Loading...
HomeMy WebLinkAbout08-3931q IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA), NA Plaintiff No: 0P- 3 9 31 Ua 1q- vs COMPLAINT IN CIVIL ACTION DONNA RHOADS 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 1400 Pittsburgh, PA 15219 (412) 434-7955 FAX: 412-338-7130 06667877 C N Pit BLK IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA), NA Plaintiff VS. Civil Action No DONNA RHOADS 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 (USA), NA 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: DONNA RHOADS 1812 CARLISLE RD CAMP HILL, PA 17011 3. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXXXXXX6466 . 4. Defendant made use of said credit card and has a current balance due of $5143.26 , as of May 20, 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 29.200% per annum on the unpaid balance from May 20, 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 , DONNA RHOADS , INDIVIDUALLY , in the amount of $5143.26 with continuing interest thereon at the rate of 29.200% per annum from May 20, 2008 plus costs. J4)43 Warmbrodt,42524 WWEINBERG & REIS CO., L.P.A. 4th Avenue, Suite 1400 Ph, PA 15219 (-7955 F -338-7130 0C N Pit BLK This law firm is a debt collector att m ing to collect this debt for our client and any information obtain will be used for that purpose. 59riR7a 7.25% APR Call now for rates as low as Prime, currently 7.25% APR, and close your ban in 10 days or less! For a Home Equity Line of Credit, call 1-800-760-2493 Mon-Fri 8 a.m.-8 p.m. Sat 10 a.m.-1 p.m. ET or apply online at www.capitaloneharrMoans.com Preferred Customer Number. 7890 046 282 7143 Account S Previous Balance $2,845.13 Payments, Credits and Adjustments $2,845.13 Transactions $962.48 Finance Charges $28.37 Save money with one low rate Apply today for your Home Equity Line of Credit from Capital Ones and use your new low rate to pay off high-interest debt. • Rates as low as Prime, currently 7.25% APR* • Loan amounts up to $500,000 $0 closing cost options You can also take advantage of our other home loan products, including mortgages and refinancing offers. `Variable annual percentage rate as published in the "Money & Investing' section of The KWI Street Journal as of 01/30/06. Maximum APR is 18%. Capital One is an Equal Housing Lender. See reverse for additional important information. i? LENDER Home Loans PLATINUM MASTERCARD ACCOUNT 5178-0523-6285-6466 FEB 12 - MAR il, 2006 Page 1 of 2 Payments, Credits and Adjustments 1 25 FEB CAPITAL ONE ONLINE ACH PAYMENT $2,845.13- Transactions New Helena 2 27 FEB CIRCUIT CITY SS *3720 MECHANICSBURG PA Minimum Amount Due $990.85 3 11 MAR PAYMENT PROTECTION 1-SM527-6904 $29.00 Payment Due Date April 11, 2006 Total Credit Line $2,750 Total Available Credit $1,759.15 Credit Line for Cash $2,750 Available Credit for Cash $1,759.15 At your service To all Customer Rdatio. or to report a lost or stolen std: 1-800-903-3637 Send paymeto to: Send utguiua to: Attn: Remittance Prooneing Capital One Bank Capital One P.O. Box 790216 P.O. Box 30285 St Low., MO 63179-0216 SLC, UT 84130-0285 Important Account Information Please review the enclosed privacy information and retain it with your account records. Also visit www.capitalone.com/aeditcards and click on the Visit the Guide to Benefits fink to lean about your latest Visa. or MasterCard. account benefits. The descriptions in this online guide replace any information you received in the past. For a prtoted copy of the Guide to Benefits, call the Customer Relations number on the back ofyour card. ?rt $953.99 8.49 Finance Charges Pkmrree reammJidefor important information Rd- &, wdM Periodic c_%;1011 no" W& PURCHASES CASH 5799.76 $509.79 .07737%P 28.24% .Orn7%P 2$.24% $17.33 $11.04 ANNUAL PERCENTAGE RATE applied this period 28.24% PLEASE RETURN PORTION BELOW WITH PAYMENT 0000000 0 5178052362856466 11 0990852845130029007 New Balance $990.85 Minimum Amount Due $29 00 Payment Due Date April 11, 2006 Total enclosed $ ---1 Account Number. 5178-0523-6285-6466 P/e to war r rAl a., V- rmaitrl j. &/-rriPWH-xxrk imkk street Apt *.. City S" ZIP Home Phase Al- m.,.. #9007136419686486# MAIL ID NUMBER Capital One Bank i DONNA RHOADS P.O. Box 790216 ???unu??llnuul?? 1812 CARLISLE RD St. Louis, MO 63179-0216 n CAMP HILL PA 17011-5909 Plane writeyaw aaaumt number om yv check err money ordn modepayabk to CopitalOwitank and moil in the errdareAarnelopr. r 10-day claim calculated from receipt of completed application and all required supporting documentation. $0-closing-cost option not available with lowest rate and requires minimum loan amount of $80,000 with a $25,000 minimum draw size. Offer intended for qualified applicants only. Terms are subject to change without notice. Not all loan products or terms are available in all states. Actual loan terms are subject to qualification for income, credit and property. This is not a commitment to make a ban or a commitment to the :merest rate, points and fees for a loan. ® 2005 Capital One Services, inc. Capital One is a federally registered service mark. All rights reserved. ?s 0 1. How To Avert A FMnas harp. t a ve a rnnNnmen grace period of fad- o- are" 2b d P Rou m ? pedodle rate. To Obtain the average daily balance for the MNnO cowtod by INe stelemere we arks this your expnt If It Iw akady been dosed. for movnpb. If w idion fir ain c aYS balance transfers, new dlatYO purchases, now a dal a otlr be once of aced: segment ems day, add my new lraneectlar to s d you aWiMxed s ptrdwe from a merdrtt anal we mceive the treamesio t from the marchers after your te ow, Bd , In yOsa, [ofd 'New Bafo rce' h dssN? N eat Day b Importarit ? ec hd? a r ct, and subtract any gymans or credo. Of the codeNaappean M it. frcm of This atement neM to 'Balance Rate Applied To we also eccomt has been dosed, yon aaan Will be reopened, the amore of the Cho s r be added to vow wm n, d S for It be credited byyotr mcm statmwd dIang date. Here N na gnca period on cosh advare S -Y urpald trance charge krAdetln the bal. f i an 4w wq be reaper for payment. If more is a mrrrberaldp are for Warr Smoak the fes Yxl co"'I'M s end epetlel trarTen. h addition, tlhere b no grace pakq m erry trrheerftlah if you do not pay the total 'New o each seytrart) This gives r the daily badanc a of each aegnem.:men, we add rep all Noe daily balances for each , to be drrpad, te the aMens, pagaratcos secant halanw hoe been In n/ asdemned aMail the bove b A b eegnan for the bMing perlpd end dMde by the total mBnber of dap n the 6Niq pedod This gives r the . 7. Ua?a Year Aesant.yea card or accrual carrot be dI . Oww V smirg a Flmasft gram Oros. Transactions which are not gect to a graft ail ere aaeued Mauro dirge tl a doll balance of eadn sepmnent. 3. 4'W- Rreas IAPRI tae n mstol6n wkh any Incomes, gambling . fl the tr trRnrerion of tln Lrarnssetlorn or 21 from the date the pr t to ear Acmu l t a 3 ) from the . e. The term 'Asruel Percentage note- may appear u APIV m the flax of this stnemem 8. IletMs Abet Fisabaris harek Umws6n. Wirt yovs,u ==a deck payment, You O arttlndze r - either to of he ther y byd am (rp i outs you o e did not pay the -New Bolonce • . If the code P (Prime). L of b. R madort from ymhr eMdt to make a are-Wne f . y t h PP- * 1111, 11r cpxkars to to charges acers, earqupaM balance uxi the ulpald balance b poll In mil. Tlie rnterr that ark m ou ma su (Bankea rd Prime) appears t lerraiaBil u) on the from o M"11 to the the o rhea and ANNUAL PEACENTAOE RATER Prover t ps r desk transaction. When, w e olteck to retake an electronic ni VolW tare transfer my be withdraw f y w y rvey chronic., even If You PSY the Rwhs New Balance, hintlicated on k the irax of your outemott the e amass starrarment do itg data but rid ma v? Y ry gasrroriy may Increase or daxepe based on the stated Indices, as }and In The Wag Street l W , n rom yov bank aocnn a soon as des soma day" receive and you wi mat refehve Your check bac yourk from Payment, e , d . unpaid l not as, Prevdaa tnersh lhpaid firtace dr oss em added u ire apptcelis se maxof ar A . - , phi she mman DDrewawly dsdoasd to you. These WII be etbctlw an xe Ares, 4 of n your financial frrWntdort, g e fcours . t c. kAriresm Rtes 41rgs. Fb sadt Jk pedod that a r am t Fnia Vrea1A Y of $0 60 iNl NWg period covered bV your pedodc stateme t ending In the menthe Jaue7, Ayd July end Oelober. c. If the code D rydrre), F (i ono. IBOR) or O 43-mo. BILLING RKIFM SUMMARY (In Case of Enom Or Ouesdae Abaft Yam Big) 1 you drink Wv bill k vwa or If d sti. N . . w be I nt tie faced ° from poaaL ws?pgeae?r? your pedadc rat«ei M ratkMn itO 110 wM d t LIBOR Rapl LIBOR next to OM V) aPDee e? m from of ywca %dode the padude m* * 1 g, you ree mars, ntamsnm on e traractlm or bN, vv" to r on a separate fleet as socn as pwdbie of she Bd F- for , . o hied amours to tie MX" grthedtase reso mbhYmntn anal the dtTenaxe will be t d. Tamper eprnem of" Wv scant. ay Rerbtstlom bt finances ar W h and ANNUAL P61 may A OE AATEB wry ?may increase or decrease based on ft ceased irndcae, as found in TM Wag Sash Journal, pkm WgddsB Aeww on the front of this asammer. We must hater then 00 days after we tent you that === the art a problem appasred Yo d o il. e reserve t e right to rim now" MW m all flares Chem" fm raw given ale margin previously dsdased to you. These changes will be offend m the Amt day of your Ming period . u can can our Customer Relations mnbm, but doing . so vA not ar ca sse d I 2. e v il ?odeme I' ' - New PVdtasas to l. d each mantlL asrrw W Lail, OwriNt rd Ranrd Y 4. Ar Payerd Fast. p rvs Vex ghts. n Vote uttm, rive r the %NOV*V ??' ranter, the dolor amaurnt of the destaipgm of the area balRCS of eedh sep hem Of ear e account account (e.g., cash ice, pudrse, gwdA transfer and )pedal parader) ou aasasaad m more than two Of the fees r as h vtfil W :steal here tin scar during aM' biMno period. Under the te r ms f and as aplanedon, It pwal6le, of wwiAWy you believe there r as error, or If you reed more dnfamnlan, • description of q , cort!aPert3q dab/ p e moe(of that hra been Previously dscsssd u you. A At t the end of each clay d?r4q agreemad, tw firearm the deft te w o w ei a not Warr to seems customer any fires vdttwA odor retlficetion , %vftt r welvb our ri ht to h the hem yw are carte )bad. You do net Mw to pay any )man M grtesdm wlia vw Bro hr?astl?drnf , but you h th e the bh?rg period, we BPPW tle d"eiy pesbdc rate for esd? of ear Breaux to tl a wid WRrs "1111"M f d g g aseeae t e sane or similar at a or tune. are sW abfpafed to pay the Parts of you hIf that ere not In queadm. WkRe we a you gaatlm we c o e o u n sepnas. Then at the end of the Ming period, tw add up h 6. Yam Aaseurt. if. memtanlip tee appears m the from of this metemem you hew 30 ant repro YOU as dMnµam or u ectim B^?' to cacao LM t e newiu of tlteae elegy twlcrtbtiora to arrive n your add o periorc finance doge fm each sooner the , days from the date tiffs statement was named to you to a id h h mom you gktesdm. p . M Ae from each scipmem to w periodic fi vo pey g t e fee or to have such fee cradled to you If you cancel your eecan. oudng aria pedod you ma t,t Special Rd* for Credit GM Pactwee nance charge for ~ Y for each seOmem of wirer scooaxT rake the bednrag b , y continue to use YOUff account memberWp fee. To World d having to mpay ost the Your atxeuri you must If you haw a problem with the qusiNY of propmy, a alance for each sepnem and add RarWny new transactions Std aW fisnartce tinsrge cahalated m the preWaa , notify r by eMlirg ar Customer Relatlms Depenrmem and e w N B l ' I credit Mve salad n thatyon uhdn 1. rnt. = ta the minca m fN ha day's for thou segtnrrt. We than sAtractM1y peYtmrass Of erode Posed as of thart day that p ew V y? a erhe s n iW (esckrdng the membership bU per to the and of the 1N"y Dercd, N a Y Clos Y A p t w march m, you may haw the ddrt rot to pay the remaking e rN Y M h dw an the as e to that se(eters. This gives r that separate, daily bd aoeunt. ?• If you paid the Bsle A et . e ear erod. You can request to does yax by calling our Customer Relations 111man. You newt destroy Your cmdt cards) and is ? m pclae e, t pum more w t m was s s 460.- and ly when I e s roads it more then or Was your home esom m nc?o teVwn Yon preNaa stateroom in M (a If y- new. bAeme was xam a e credit amount), new trarscdora which post ro va r carcase or s e i l account seems decks, cancel all preemhodred billing, and caste uNsccauud. If you do not cancel = Within 100 malas Of Yam mYYg addlelL we otvsn or the merchMt, a If war muted you the = ? f p c a purchase wWnwte are rat added to de daily bahernces. We calosalate the be sv? wdMV balm?•dd? M 8" DreauOMtlzad argemma, we wW consider receipt of a dirge Yam audedzatlon to reopen your ?decasn. Additionally, your *occur" will rat be cosec property or seMCes, so prcbasas ere cavered regerdaas arnomt a loceaon of purchase.) fleece ramnmrber to Agra d1 oarespadahee, the days in the cwmnt thrones Bergs, Whirr wcycle. aepeT balance the you pay sal anaaxs you owe r Including: any sues you awaallftd finance charges, pock Pe ch 1' mesa eft oppJy to oouxwna. aareredx rod accaars d?iy periodic 1M nnnbm of days In the billing P°"°° u rounding on a daily bads, my be a vadRros between this col allight d d d h advance fees and ary other tees a iseased t your eccoun. You are responsible for these smouhe what er I Does eon apply 00 Mwtnes, -,C,.* Card occo me a e on n t e amour of finanee °Y gosessed. b If t ecode w N they appear on Voce acfaan at the time you reawst to close the acaart Of they are Incurred aWeprm to Ce 1M Ono npports Infomstlon privacy protection: see our eat www.caslulanwrurn. . appeeom the hex of cis etaummx -x1 to 'Balace Rote Applied To,' we mdtlply tle Your request to dose three account. This may M" In charges eppeadg myofr?coun a fteyou hew tdh CapNtl One le a b riy rag = leaves mark of Capital al Capor.0. All i1glrla reserved. 12003 ee of GpkA Orv OILALBAK nkwlyd :: Py you mall to as will bs created to ever aocant ea of tins 6ushwn day row receive It Provided 117 you saW the Dottan portlm of tlns LIatanatt arnd Wu clack pie ncalved °n ep° and 12) your pew odor pom n Sur p?ocaaslrq canes by 3 p.m. Ef 111 rem PT). Pbew apow eL least Aw I6) buAnsas days br pwtd dalvery Pbass da not caws ? r LI arry odtllnpm bcatlen a Ion epsdp ear ymmay nod be credteA es of 1M clay vw receive 1Mm. Qr buknoas deW ate MmdaY yroutdn gatsrday, e?hgnp hoAdeys. accossn for 1M ar ?oj tlPe?deck TM eudwdaagon apsles tPeNj drocb ??'v?edeend tw a decklN, you aWedxe r to make a arnatbne Aecuoric uahrfer dealt Ism you boric r te make a charge agehat your bank acoont urehg tM deck, a papR deft a salsa h?an. ? bifirng cycle even If amt by eaneana ails. Ii vw carol procass the uaraur, You autlerize 4 fem. -- VERIFICATION CAPITAL ONE BANK (LISA), N.A., successor-in-interest to Capital One Bank vs RHOADS, DONNA 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 (USA), N.A., successor-in-interest to 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. 1 TRAC YLOR -'? ?-I_ Notary Public SHARON REUBENS NOTARY SEAL MY ONEXP 1620il 5178052362856466 A049 WELTMAN, WEINBERG & REIS CO., L.P.A. z V\ •7-, f7^ 5L t. : J r n CASE NO: 2008-03931 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CAPITAL ONE BANK USA N A VS RHOADS DONNA WILLIAM CLINE , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon RHOADS DONNA the DEFENDANT , at 0010:32 HOURS, on the 12th day of July , 2008 at 1812 CARLISLE RD CAMP HILL, PA 17011 by handing to DANIELLE COULTER ADULT DAUGHTER 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 ,71j410P' C)- Sworn and Subscibed to before me this of So Answers: 18.00 14.00 i?? 00 10.00 R. 'Thomas Kline .00 42.00 07/14/2008 WELTMAN, WEINBERG & REIS By - 7 -. day Deputy Sheriff A. D. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff vs. DONNA RHOADS Defendant No.: 08-3931-CIVIL TERM PRAECIPE FOR DEFAULT JUDGMENT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: JAMES C. WARMBRODT, ESQUIRE PA I.D.442524 Weltman, Weinberg & Reis Co., L.P.A. 1400 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#6667877 Judgment Amount $ 5,447.23 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.: 08-3931-CIVIL TERM DONNA RHOADS Defendant PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter Judgment against the Defendant, DONNA RHOADS above named, in the default of an Answer, in the amount of $5,447.23 computed as follows: Amount claimed in Complaint $ 5,143.26 Interest from 05/20/08 to 8/29/08 at the legal interest rate of 29.20% per annum $303.97 TOTAL $5,447.23 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: ?- JAMES C. W R RODT, ESQUIRE PA I.D.#42 4 Weltman, einb rg & Reis Co., L.P.A. 1400 Ko ers BI g. 436 Sev th A nue Pittsbur , P 15219 (412) 4 955 WWR#6667877 Plaintiffs 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: 1812 CARLISLE RD CAMP HILL,PA 17011 IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff vs. DONNA RHOADS Defendant Case no:: 08-3931-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, DONNA RHOADS 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, DONNA RHOADS is not in the military service. Further Affiant sayeth naught. SWORN TO AND SUB in my presence this 22. day Notarial Seal Wayne A. Jones, Notary Public City Of Pittsburgh, Allegheny County My Commission Expires June 29, 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. j a IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff DONNA RHOADS Defendant(s) IMPORTANT NOTICE TO: DONNA RHOADS Date of Notice: /11. 1 1812 CARLISLE RD CAMP HILL,PA 17011 WWR#: 06667877 Case # a ' 3 f ? UNILI 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 C? -- `J IACAA&0-4 W000&-W<% -- 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 Military Status Report W Pursuant to the Servicemembers Civil Relief Act Page 1 of 2 AUG-29-2008 08:05:56 " Last Name First/Middle Begin Date I Active Duty Status Service/Agency RHOADS DONNA 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. 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://www.defenselink.mil/faq/pis/PC09SLDR.htm1 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 8/29/2008 # ? C t rl pi c N -n " -4 0 1 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff vs. Civil Action No.: 08-3931-CIVIL TERM DONNA RHOADS 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 (xx) Assumpsit Judgment in the amount of $5,447.23 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. PR ONOTARY (OR DEPUTY ?Q DONNA RHOADS 1812 CARLISLE RD CAMP HILL,PA 17011 Plaintiffs address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7t' Avenue, Pittsburgh, PA 15219 1-888-434-0085