma Chhwga. Fm tech bUV Pwiad that ywr amount Y&Aod lea Scarce rdualik a minimum loW FINANCE CHARGE of SMSO will be Impeded. t t Term vary Reduadw in Rlnraw Chwga We reserve the right to not s ssm any mat finance charges for any ghen billing parked. 2. Ausomp Defy Balanm Oncludro Now Pwduaa4 Finance dupe is calculated by rdlPi ft if* daily balance of each egpemt of your mcoud (a.p., cash advrno, phrcham, special trrsides , arc apace pudwe) by to mnaprdihf day prkdio nla(e) that has been pmVAudy disdaeed to you. At du and of sadh day define tie billing per W, we apply ihs daily periodic rate for each mg main of your amount to the daily balance of each aag,mat Then at tie and rite brae prod. we add up to results of tags day uuloulasons to ard" at your periodic fence Berge breech segem. vye add up the nab from erh agmsnt b *dW at *M but pwlmk i nerre dope for youracceunt Togslhedasybe, forark argnared youraoooud, w asks to bsgkrAv balance for .on segment and add any caw i aaasc lyons and any prlofo Onam chrge calculated an the prmlan days batence fur tW esiyhsen Watrdm aubbwl ary paymaras r crafts posted r offset day that ara allocated b tat segment. This unis as M espalheh daily balance fr each "Ormint of your amount Norther, t you pad to Now Balance ehovn on your Prswnw stows t In fur (r tyour new, bbalance wes cave r s acct "mum), mew hrradbe, which pod to your pumlua -special pumdwa segments era not added to tM daily balances. we comma ft average dally balance by addip M the dally balances bgstw and dlwdng to gum by the sober of the asp In the arrant bllbg cycle. To caladW your toW finerrs damge, MUMPIY the number of cap in tat ararnp parlor. Date to roedap on ¦ day bass or de to IN & m mellm! Berge saeasnent then may be a vriance between lift calculation and the amount of Anrroe tlhrpe acaWty amaed. 3. Annual ft, Rifts 901111G a. The farm •Anrud PecrMepe Rata' may appear -"APR* on to loom of this aftwnwC b. It the code P (Quarterly Prime). I. i0sarWy LIBORL C (Ouarlady CDC r 8 (Bankcard Poke) alpars on to front of the statement ed b to periodic mic(a), the periodic rates and mhrasparldrp ANNUAL PERCENTAGE RATES may vary quarterly and maytrmaeeee. devaae based m to stated indices, a Imrd lo The Vital Seat Journal, pis the mwgin prowousy diWosed to you. These dwVw will be stedhe on to Aa dry dyer lofty perked cowered by YON pelofc seormwM ending In to months of January, Apo, July OW October. c 11 Ow code D (Monthly Prime), F (Manihly LOORI or a (Treasury LIBOR) appears m to ham of your satrmern mend to the periodic rate(s), ft periodic ram aid cannpakctp ANNUAL PERCENTAGE RATES may vary man" and may iawam or decrease based on ere salad Indices, as farad In The Was SOW Job", plus OW mmgn previously disclosed to you. Thus cherigiber will be effective m ft firs day of yam blip period aril !!T!. Rabured Payhnam 4. A"nagmt of Lafe, OMOM and Fees. Under the ftma of your cuatonhar speanwnl. w• mar" the mye to vista or not to ammo eery Ism without prior modkedwto you without welwrlgourf ht to answers me saner sinbrbaate btarenhe. t 5. Rasa I yiser Ai mat. #a membrift fee spears on the from of your statement you him 30 drys horn to don Ands eWenem was mailed to you to mold PO*V to fee or to him such fee credited b you if you canoe your mcioum without left to pay the rawbo *fee. To anlod your amass you mud nobly us by calling our Customer Relations Department and pay your Tow Bstahae In full (excluding the membership fm) lam b to and of do Odryday, grind. S. N Vsu Close Vow Amount You can request b does your amount by calling our Cusoomer Relations Department Vou must decoy yourcrsdllcerd(a)and smontares,' I . antral as pmeMadad biro and omen using your mecum. After your repast to doe, N you continue to esrhaad m do not cancel presutlhortned bWAV arrangements. we will consider recalls of a charge your emadssm to Map ym amount open. Additionally your amount will not be dosed until you pay as amours you over us including; my transactions you have suthortsed, mama charges. post due fess, owreme far, reared payment Now, own advance lgee and any o0w bar mounted to your account You are respaebk for drove emoums W WIw #W appear m your amass at the tms you request to dose the account or VW sea Inca red subsequent to your request to dose the scorn m. The may neat In degas gpF, I m youracccum after yu hm requested to account to be dosed. 7. Uatrp Yaw AomaL Your card or account cemot be used in mraucUm aft my Internet gKnb*q transactions. S. Alaska About EMO&Ook Check Convuskm Man you p c 11, a deck as payment, you auW"tm w either to use InMmation from your lack to a" a ong-woe electronic find transfer from your bank amount or to protein the payment as a duck ermmdlm. Wh n we use blormation from your tlrrk to make an elecknink, fund trrWaf, Oun s may be wMdrmm bum your bank amount as som as the acne day we race" yo-payws, a d you cull not mic" yaw o n& back from your feaelal Imtbmtlm. BILLING RIGHTS SUNINIARY (In Can of Ends or Questions about Your Bill) If you think your hill is aemmI m it you need mom hlMiretom on a karoaWm r bib, write, to coo on a separate sheet as seen a possible at do address for impriast shown on the from of this verteen. % mat how limn you no Law Ow 60 drys after, we sent you the and bill an which the over m pr.Mm approved. You can aN our Customer Relations number, but dory ee wit not per-Your %his. In your W-. ghee a to lolrwme inbmedon: your cancan ant amount number, the dollar amount of to suspected aim, a description of the am and an eptaratlen, If parallels, of why you hello" them is an error, or It you need more Information, a description of the Item you an unsure, about You da nut lint to pay any amount in question who we are Investigating it, but you are ell obligated to pay the parts of your bill that me not In quietism. While we Inwisdgate, your gmkrbm. we G riot vepm you as delinquent or Was any action to Collet Ow amount you question. t. t Special RA for Croft Card Purchases I you law a problem with to Quality of PMP" r SOMM that you purcare0 with a ondd card and you have eied in good faith to omad the problem wlh the rnarcaant you may baw the rWA not to pay the remaining anon de m the property or sm ilms. Ybu him de price dbn only when the purdhaes price was more than SM.00 and fit* purchase was mrda In your home stele m wiWn 100 rnttas of your maslog address. of we own or operate tla.,WCO M -taw mead you tog adverbamat for the property or services, ON puclu a sm covered rprdba of amount or location of pudma.) PNaas remember to sign all correspondence. t Does not apply b consumer rion-credif card accounts t Dar rotapPfyfa Webass non mill cod amounts Capital One suppoft imomston p0racy protection: we our wbbalie r7M .Q. Capital One Is a federally regislaed service mark of Capital One Financial Corporation. AN rights reserved. 02006 Capital Cne TC-06 VlVn16Um • 1 • U1/IUNI krpeen Nease: PsI se ymalbwWbeaedWbyamscantrdtaiWMrdryscassia Itpnrdad(1)ymsaldto beam plasm awe sWwnantad yaw d¦dk In the andaed enrttr emwkn end R) youpeyuM Y Need h ter tomb, by3pro.ET(12air PT).plowdm tMsiAa(S)6nnI dayslrposialdrMmy.Peyrrb ertrasbyrsngalhrbatlahah a y dhwfam my rt b adnd r dte drys leek! ten. Ourb tiros, drys tee flmdey tam O Sgbdgy, adtte hcldga. Pbr donotwebptrs,pPrdpe,alc WMnp WP m yourpeynl.K VERIFICATION CAPITAL ONE BANK (USA), N.A. vs GORDON, ADAM M 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, TRACY TAYLOR, Authorized Agent, of CAPITAL ONE BANK (USA), N.A., 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 I,O Uvonda S. Brooks Notary Public Douglas County, Georgia My Commission Expires February 29, 2012 4862362200836164 A049 WELTMAN, WEINBERG & REIS CO., L.P.A. ? r~= Sri .. FTI Q -C SHERIFF'S RETURN - REGULAR CASE NO: 2008-03928 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CAPITAL ONE BANK USA N VS GORDON ADAM M TIMOTHY REITZ , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon GORDON ADAM M the DEFENDANT , at 0020:23 HOURS, on the 10th day of July , 2008 at 111 MAPLE DR MECHANICSBURG, PA 17050 7-1 nATAT TT fl nn TlnAT by handing to WIFE OF DEFENDANT a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge -71146y 4 18.00 10.00 .00 10.00 .00 38.00 Sworn and Subscibed to before me this day So Answers: R. Thomas Kline 07/14/2008 WELTMAN, WEINBERG & REIS By. De uty She ff of A. D. v IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA), NA Plaintiff vs. ADAM M GORDON Defendant No. 08-3928 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#06648717 Judgment Amount $ 3,502.80 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 (USA), NA Plaintiff vs. Civil Action No. 08-3928 CIVIL TERM ADAM M GORDON Defendant TO THE PROTHONOTARY: PRAECIPE FOR DEFAULT JUDGMENT Kindly enter Judgment against the Defendant, ADAM M GORDON above named, in the default of an Answer, in the amount of $3,502.80 computed as follows: Amount claimed in Complaint $3,257.64 Interest from April 30, 2008 to August 27, 2008 at the legal interest rate of 27.60% per annum $245.16 TOTAL $3,502.80 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, Esgr PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#06648717 Plaintiff's address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 1400 Koppers Building, 436 7`? Avenue, Pittsburgh, PA 15219 And that the last known address of the Defendant is: 111 MAPLE DR, MECHANICSBURG, PA 17050 IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA), NA Case no: 08-3928 CIVIL TERM Plaintiff vs. ADAM M GORDON 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. Affant 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. Affant further states that based upon investigation it is the affiant's belief that the Defendant, ADAM M GORDON 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, ADAM M GORDON is not in the military service. Further Affiant sayeth naught. SWORN TO of A W NOT AFFIANT D in my presence this day IN, COMMONWEALTH OF PENS ANIA Notarial Seal Wendy L. Gault, Notary Publ'?c City of Pittsburgh, Allegheny County My Commission Expires July 15, 2010 Member, Pennsylvania Association of Notaries This law firm is a debt collector attempting to collect this debt for our client and any information obtained will be used for that purpose. 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 MAY-16-2008 14:40:52 < Last Name First/Middle Begin Date I Active Duty Status Service/Agency GORDON ADAM 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 4124k Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The Department of Defense strongly supports the enforcement of the Servicemembers Civil Relief Act [50 USCS Appx. §§ 501 et seq] (SCRA) (formerly the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's active duty status by contacting that person's Military Service via the "defenselink.mil" URL provided below. If you have evidence the person is on active-duty and you fail to obtain this additional Military Service verification, provisions of the SCRA may be invoked against you. If you obtain further information about the person ( e.g., an SSN, improved accuracy of DOB, a middle name), you can submit your request again at this Web site and we will provide a new certificate for that query. This response reflects current active duty status only. For historical information, please contact the Military Service SCRA points-of-contact. See: http;//w-Aw.defens.e...link.mil/faa/pis/PC09.5......L.....D....R_..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:PRMZZJQCEX https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 5/16/2008 4 ' IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (US A), N Plaintiff ADAM M GORDON Defendant(s) IMPORTANT NOTICE TO: ADAM M GORDON 111 MAPLE DR MECHANICSBURG,PA 17050 Date of Notice: oe5 Qw-p WWR##: 06648717 Case # C9 - ??c-g 0jv I L 1 evy 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....AGAINS.T.....YOU.....WITHO.UT.... 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 (`O ?I ?iJC` ?Cl1Mf? U? dp +?"v? vLv"' BY: PATRICK THOMAS WOODMAN PA I.D. ##34507 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 KOPPERS BLDG, 436 7TH AVE. PITTSBURGH, PA 15219 `_ TTL"" G"'-? '? ,r? O? ?,,, ? 4? a° .Q ??,'- ? ? b ?? tT't = '? ` .D ? ? Y] C>.3 ::1 .?: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA), NA Plaintiff vs. Civil Action No. 08-3928 CIVIL TERM ADAM M GORDON 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 9090 (xx) Assumpsit Judgment in the amount of $3,502.80 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 HONOTAR UTY) ADAM M GORDON 111 MAPLE DR 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 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 08-3928 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CAPITAL ONE BANK (USA), N Plaintiff (s) From ADAM M. GORDON, 111 MAPLE DRIVE, MECHANICSBURG, PA 17050 (1) You are directed to levy upon the property of the defendant (s)and to sell (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: SOVEREIGN BANK, 17 W. HIGH STREET, CARLISLE, PA 17013 and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due$3502.08 Interest $620.13 Atty's Comm % Arty Paid $157.50 Plaintiff Paid Date: September 1, 2011 (Seal) L.L.$.50 Due Prothy $2.00 Other Costs David D. Buell, Prothonotary Deputy REQUESTING PARTY: Name WILLIAM T. MOLCZAN, ESQ. Address: WELTMAN, WEINBERG & REIS CO., L.P.A., 1400 KOPPERS BUILDING, 436 SEVENTH AVENUE, PITTSBURGH, PA 15219 Attorney for: PLAINTIFF Telephone: 412-434-7955 Supreme Court ID No. 47437 FILED-OFFICE OFF THE PROTHONOTARY "D I 1 SEP -1 AM 11:51 CUMBERLAND COUNTY PENNSYLVANIA IN THE Ci?I r%: T OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK WS A), N '11Jntiff vs. ADAM 'vl GORDC' Defendant(s) 1I af)G IIB /1, Mech?3nlcSb?Q?Ptdarn, •hee(s) ? r, t+yk S=r. C,.rf;sIe / ?'A- 1,013 No. 08-3928 CIVIL TERM PRAECIPE FOR WRIT OF EXECUTION (BANK ATTACHMENT ONLY) 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 d- al? 01005 It-it: 4? l o9 ? F t 1 5b 0051-,5 s•?y?p N ?, 43?U?1 N r'? J d n A.. 2,?/ `C ul?r sj- p L' ;u- L 6v. WWR No. 6648717 f.Sb D+,c LL IN THE COUK OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BAI?K (!_,S A), N Plaintiff vs. Civil Action No. 08-3928 CIVIL TERM ADAM M GORDO,4 Defendant(s) SOVEREIGN ; BANK Gani ishee(s) PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONi,•T/v.RY: Kindly issue a Vv rit of Execution in the above matter... 1. direr%A to the Sheriff of CUMBERLAND County: aga,nst .DAM M GORDON , Defendant ?. aga„-st SGVEREIGN BANK... Garnishee 4. Judgment Amount $ $3,502.08 Le,.s Payments/credits received $ $0.00 Intr. rest $ $620.13 Cwts $ SUb OTAL: $ $4,122.21 Cost:: (to !)e added by Prothonotary): $ WELTMAN, WEINBERG & REIS CO., L.P.A. By: William T. Molcza , squire PA I.D. 447437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR No. 6648717 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor Capital One Bank (U.S.A.) N.A. vs. Adam Gordon wQ?t?41r 01 ti:111nt,r;?f?r1? SE/" Qr?? aA I2 Ppf 03 CU c8L .4 #V0 r r . PEA(WS CVANIA Case Number 2008-3928 SHERIFF'S RETURN OF SERVICE 09/09/2011 09:41 AM - Amanda Cobaugh, Deputy, who being duly sworn according to law, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands, possession, or control of the within named garnishee, 17 W High Street, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to DENISE BEECHER, CUSTOMER SERVICE REP, personally three true and attested copies of the Writ of Execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on August 12, 2011 to Adam Gordon at 111 Maple Drive, Mechanicsburg, PA 17050. SHERIFF COST: $155.54 September 09, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF rJl ?, 7 ' Amanda Coba ugh ,.cj ^.C:; r;t(. (e?iE?C50?i. ?I i::. SHERIFF'S OFFICE OF CUMBERLAND COUNTY R Anderson off ,ody S Smith Chief Deputy Richard W Stewart Solicitor ???at?• o'. .?iutGF??a ? THE PPP HM- J I , 2012 MAR 22 AM 10: 415 PENNSYLVANIA Capital One Bank (U.S.A.) N.A. vs. Adam Gordon Case Number 2008-3928 SHERIFF'S RETURN OF SERVICE 09/09/2011 09:41 AM - Amanda Cobaugh, Deputy, who being duly sworn according to law, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands, possession, or control of the within named garnishee, 17 W High Street, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to DENISE BEECHER, CUSTOMER SERVICE REP, personally three true and attested copies of the Writ of Execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on August 12, 2011 to Adam Gordon at 111 Maple Drive, Mechanicsburg, PA 17050. 03/21/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is returned as ABANDONED. No action on writ in over 6 months. SHERIFF COST: $87.67 March 21, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF a %r„ C'w-.t;Suife Snentf. 7ele ;soft. Inc.