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Home My WebLink About08-3936a c IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff No. OB- SUG aivi I 1ex*% VS. COMPLAII T IN CIVIL ACTION DEBORAH K TRAYLOR Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: Matthew D. Urban, Esquire PA I.D. #90'?63 WELTMAN, WEINBERG & RE IS CO., L.P.A. 1400 Koppe; s Building 436 Seventh Avenue Pittsburgh, CA 15219 (412) 434-T55 WWR#065C3555 V IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff VS. Civil Action No. DEBORAH K TRAYLOR Defendant COMPLAINT IN CIVIL ACTION AND N')TICE 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 ar:d 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 LAIYYER 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 CUMBERLAND COUN T Y LAWYER REFERRAL SER ',TICE CUMBERLAND COUNTY BAR A"' SOCIATION 32 SOUTH BEDFORD STI'..'?ET CARLISLE, PA 1701'' (717) 249-3166 COMPLAINT V 1. Plaintiff is a corporation with offices at 15000 Ck PITAL ONE DRIVE RICHMOND, VA 23238. 2. Defendant, DEBORAH K TRAYLOR , is an adz;lt individual with a last known address of 25 N QUEEN ST SHIPPENSBURG,PA 17257. 3. Defendant applied for and received a credit cart; issued by Plaintiff bearing the account number XXXXXXXXXXXX3589. 4. Defendant made use of said credit card and h?.s a current balance due and owing to Plaintiff, as of June 19, 2008, in the amount of $ 1,872.72 . A true and correct copy of Plaintiff's Statement of Account is attached hereto, marked as Exhibit "1" and made a part hereof. 5. Defendant is in default of the terms of the cardhol ler Agreement having not made monthly payments to Plaintiff thereby rendering the entire balance immediately due and payable. b. Plaintiff avers that the Cardholder Agreement between the parties provides the Plaintiff is entitled to the addition of finance charges at the rate of 2590% p,-r annum on the unpaid balance. ?. Although repeatedly requested to do so by Plaint ff, Defendant has willfully failed and/or refused to pay the principal balance, finance charges or any part ''iereof to Plaintiff. WHEREFORE, Plaintiff prays for judgment in its avc - and against Defendant, DEBORAH K iRAYLOR , in the amount of $ 1,872.72 with continuing ir.,erest thereon at the rate of 25.90% per annum from June 19, 2008 plus costs. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED SHALL BE USED FOR THAT PURPOSE. WEL MAN, WEINBERG & REIS, CO., L.P.A. a hew D..irban, Esquire PA I.D. #90963 WELTMAN . WEINBERG & REIS CO., L.P.A. 1400 Koppev s Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7555 WWR#:065x'8555 t J - zron = n oro 3 w -ak~ pm N Jib w 7R` - N 050641 1111111111 U]Nq bx?O oo proppp p C X bi 4?7 N '.yd J Y O Yy?? N J ? N N ?n a J r a F+ C r = x iu I O O 0 0 0 0 O r W 00 OD Cl. r N O W O N 0• W Oo •o O O W O N O O 0 0 0 W V ?O z a 0 N 8 (((QQQQQQnnnnnn?????? II 41 Fa; > 9 Hti ;s z 4y? 03 > rM? s > 3 •' U V ? T S } "'J??g]? M?bpp??pp g b000 ??? kO O.P a ? ? o $ ?.? INK ,? ? ? S a 8' 1 M aj^' a 9 '( ReC. 3 S NO V a al n 00 ?O ? N X88 ?` c- VERIFICATION CAPITAL ONE BANK (USA), N.A., successor-in-interest to Capital One Bank vs TRAYLOR, DEBORAH K 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, JAMELA SINGLETARY, 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. JA4 Z-7?' ET No ublic 4388642030263589 A049 WELTMAN, WEINBERG & REIS CO., L.P.A. ARYONNE MABSON NOTARY PUBLIC DEKAIB COUNTY, GEORGIA MY COMMISSION EXPIRES OCT. 29, 2011 I ? 9L, 00 00 00 ;;. t I E G3 tV i 0 SHERIFF'S RETURN - REGULAR CASE NO: 2008-03936 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CAPITAL ONE BANK VS TRAYLOR DEBORAH K MARK CONKLIN , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon TRAYLOR DEBORAH K DEFENDANT the at 0013:05 HOURS, on the 9th day of July , 2008 at 25 N QUEEN STREET SHIPPENSBURG, PA 17257 DEBORAH TRAYLOR 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 20.00 Affidavit .00 Surcharge 10.00 .00 4 Sworn and Subscibed to before me this day So Answers: R. Thomas Kline 07/10/2008 WELTMAN WEINBERG & REIS By: Deputy Sheriff of A. D. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK, Plaintiff vs. DEBORAH K TRAYLOR Defendant No. 08-3936-CIVIL TERM PRAECIPE FOR DEFAULT JUDGMENT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: Matthew D. Urban, Esquire PA I.D.#90963 Weltman, Weinberg & Reis Co., L.P.A. 1400 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#06508555 Judgment Amount $ 2,029.53 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. 08-3936-CIVIL TERM DEBORAH K TRAYLOR Defendant TO THE PROTHONOTARY: PRAEOIPE FOR DEFAULT JUDGMENT Kindly enter Judgment against the Defendant, DEBORAH K TRAYLOR above named, in the default of an Answer, in the amount of $2,029.53 computed as follows: Amount claimed in Complaint $1,872.72 Interest from June 19, 2008 to October 15, 2008 at the interest rate of 25.90% per annum $156.81 TOTAL $2,029.53 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: Matthew D. Urban, Esquire PA I.D.#90963 Weltman, Weinberg & Reis Co., L.P.A. 1400 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#06508555 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: 25 N QUEEN ST SHIPPENSBURG,PA 17257 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff. DEBORAH K TRAYLOR Defendant IMPORTANT NOTICE TO: Deborah K Traylor 25 N Queen St Shippensburg,Pa 17257 t, (1 Date of Notice: I X W WR#:06508555 V CASE#: 08-3936-CIVIL TERM 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 NOTICE TO A 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. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 WELTMAN, WEINBERG & REIS CO., L.P.A. By: 6 /) Uvm vu-a"'__ PATRICK THOMAS WOODMAN PA I.D. #34507 WELTMAN WEINBERG & REIS CO., L.P.A 1400 KOPPERS BLDG, 436 7TH AVE. PITTSBURGH, PA 15219 (412) 434-7955 WWR #06508555 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff DEBORAH K TRAYLOR Defendant IMPORTANT NOTICE TO: Budget Counseler Marantha 527 L.W.E. Po Box 507 Chambersburg, Pa 17201 Date of Notice: W"- &* aQ e WWR#:06508555 d CASE#: 08-3936-CIVIL TERM 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 NOTICE TO A 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. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 1701.3 (717) 249-3166 WELTMAN, WEINBERG & REIS CO., L.P.A. By: ?f ate. (/tW?ac64 Q1VU1t1-^ PATRICK THOMAS WOODMAN PA I.D. #34507 WELTMAN WEINBERG & REIS CO., L.P.A 1400 KOPPERS BLDG, 436 7m AVE. PITTSBURGH, PA 15219 (412) 434-7955 IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK, Plaintiff VS. DEBORAH K TRAYLOR Defendant Case no: 08-3936-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, DEBORAH K TRAYLOR 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, DEBORAH K TRAYLOR is not in the military service. Further Affiant sayeth naught. AFFIANT SWORN T DD SUBSCRIBED i y presence this JNay of ?}GU COMMONWEALTH OF PENNSYLVANIA ?./ Notarial Seal NO RY P IC Wayne A ,tones, Notary Public City OF Pittsburgh, Allegheny County My Commission Expires June 29, 2010 Member, Pennsylvania rlseociation of Notarise 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 Military Status Report ' Pw•suant to the Servicemembers Civil Relief'Act Page 1 of 2 OCT-15-2008 11:24:23 Last Name First/Middle Begin Date Active Duty Status Service/Agency TRAYLOR DEBORAH K 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. 1/1 - Mary l4. Snavely-.D:a on, Director Dep?a'-tment ofDefer'se - Manpower Data Center 1600,,'`,'i'ilson Blvd., cite 400 Arlin ton. `?.A 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 U•SCS 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 "defenseiipk.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.miItag/pis/I'C09S.LDR.html. WARNING: This certificate was provided based on a name and Social Security number. (SSN) provided https:/Jvnww.dmdc.osd.mil/scra/owa/scra.prc Select 10/15/2008 i Request for Military Status Page 2 of 2 .by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report III: BDOXETVJQWTJ https://www.dmde.osd.mil/scra/owa/scra.prc Select 10/15/2008 I- 4ok- P-%.l C-) hJ tos cs`r q --4 z m -? C :s IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK, Plaintiff VS. Civil Action No. 08-3936-CIVIL TERM DEBORAH K TRAYLOR 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 $2,029.53 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: By DEBORAH K TRAYLOR 25 N QUEEN ST SHIPPENSBU.RG, PA 17257 Plaintiffs address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7d` Avenue, Pittsburgh, PA 15219 1-888-434-0085 ?.. ? ,; IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK, Plaintiff vs. Civil Action No. 08-3936-CIVIL TERM DEBORAH K TRAYLOR Defendant NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the following Order or Jud ent was entered against you on (xx) Assumpsit Judgment in. the amount of $2,029.53 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 ONOT Y) BUDGET COUNSELER 527 L.W.E. PO BOX 507 CHAMBERSBURG, PA 17201 Plaintiffs address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7 h Avenue, Pittsburgh, PA 15219 1-888-434-0085 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff vs. DEBORAH K TRAYLOR Defendant(s) No. 08-3936-CIVIL TERM PRAECIPE FOR SATISFACTION OF JUDGMENT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt, Esquire PA I.D. # 42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7999 WWR#6508555 BNT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff VS. Civil Action No. 08-3936-CIVIL TERM DEBORAH K TRAYLOR Defendant(s) PRAECIPE FOR SATISFACTION OF JUDGMENT At the request of the undersigned attorneys for the Plaintiff, you are directed to satisfy the above-captioned Judgment. WELTMAN, WEINBERG & REIS CO., L.P.A. By: rodt, PA I.D. WELINB James )nAvenue 1400 ildin 436 SPittsb 5219 (412) WWR #6508555 Sworn to and subscribed before me this /at- day of July, 09 NO RY PUB C & REIS CO., L.P.A. Nlfariaf deal L v" Ci1 s.u f',e.A fortes, Not" Public ihsburgh, Allegheny Cou 'y rkly 9 Commissio1Mpires June 29 2010 "" ?" , P 17ngy1v?ni, gssoG" e" ba a Notaries T? ?I_ '?Y Ji i 1C i 2`u9 JU 17 PH i2: ? J t Ci 1 :_}i r rr t Nit 42.00 Po AT't `f crmr1que8 gT* 0 sla s