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HomeMy WebLinkAbout08-3939 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL, ONE BANK (USA), N. n Plaintiff No: ?g - 3939 l..:t?<< kern vs. COMPLAINT IN CIVIL ACTION SALLY A SHARPE Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: Matthew D. Urban WELTMAN, WEINBERG & REIS CO., L.P.A. 436 Seventh Avenue, Suite 1400 Pittsburgh,. PA 15219 (412) 434--7955- FAX: 412-338-71.30 06677093 C N.Pit IAS IN THE COURT OF COMMON PLEAS OF C"JT°i73E?.' t?11' COUNTY, PEN1gSYLVANIA CIVIL DIV-S:ION i CAPITAL ONE BANK (USA), N. Plaintiff vs. Civil Action No SALLY A SHARPE 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, L-r 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 ycu. 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 PAPE:'.12 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 ('7w7) 249-3165 COMPLAINT 1. Plaintiff, CAPITAL ONE BANK (USA), 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: SALLY A SHARPE 149 E MAIN ST WALNUT BOTTOM, PA 17266 3. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXXXXXX4315 . 4. Defendant made use of said credit card and has a current balance due of $1343.32 , as of May 15, 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 20.400% per annum on the unpaid balance from May 15, 2008 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 .ts favor. and against Defendant , SALLY A SHARPE , INDIVIDUALLY , in the amount of $1343.32 with continuing interest thereon. at the rate of 2C.400% per annum from May 15, 2008 plus costs. duttriew D . TJrban WELTMAN, WEINBERG & REIS Co., L.P.A. 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 (412) 434-7955 FAX: 412-338-7130 06677093 C N Pit IAS 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. CBPiita/CW NOT PAYING YOUR DEBT 500013 what's in your wallet? DOESN'T MAKE IT GO AWAY. In fad, 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 &= 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 days to keep your account from being charged aff. m 2006 Capital One Services, Inc. Capital One is a federally registercd service mark ALI rights reserved 500013-08503 FINANCE Previous Balance Payments b Credits CHARGE Transactions New Balance Minimum Payment Due Date $961.73 - $0.00 + $16.27 + $29.00 = $1,007.00 $257.00 Jan. 21, 2007 Nov. 22, 2006 - Dec. 21, 2006 Page 1 of 1 PIEASE PAY N LW Tors AarMW MasterCard Platlnum Account Ma Mis erCar Plata Your account is six payments behind. If we charge off your account due to late payments, we will report the s 5 charged-off status to several national credit bureaus, and the Purchase APR as reflected on this statement will i be applied to all your outstand ng balances. Act now to prevent this from happening. Please pay the amount due Your Account information on your statement or give us a call at 1.600.955.6600. Wall work with you so you can take control of your account and start rebuilding your credit with Capital One. TOTAL CREDIT LINE $750.00 TOTAL AVAILABLE CREDIT $0.00 CREDIT LINE FOR CASH $750.00 payments, Credits & Adjustments AVAILABLE CREDIT FOR CASH $0.00 Transactions 1 21 DEC PAST DUE FEE $29.00 Finance Charges (Please see reverse for important informatim) Balance at Periodic ?ng CF ?CE applied to Your account is 90 days past due and your Payment Protection coverage has been suspended. As stated in your Payment Protection agreement your coverage and monthly charge will be reinstated once your account is Purdrases $970.53 0.05569% P 20.40% $16.27 no longer 90 days past due. You may sill be eligible for bene9ls to be paid t0 your account for loss events Cash $0.00 0.05666% P 21.49% $0.00 described in your Payment Protection agreement. Call Slonebridge Berrefit Services at 1-866-527.6904 to See If ANNUAL PERCENTAGE RATE applied this period: 20.40% your situation qualifies for benefits. At Your Service 1600503,1637 Y our You were assessed a past due fee because your minimum payment was not received by the due date. To avoid ® this fee in the future, we recommend that you allow at last 7 business days for your minimum payment to reach To Customs Rele8as at' to report a lost or stolen card: call Capital One. ® Send payments to: Capital One Be* • P.O. Box 70884 - Charkne, N A Send Inquiries to: Capital One • P.O. Box 30285 - Sell take City, UT 6056 506 1 7 2 Gap OrL I what's in your wallet?. C 28272-0884' EXHIBR 84130-0285 1 061221 PAGE 1 of 1 OIBC6056 PLEASE RETURN PORTION BELOW WITH PAYMENT 0 5178052626364315 21 1007000030000257005 New Balance Minimum Payment Due Date C$1,007.00 $257.00 Jan. 21, 2007 PLEASE PAY AT LEAST THIS AMOUNT Amount Enclosed . Capital One Bank P.O. Box 70164 IslsslllsssrtlrltNoIII Charlott9, NC 29272-0884 InIsllnlsulsllurlulrillurlnlslulnlulltIloilo 11nr11 Account Number. 5178-0526-2636-4315 Please print address or phone number changes below using blue or black ink. Home Phone Altemwte Phone Email address @ #90356757479435159 NAIL ID NUMBER SALLY A SHARPE 149 E MAIN ST WALNUT BOTTOM, PA 17266-9712 nrlllsulr,lrlsllnrllnlsluloslnsllt,Islslnllrlnslln 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. SALLY A SHARPE VERIFICATION CAPITAL ONE BANK (USA), N.A. vs SHARPE, SALLY A 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, SHARON REUBENS, 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. SHARON REUBENS Notary Public 5178052626364315 A049 WELTMAN, WEINBERG & REIS CO., L.P.A. 4 O 00 .oho v O w lit* %J0 94 SHERIFF'S RETURN - NOT SERVED CASE NO: 2008-03939 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CAPITAL ONE BANK USA NA VS SHARPE SALLY A R. Thomas Kline , Sheriff , who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT , to wit: SHARPE SALLY A but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT & NOTICE the within named DEFENDANT , SHARPE SALLY A NOT SERVED , as to 149 E MAIN STREET WALNUT BOTTOM, PA 17266 NUMEROUS ATTEMPTS. DEFENDANT WAS HOME AND WOULD NOT ANSWER DOOR. Sheriff's Costs: So answers: Docketing 18.00 c- Service 28.00 _ r Affidavit .00 R. Thomas Kline Surcharge 10.00 Sheriff of Cumberland County .00 56.00 WELTMAN WEINBERG REIS 08/01/2008 Sworn and Subscribed to before me this day of , A. D. 1' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA), N. Plaintiff VS. SALLY A SHARPE Defendant NO : 08 - 3939 0,1 Vi ( l erw COMPLAINT IN CIVIL ACTION FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: Matthew D. Urban WELTMAN, WEINBERG & REIS CO., L.P.A. 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 (412) 434-•7955 - FAX: 412-338-71.30 06677093 C N.Pit IAS VW COPY FROM RECORD In Te Wy whereof, I here aelo set my haW d ? F at >de, Pa. ova_ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, ' P EN1,SYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA), N. Plaintiff VS. Civil Action No . SALLY A SHARPE 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 twerlt?7 (2W days after this cornp_ laint and notice are se-rued, b-r entering a wi:itten appeFLrance personally or by an attorney Ex.d riling in writing with. the court your defenses or objections to the claims set forth against ycu. 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 tae plaint=iff. You may lose money or r-roperty or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR L_kWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CAM:OT 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 1701.3 (7117) 249-3166 COMPLAINT 1. Plaintiff, CAPITAL ONE BANK (USA), 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: SALLY A SHARPE 149 E MAIN ST WALNUT BOTTOM, PA 17266 3. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXXXXXX4315 . 4. Defendant made use of said credit card and has a current balance due of $1343.32 , as of May 15, 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 20.4006 per annum on the unpaid balance from May 15, 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 , SALLY P_ SHARPE , INDIVIDUALLY .in the amount of $1343.32 with continuing interest thereon at the rate of 2C-.400% per annum from May 15, 2008 plus costs. Matthew D. Urban ----- -?---- WELTMAN, WEINBERG & REIS CO., L.P.A. 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 (412) 434-7955 FAX: 412-338-71.30 06677093 C N Pit IAS 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. capital0te° NOT PAYING YOUR DEBT 500013 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 &= check by phone service or speak to an associate by calling 1.800.955.6600. Make sure you Cal or pay the amount due on your statement within 30 days to keep your account from being charged of. 0 2006 Capita! One Services, Inc Capita! One is a federally registered service mark All rights -rrved 500013.08503 FINANCE Previous Balance Payments & Credits CHARGE Transactions New Balance Minimum Payment Due Date C$961.73 - $0.00 + $16.27 + $29.00 = $1,007.00 $257.00 Jan. 21, 2007 Nov. 22, 2006 - Dec. 21, 2006 Page 1 of 1 MEAR FAY AT LW TM AMaan MasterCard Platinum Account 51784526.26364315 Your Account Information TOTAL CREDIT LINE $750.00 TOTAL AVAILABLE CREDIT 50.00 CREDIT LINE FOR CASH $750.00 AVAILABLE CREDIT FOR CASH $0.00 [Finance Charges (Please see reverse four irmepport?ant information) Baps plied to P?? APR h? CFINAN HARGE rchases $970.53 0.05589% P 20.40% $1627 sh $0.00 0.05888% P 21.49% $0.00 NNUAL PERCENTAGE RATE applied this period: 20.40% ® At Your Service 1-MM3.3637 To all Customer Relations ar to report a lost or stolen card Your account is six payments behind. It we charge off your account due to late payments, we will report the charg" status to several national credit bureaus, and the Purchase APR as reflected on this statement Al be applied to all your outstanding balances. Ad now to prevent this from happening. Please pay the amount due on your statement or give us a call at 1.800.955.6600. We'll work with you so you can take control of your account and start rebuilding your credit with Capital One. Payments Credits & Adiustments Transactions 1 21 DEC PAST DUE FEE $29.00 Your account is 90 days past due and your Payment Protection coverage has been suspended. As stated in your Payment Protection agreement, your coverage and monthly charge will be reinstated once your account is no longer 90 days past due. You may ad be eligible for benofts to be paid to your account for loss everts described in your Payment Protection agreement. Call SMnebridge Beneft Services at 1-MB-527 904 to see t your situation quafilles for bereft. You were assessed a past due fee because your minimum payment was not received by the due date. To avoid this fee in the future, we recommend that you allow at least 7 business days for your minimum payment to reach Capital One. ® Sand payments to: Capital One Bank • P.O. Box 70884 - DOIDtle, NC 28272.0884' X Sand pital One P.O. ? 30285. Sat Lake Cry, UT 84130-0285 E HI BIT A Ca 1 SIMON 6056 506 1 7 21 061221 PAGE 1 of 1 OIBC6056 PLEASE RETURN PORTION BELOW WITH PAYMENT 0 5178052626364315 21 1007000030000257005 CapBJhA1GW what's in your wallel7• Account Number. 5178-0526-2636-4315 New Balance Minimum Payment Due Date C$1,007.00 $257.00 Jan. 21, 2007 PLEASE PAY AT LEAST THIS AMOUNT Amount Enclosed Capital One Bank P.O. Box 70664 Irlrrlllrrrrrlrllrrlll Charlotte, NC 26272-0664 Irtlrllrrlrrrlrllrrrlralrlllrnlrrlrlrrlnlrrllrrlrrlrsill IIIH Please print address or phone number changes below using blue or black ink. Address Home Plane Alternate Phone E-mail address a9035675747941515e MAIL ID NUMBER SALLY A SHARPE 349 E MAIN ST WALNUT BOTTOM, PA 17266-9712 urllltnltr[III lnrllnlrlgill OlrarllrrlrlrIIoilrlnrllrr 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. SALLY A SHARPE VERIFICATION CAPITAL ONE BANK (USA), N.A. vs SHARPE, SALLY A 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, SHARON REUBENS, 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. C SHARON REUBENS Notary Public 5178052626364315 A049 WELTMAN, WEINBERG & REIS CO., L.P.A. Cry j7 h S :b V L - ?F 8 U13Z IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff vs. SALLY A SHARPE Defendant(s) No. 08-3939-CIVIL TERM PRAECIPE TO REINSTATE COMPLAINT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt, Esquire PA ID #42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Buidling 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#6677093 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff vs. Civil Action No. 08-3939-CIVIL TERM SALLY A SHARPE Defendant(s) PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. WELTMAN, WEINBERG & REIS CO., L.P.A. By: James C. W PA ID #425 WELTM 1400 Ko Esquire Buidling & REIS CO., L.P.A. 436 Sev h Avenue Pittsbu , PA 15219 (412) 434-7955 W WR #6677093 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA), N. Plaintiff vs. SALLY A SHARPE Defendant No. COMPLAINT IN CIVIL ACTION FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: Matthew D. Urban WELTMAN, WEINBERG & REIS CO., L.P.A. 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 (412) 434--7955 FAX: 412-338-73.30 06677093 C N,Pit IAS IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION ,' CAPITAL ONE BANK (USA), N. Plaintiff vs. Civil Action No SALLY A SHARPE 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 ycu. You are warned that if you `ail to do so the case nay 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. it 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) 249-3165 . COMPLAINT 1. Plaintiff, CAPITAL ONE BANK (USA), 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: SALLY A SHARPE 149 E MAIN ST WALNUT BOTTOM, PA 17266 3. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXXXXXX4315 . 4. Defendant made use of said credit card and has a current balance due of $1343.32 , as of May 15, 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 20.400% per annum on the unpaid balance from May 15, 2008 . 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 .t:s favor_ and against Defendant , SALLY P_ SHARPE , INDIVIDUALLY .in the amount of $1343.32 with continuing interest thereon. at the rate of 20.400% per annum from May 15, 2008 plus costs. Matthew D. Urban WELTMAN, WEINBERG & REIS CO., L.P.A. 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 (412) 434-7955 FAX: 412-338-71.30 06677093 C N Pit IAS 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. caphwOne° NOT PAYING YOUR DEBT 5OW13 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 free check by phone service or speak to an associate by calling 1.800.955.6600. Make sure you can or pay the amount due on your statement within 30 days to keep your account from being charged off. m 2006 Capital One Services, J= Cs ral One it a, federally r sinned civic, mark. All r,ghxr resntxd 500013-08503 FINANCE Previous Balance Payments & Credits CHARGE Transactions New Balance Minimum Payment Due Date $961.73 + $16.27 + $29.00 = $1,007.00 $257.00 Jan. 21, 2007 Nov. 22, 2006 - Dec. 21, 2006 Page 1 of 1 MEAM W AT LEAST MS AMOLW MasterCard Platinum Account 5178-M26-26364315 Your Account Information TOTAL CREDIT LINE $750.00 TOTAL AVAILABLE CREDIT $0.00 CREDIT LINE FOR CASH $750.00 AVAILABLE CREDIT FOR CASH $0.00 FFInanceCharges lease see reverse fa important information) rate Periodic COrndhng FINANCE d lo rate AP CHARGE 70.53 0.05589% P 20.40% $1627 O.OD 0.05688% P 21.49% $0.00 RATE applied this period: 20.40% Your accourd is sic payments behind. H we charge off your account due to late payments, we will report the charged•oft status to several national credit bureaus, and the Purchase APR as reflected on this statement will be applied to all your outstanding balances. Ad now to prevent this from happening. Please pay the amount due on your statement or give us a call at 1.800.955.6600. We'll work with you so you can take control of your account and start rebuikfing your credit with Capital One. Payments, Credits & Adjustments Transactions 1 21 DEC PAST DUE FEE S29.00 Your accourd is 90 days past due and your Payment Protection coverage has been suspended. As stated in you Payment Protection agreement, your coverage and monthly charge will be reinstated once your account is no longer 90 days peg due. You may still be eligible for benefits to be paid to your account for loss events described in your Payment Protedion agreement Call Sionebrillp Benefit Services at 1.89&527-6904 to see'rf your situation qualifies for berhefds. At Your Service 1.800,903-3637 You were assessed a past due fee because your minimum payment was not received by the due date. To avoid To rat Customer Reteams or m report a lost a stolen card: this fee in the future, we recommend that you allow at least 7 business days for your minimum payment to reach Capital One. ® Swid payments to: Capital One Bank - P.O. Box 70864 • Charlotte, NC 28272-0884 A Send inquiries to: GAP V Capitel One • P.O. Box 30285 - Soft Lake Cey, UT 84130.0285 a 1 6056 506 1 7 21 061221 PAGE 1 of 1 OIBC6056 PLEASE RETURN PORTION BELOW WITH PAYMENT cap"0 5178052626364315 21 1007000030000257005 ?' I what's in yourwa1M?' New Balance Minimum Payment Due Date Account Number. 5178-0526-2636-4315 Please print address or phone number changes below using blue or black ink. $1,007.00 $257.00 Jan. 21, 2007 Address PLEASE PAY AT LEAST THIS AMOUNT Home Phone Alternate Phone Amount Enclosed Email address @ , a 4035675747941515, MAIL Il NUMBER SALLY A SHARPE 149 E MAIN ST Capital One Bank WALNUT BOTTOM, PA 17266-9712 %.0;,9o:%70684 1,6rlllnurlrlu'lll I,nlllnrhrlrlrllhrrl6rlrlnlur6ul1Ml1Llnllrlrrr16r1 o. NC 26272-0884 LrIrIlrrlrrrlrlLrdrdrllLrrlrlLLrlydrrllrrlrrlrrlLrrll 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. SALLY A SHARPE VERIFICATION CAPITAL ONE BANK (USA), N.A. vs SHARPE, SALLY A 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, SHARON REUBENS, 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. L SHARON REUBENS NotaryPublic 5178052626364315 A049 WELTMAN, WEINBERG & REIS CO., L.P.A. LE:3j I t ` OF THE Few s'i"NOTARY 2009 JUN _ 5 PM `: 5 2 Gtv?? a',' 11rr?!„ PENN (?-1f $$ ? ? ? S(o ?:,,c-? aat?3aa Sheriffs Office of Cumberland County R Thomas Kline N b Sheri $titwytrv pt ` n,u6er/? "= j Ronny R Anderson V - Chief Deputy Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor --- Capital One Bank (U.S.A.) N.A. vs. . Case Number Sally A. Sharpe 2008-3939 SHERIFF'S RETURN OF SERVICE 07/02/2009 09:06 PM - R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Sally A. Sharpe, but was unable to locate her in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant Sally A. Sharpe. After several attempts the complaint has expired. SHERIFF COST: $53.20 SO July 06, 2009 k R TXOMAS KLINE, SHERIFF 1LE - -i?? ; r ,Y 1 2f610 . 'R 13 A i 9. 43 Cvf,? . , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA) NA Plaintiff vs. SALLY A SHARPE Defendant No. 08-3939-CIVIL TERM MOTION FOR ALTERNATE SERVICE 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 #6677093 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA) NA Plaintiff No. 08-3939-CIVIL TERM vs. SALLY A SHARPE Defendant PLAINTIFF'S MOTION FOR ALTERNATE SERVICE AND NOW, comes Plaintiff, by counsel, Weltman, Weinberg & Reis Co., L.P.A. and requests this Honorable Court to enter an Order allowing the Plaintiff to make service upon Defendant, Sally A Sharpe, by certified U.S. Mail and Certificate of Mailing, addressed to 149 E. Main Street, Walnut Bottom, Pa 17266, averring in support thereof the following: 1. On or about July 3, 2008, Plaintiff filed a Complaint in Civil Action against Defendant to recover the unpaid balance due Plaintiff from Defendant in the amount of $1,343.32. 2. When the Sheriff of Cumberland County, Pennsylvania, attempted to make service of Plaintiff's Complaint on Defendant, the Sheriff was unable to do so, as evidenced by the Sheriffs return, a true and correct copy of which is attached hereto, marked Exhibit "I", and made a part hereof. 3. Upon receipt of the Sheriff's return of no service, Plaintiff conducted an investigation with the United States Postal Service to confirm the physical address of the Defendant. WWR #6677093 4. Pursuant to Plaintiffs request for information, the United States Postal Service confirmed Defendant's physical address of 149 E. Main Street, Walnut Bottom, Pa 17266, a true and correct copy of Plaintiff's Postal Request is attached hereto, marked as Exhibit "2", and made a part hereof. 5. Plaintiff conducted an online white pages search and was unable to confirm a current address for Defendant of 149 E. Main Street, Walnut Bottom, Pa 17266. 6. Plaintiff contacted the Cumberland County Tax Assessment office, a representative from which could not confirm the Defendant as being the registered owner of 149 E. Main Street, Walnut Bottom, PA 17266. 7. Upon receipt of the Sheriff's return of no service, Plaintiff conducted an investigation with the Accurint Total Research System to confirm the physical address of the Defendant. 8. Pursuant to Plaintiff's request for information, Accurint Total Research System confirmed Defendant's physical address of 149 E. Main Street, Walnut Bottom, PA 17266, a true and correct copy of the Accurint search results is attached hereto, marked as Exhibit "3", and made a part hereof. 9. Based upon the foregoing, Plaintiff believes and therefore avers that Defendant is attempting to avoid service of process in the above-captioned matter and Plaintiff therefore seeks an Order of Court, pursuant to Pennsylvania Rule of Civil Procedure 430, granting Plaintiff leave to serve its Complaint on Defendant by alternative means. WWR #6677093 WHEREFORE, Plaintiff requests this Honorable Court to enter an Order pursuant to PA.R.C.P. 430(a), authorizing the Plaintiff to serve Defendant by Certified U.S. Mail and Certificate of Mailing sent to an address (149 E. Main Street, Walnut Bottom, Pa 17266) at which Defendant is presently receiving mail according to information obtained from the Post Office, or by allowing service by a competent adult. William T. Molczan, quire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR #6677093 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA) NA NO. 08-3939-CIVIL TERM Plaintiff VS. SALLY A SHARPE Defendant AFFIDAVIT PURSUANT TO PA R.C.P. 430 (a) BEFORE ME, a Notary Public, in and for the foregoing County and Commonwealth, personally appeared William T. Molczan, Esquire, of Weltman, Weinberg & Reis, Co., L.P.A., attorneys for Plaintiff, and deposes and says that the following accurately reflects efforts made to ascertain the exact whereabouts of Defendant named in the above-captioned matter. a. Plaintiff requested current address information from the United States Postal Service, which request for information confirmed the current address for Defendant as being 149 E. Main Street, Walnut Bottom, Pa 17266. A true and correct copy of the Postal Service Return is marked Exhibit "2" attached hereto and made a part hereof. b. Plaintiff conducted an online what pages search that could not confirm the Defendant's address to be 149 E. Main Street, Walnut Bottom, PA 17266. C. Plaintiff requested current address information from the Accurint Total Research System, which request for information confirmed the current address for Defendant as being 149 E. Main Street, Walnut Bottom, PA 17266. A true and correct copy of the Accurint search results is marked Exhibit "3" attached hereto and made a part hereof. WWR #6677093 Plaintiff conducted an online tax-assessment search for the address of the Defendant that could not confirm the Defendant as being the registered owner of 149 E. Main Street, Walnut Bottom, PA 17266. Finally, Affiant deposes and says that after the foregoing investigation, the exact whereabouts of the Defendant, Sally A Sharpe, is 149 E. Main Street, Walnut Bottom, Pa 17266. WELTMAN, WEINBERG & REIS, CO., L.P.A. Z/4'/ William T. Molczan, Esq)Ke PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 Sworn to and subscr' fore me this IC" y of arch, 10 N ?pF pENNgYt.VA1i1Y1 Nio/r+riM 8"j w.yrr. A. JOW. ft"N ,kk ?of Imsouro, t Member. Pen Agodation of Notaries WWR #6677093 Sheriffs Office of Cumberland County R Thomas Kline Sheriff Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor Capital One Bank (U.S.A.) N.A. vs. Sally A. Sharpe SHERIFF'S RETURN OF SERVICE Case Number 2008-3939 07/02/2009 09:06 PM - R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Sally A. Sharpe, but was unable to locate her in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant Sally A. Sharpe. After several attempts the complaint has expired. SHERIFF COST: $53.20 July 06, 2009 ?,,??tr at clu"b"t4.7 OFFICE OF THE ShERIFF SO R Ty90MAS KLINE, SHERIFF EXHIBIT i -, r Postmaster WALNUT BOTTOM, PA 17266 Date: September 29, 2009 t(1LL=S i i llit iH?i v(L OF :?vi?i.ESS OR BOXI1OLDFi"i3; ORP.IATION':EEDED FOR SERVICE OF LEGA! PROCESS Please furnish the new address or the name and street address (if a boxhokler) for the following: Name: SALLY A SHARPE 149 E MAIN ST Address: WALNUT BOTTOM, PA 17266 Note: Only one request may be made per completed form. The name and last known address are required for change of address information. The name, if known, and Post Office box address are required for boxholder information. The following information is provided in accordance with 39 CFR 265.6(d)(5)(ii). There is no fee for providing boxholder or change of address information. 1. Capacity of requester (e.g., process server, attorney, party representing self): ATTORNEY 2. Statute or regulation that empowers me to serve process (not required when requester is an attorney or a party acting pro se---except a corporation acting pro se must cite statute): 3. The names of all known parties to the litigation: SALLY A SHARPE, CAPITAL ONE BANK (USA);NA 4. The court in which the case has been or will be heard: PROTHONOTARY CUMBERLAND C 5. The docket or other identifying number (a or b must be filled out): X a. Docket or other identifying number: #08-3939-CIVIL TERM __ b. Docket or other identifying number has not been issued 6. The capacity in which this individual is to be served (e.g., defendant or witness): DEFENDANT WARN!NG THE SUBMISSION OF FALSE INFORMATION TO OBTAIN AND USE CHANGE OF ADDRESS INFORMATION OR BOXHOLDER INFORMATION FOR ANY PURPOSE OTHER THAN THE SERVICE OR LEGAL PROCESS IN CONNECTION WITH ACTUAL OR PROSPECTIVE LITIGATION COULD RESULT IN CRIMINAL PENALTIES INCLUDING A FINE OF UP TO $10,000 OR IMPRISONMENT OF NOT MORE THAN 5 YEARS, OR BOTH (TITLE 18 U.S.C. SECTION 1001). I certify that the above information is true and that the address information is needed and will be used solely for service of legal process in conjunction with actual or prospective litigation. 0^ Signature William T. Molczan, Esquire; PA ID# 47437 Attorney Printed Name WWR File No. 6677093 User: REA No such address: WELTMAN, WEINBERG & REIS CO., L.P.A. No change of address order on file: Y Moved. left no fnrwir ;nn '-d-dress: 436 Seventh Avenue, 1400 Koppers Building Pittsburgh. PA 15219 FOR POST OFFICE USE ONLY NEW ADDRESS OR BOXIIOLDER'S NAME POSTMARK . AND STREET ADDRESS EXHIBIT z Deep Skip Search Page 1 of 1 SALLY A SHARPE 149 E MAIN ST SALLY SHARFE WALNUT BOTTOM PA 17266-9712 SALLEY A Link ID: 2311232333 Jun 06 - Feb 10 DOB: Age: 51 Gender - Female Setup Alert EXHIBIT httnc•//cPCiire arrrnrint rnm/ann/hnc/micr. CERTIFICATE OF SERVICE The undersigned certifies that a true and correct copy of the within Motion for Alternate Service was served on the ?TV \ day of_?i, 2010, by first class, U.S. Mail, postage-prepaid, addressed as follows: Sally A Sharpe 149 E. Main Street Walnut Bottom, Pa 17266 Attorney for Plaintiff WWR #6677093 CAPITAL ONE BANK (USA) NA IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. SALLY A. SHARPE, DEFENDANT NO. 08-3939 CIVIL IN RE: PLAINTIFF'S MOTION FOR ALTERNATE SERVICE ORDER OF COURT AND NOW, this 15th day of April, 2010, upon consideration of Capital One Bank (USA), NA's Motion for Alternate Service, IT IS HEREBY ORDERED AND DIRECTED that service of the Complaint in Civil Action may be made on Defendant, Sally A. Sharpe, by permitting the Plaintiff to mail a copy of the Complaint to the Defendant's last know address at 149 East Main Street, Walnut Bottom, PA 17266 by Certified Mail and by Certificate of Mailing Postal Form 3817, postage prepaid. Additionally, the Plaintiff shall post a copy of the Complaint on the residence at 149 East Main Street, Walnut Bottom, PA 17266. Service to be completed on the mailing and posting. By the Court, 4o, ?AA\ 14 % M. L. Ebert, Jr., J. -,-8t1Ty-A. Sharpe 149 East Main Street Walnut Bottom, PA 17266 illiam T. Molczan, Esquire Weltman, Weinberg & Reis, Co., LPA 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 bas Cc- CGS 1 /, -VIn C- O -r•i F3 a ,blo .j Um llo APA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff VS. SALLY A SHARPE Defendant(s) No. 08-3939-CIVIL TERM PRAECIPE TO REINSTATE COMPLAINT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: Lyndsay E Rowland, Esquire PA ID #205520 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Buidling 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#6677093 CFR IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff vs. Civil Action No. 08-3939-CIVIL TERM SALLY A SHARPE Defendant(s) PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. WELTN%N, WEINBERG & REIS CO., L.P.A. By: Lynd,4 E Row A4, SsglrC PA ID #205520 / WELTMAN, INBERG & REIS CO., L.P.A. 1400 Koppers Buidling 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR #6677093 410.00 PO Any C* %51888 1 94 &8a? SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson ~~~~,~-~;~ Sheriff :,i ,; f~~ far r.r,:, ~ !r7T,~,RY l i ~._ .~ Jody S Smith ~4~~,,1, ~~~~~" Chief Deputy °~ (~ ~ ~ ~ - 4 ~ ~ 3t .~ Richard W Stewart Solicitor - CUN?3~~~. ~ ~: ~~JUNTY F'~Ni4S~`LVANIA Capital One Bank (U.S.A.) N.A. vs. Case Number Sally A. Sharpe 2008-3939 SHERIFF'S RETURN OF SERVICE 08!3112010 06:30 PM -Stephen Bender, Deputy Sheriff, who being duly sworn according to law, states that on August 31, 2010 at 1830 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Sally A. Sharpe, pursuant to order of court by posting the premises located at 149 E. Main Street, Walnut Bottom, Cumberland County, Pennsylvania 17266 with a true and correct copy according to law. r~ STEPHEN BENDER, DEPUTY SHERIFF COST: $46.60 September 01, 2010 SO ANSWERS, ~' ~° `_` RON R ANDERSON, SHERIFF ;~:,rt. ~~,~_: -: ~~_~~~-~Ir ~ll:~ ~._ ~i V 16i~ ~1; a~~Pj + -~ w c ...j ,. L`1 ~ /~jY P l~`~F IN THE: COURT OF COMMON PI_,FAS Of~ CUMBERLAND COUNTY; PI:;NNSYLVANIA CIVIL DIVISION IN THE COURT OF COMMON PI:.EAS OI' CUMI3IIZI_nND COt1N"T'Y. PENNSYLVANIA CIVIL, DIVISION CAPITAL ONE BANK (USA), NA Plaintiff No. 08-3939 CIVIL VS. SAL.,LY A. SHARPS Defendant AFFIDAVI'C OF SERVICE OF COMPLAINT BEFORE ME, the ~mdersigned auChority, personally appeared James C~. Wai-mbrodt, Esquire, who according to law deposes and says that ~ copy of the Complaint in Civil Action has been served on the Defendant, SALI_.Y A. SHARPIE. l . On or about API2.1L 1~, 20I0, Plaintiff received asigned Order of Court permitting service, on the Defendant, to be complete and valid upon mailing to the complaint by first class mail, certificate of mailing and by certified mail, return receipt requested. Said Order of Court is attached as Exhibit "1 ". 2. On or about AUGUST 2E>, 2010, Plaintiff mailed the complaint to 149E :MAIN ST.. W ALNUT BOTTOM 17266. Said certificate of mailing and certified mail. receipts are attached as L?~hibit " 2". 3. On or about Ai.JGUST 31, 2010, Cumberland County Sheriff posted the property per court order. Service is deemed perfected on AUGUST 31, 2010. WELTMAN, WEINBERG &REIS, CO., L.P.A. James C. WaC ~brodt, Esquire PA I.D. #4 5 WELTM N, F,INBERG &REIS CO., L.P.A. 1400 Ko pers wilding 436 Sev nth venue Pittsbu gh, A 15219 (412) ~4-955 ~VWR~ i ~ 7093 Sworn to and subscribed before me fh)~s__ day of SP/~~c'n•~ef l0. ARY I~LIC COMMONWEALTH OF PENNSYLVANYA ~ Notarial Seal j Wayne A. Jones, Notary Public City of Pittsburgh, Allegheny County f My Commission Expires June 29, 2014 Member. Pennsylvania Assoti~lon rfi Nc~tarips CAPITAL ONE BANK (USA) NA IN THE COURT OF COMMON PLEAS OF PLAINTIFF :CUMBERLAND COUNTY, PENNSYLVANIA V. SALLY A. SHARPE, DEFENDANT NO. 08-3939 CIVIL IN RE: PLAINTIFF'S MOTION FOR ALTERNATE SERVICE ORDER OF COURT AND NOW, this 15th day of April, 2010, upon consideration of Capital One Bank (USA), NA's Motion for Alternate Service, IT IS HEREBY ORDERED AND DIRECTED that service of the Complaint in Civil Action may be made on Defendant, Sally A. Sharpe, by permitting the Plaintiff to mail a copy of the Complaint to the Defendant's last know address at 149 East Main Street, Walnut Bottom, PA 17266 by Certified Mail and by Certificate of Mailing Postal Form 3817, postage prepaid. Additionally, the Plaintiff shall post a copy of the Complaint on the residence at 149 East Main Street, Walnut Bottom, PA 17266. Service to be completed on the mailing and posting. By the Court, F 4 py '`'fit 'a M. L. Ebert, Jr., ~ J. Sally A. Sharpe 149 East Main Street Walnut Bottom, PA 17266 William T. Molczan, Esquire Weltman, Weinberg & Reis, Co., LPA 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 bas U.S. Postal .ServiceTh~ CERTIFIED MAILT~:~ RECEIPT -• {Domestic Mai! Onty~ iNo lrtsurance Coverage Provided) .. ~ For delivery information visit our website at www.usps.como, u'1 l7-' O p Retum Recelpl,Fee ~ (Endorsement Required) ~ Restricted Delivery Fee (Endorsement Reqwred) O lti ~ Total Postage & Fees O r-l O lti r '~L'{r~~ _, ~tt~ITEflS7I~TE'S Certificate PQSTI~ L SERVICE. IVf a i l i This Certiricale of Mating provides evidence That mail has been presented to USPS~ far mat, This form ma~ypbje®USed f~or~dgomes~i`c,~and®inlryer~nay6~onpal mailp. From: YVc.l~l 1 t~.d~, 4rUGl1 141c7! g f~ 13~~~7~~ l dA i 4U (~_ Ta: 436 7th Aue. urgh, P~ 15219 ,~ gYt1'.'~ hit 1 e_~ /~ L -Cn~ . 1, I ~~ . ~~ i ~ ~ .{ 1 L~~~~!~~ ~ ~ i"r~ .yi '~ . r. r ~ I ,~~+ ~' ,f PS Form 3817, April 2007 PSN 7530-02-000-9065 EX~B~T e 4 ,? ci 9 3 •_r n t,., 16 F M 12: IN THE COURT OF COMMON! PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA), NA Plaintiff VS. No. 08-3939 CIVIL TERM PRAECIPE FOR DEFAULT JUDGMENT SALLY A SHARPE Defendant pi fly bb #j Ufimbra04 aC# as?a7? 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) 434-7955 WWR# 6677093 Judgment Amount $ 2,024.28 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA), NA Plaintiff vs. Civil Action No. 08-3939-CIVIL TERM SALLY A SHARPE Defendant PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter Judgment against the Defendant, SALLY A SHARPE above named, in the default of an Answer, in the amount of $2,024.28 computed as follows: Amount claimed in Complaint $1,343.32 Interest from May 15, 2008 to November 8, 2010 at the interest rate of 20.400% per annum $680.96 TOTAL $2,024.28 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. Wa rodt, ESQUIRE PA I.D. #425 Weltman, W i erg & Reis Co., L.P.A. 1400 Koppe uilding 436 Seven enue Pittsburgh 15219 (412) 434 9 5 WWR# 6 7 093 Plaintiffs address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 1400 Koppers Building, 436 7th Avenue, Pittsburgh, PA 15219 And that the last known address of the Defendant is: 149 E MAIN ST., WALNUT BOTTOM, PA 17266 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff Case No. 08-3939-CIVIL TERM vs. SALLY A SHARPE Defendant TO: SALLY A SHARPE 149 E MAIN ST WALNUT BOTTOM, PA 17266 IMPORTANT NOTICE Date of Notice: 10 /1? 1149 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. 17018 (717) 249-3166 WELTMAN, VO.IIWBERG & REIS CO., L.P.A. Matthew Urban P.A.I.D.# 90963 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 Seventh Avenue, 1400 Koppers Building Pittsburgh, PA 15219 Phone: (412) 434-7955 6677093 N PIT C4P IN THE COMMON PLEAS COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA), NA Plaintiff VS. SALLY A SHARPE Defendant Civil Action No. 08-3939-CIVIL TERM NON-MILITARY AFFIDAVIT The undersigned is the duly authorized agent and/or attorney for the Plaintiff in the within matter and states as follows: Affiant 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, SALLY A SHARPE 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 DMDC does not possess any information indicating that the below individual is in the military service: SALLY A SHARPE 149 E MAIN ST. WALNUT BOTTOM, PA 17266 Affiant further states that the averments contained herein are true and correct to the best of Affiant's knowledge, information and belief and that these averments are made subject to the penalties of 18 Pa C.S.A. §4904 relating to unsworn falsification to authorities. Request for Military Status • Department of Defense Manpower Data Center 40 Military Status Report Pursuant to the Service Members Civil Relief Act Page 1 of 2 Nov-09-2010 08:10:17 < Last Na First/Middle Begin Date Active Duty Status Active Duty End Date Service me Agency SHARPE SALLY A Based on the information you have furnished, the DMDC does not possess _ any information indicating the individual status. 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 Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). Olt 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 DoD strongly supports the enforcement of the Service Members Civil Relief Act (50 USC App. §§ 501 et seq, as amended) (SCRA) (formerly known as 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 status by contacting that person's Service via the "defenselink.mil" URL http://www.defenselink.miUfaq/pis/PC09SLDR.html. If you have evidence the person is on active duty and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. §521(c). If you obtain additional 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 active duty status including date the individual was last on active duty, if it was within the preceding 367 days. For historical information, please contact the Service SCRA points-of- contact. https://www.dmdc.osd.mil/appj/scra/popreport.do 11/9/2010 Request for Military Status Page 2 of 2 More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d)(1) for a period of more than 30 consecutive days. In the case of a member of the National Guard, includes service under a call to active service authorized by the President or the Secretary of Defense for a period of more than 30 consecutive days under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy TARs, Marine Corps ARs and Coast Guard RPAs. Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps) for a period of more than 30 consecutive days. Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of SCRA extend beyond the last dates of active duty. Those who would rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected. WARNING: This certificate was provided based on a name and SSN provided by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID:6CDBSV5GEF https://www.dmdc.osd.mil/appj/scra/popreport.do 11/9/2010 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA), NA Plaintiff VS. Civil Action No. 08-3939-CIVIL TERM SALLY A SHARPE Defendant SALLY A SHARPE 149 E MAIN ST. WALNUT BOTTOM, PA 17266 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 11.1 WHO (xx) Assumpsit Judgment in the amount of $ 2,024.28 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 Plaintiff's 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