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HomeMy WebLinkAbout08-4228IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. No. COMPLAIl`dT IN CIVIL ACTION GEORGE E SEIDLE individually and D/B/A VIDEO REPAIR SERVICE Defendant 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, I'A 15219 (412) 434-7? 55 WWR#06677300 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. Civil Action No. GEORGE E SEIDLE individually and D/B/A VIDEO REPAIR SERVICE Defendant COMPLAINT IN CIVIL ACTION 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 CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 COMPLAINT 1. Plaintiff is a corporation with offices at 15000 CAPITAL ONE DRIVE RICHMOND, VA 23238. 2. Defendant, GEORGE E SEIDLE , is an adult individual with a last known address of 813 WERTZVILLE RD ENOLA,PA 17025 , and engaged in business as VIDEO REPAIR SERVICE with a last known address of 813 WERTZVILLE RD ENOLA,PA 17025 3. Defendant applied for and received a credit card issued by Plaintiff bearing the account number XXXXXXXXXXXX5798. 4. Defendant made use of said credit card and h.s a current balance due and owing to Plaintiff, as of June 5, 2008, in the amount of $1,162.80 . 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 cardholder Agreement having not made monthly payments to Plaintiff thereby rendering the entire balance immediately due and payable. 6. Plaintiff avers that the Cardholder Agreement between the parties provides the Plaintiff is entitled to the addition of finance charges at the rate of 25.90% per annum on the unpaid balance. 7. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed and/or refused to pay the principal balance, finance charges or any part thereof to Plaintiff. WHEREFORE, Plaintiff prays for judgment in its favor and against Defendant, GEORGE E SEIDLE individually and DB/A VIDEO REPAIR SERVICE , in the amount of $1,162.80 with continuing interest thereon at the rate of 25.90% per annum from June 5, 2008 plus costs. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED SHALL BE USED FOR THAT PURPOSE. WELTMAN, WEINBERG & REIS, CO., L.P.A. William T. Molc , 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#:06677300 /One- NOT PAYING YOUR DEBT 500013 I 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 J= check by phone service or speak to an associate by calling 1.800.955.6600. Make sure you 011 or pay the amount due on your statement within 30 days to keep your account from being charged off. ® 2006 Capita! One Services, Inc. Capital One AS a federally rjaskmd smie, mark AR rigba resrrawi 500013.09503 FINANCE Previous Balance Paillments a Croft CHARGE Transactions New Dakota Minimum Payment Due Data $772.63 - $0.00 + $17.76 + $29.00 = $819.39 $319.39 Feb. 07, 2007 Dec. 08, 2006 - Jan. 08, 2007 Page 1 of 1 •'? KUK ee AT IEAST TIS AMOUNT Visa Business Card Account "low Your account is six payments behind. if we charge off your account due to late payments, we will report the 4115-07242521-5798 Ga charged-off status to several national credit bureaus, and the Purchase APR as reflected an this statement will sssr-be applied to all your outstanding balances. Act now to prevent this from happening. Please pay the amount due Your Account in Information r?turo on your statement or give us a call at 1.800.955.8600. Well work with you so you can take control of your TOTAL CREDIT LINE account and start rebuilding your credit with Capital One. TOTAL AVAILABLE CREDIT $0.00 CREDIT LINE FOR CASH 00.00 AVAILABLE CREDIT FOR CASH $0.? $0.00 Finance Charges q%asa sea reverse for important into me6rn) Bapppliieed to Pan?x R rag ?jjARGEE Purchases $782.09 0.0709696 25.90% $17.76 Cash $0.00 0.07096% 25.90% $0.00 ANNUAL PERCENTAGE RATE applied this period: 25.90% ® At Your Ssrvlca 1.800-087-0904 To Cal Cuafa oar Relations Or b repro a bat or adeo card: ® Send payments to: Cspad One, F.S.B - P.O. Box 70985 • Chabae, NC 29272-M A Saw inquiries to: CVkd One • P.O. Box 30285 - Sal Lake Cry. In 80130-0285 "Important Notice" At this time we are unable to provide your Rewards Summary. To review year current Rewards balance Or edit"l Rewards information, please call the number on the back Of your credit card. We apologize for arry in onvartiLrga this may cause. PMMO-rlt8. Credits 8 Adlustments Transactions 1 OB JAN PAST DUE FEE $29.00 Under terns previously disclosed to you, score or all of your Annual Percentage Rates (APRs) have been i? since your account was past due twice in Use past 12 boring cycles. if your rates have already subsequent detinquencen extended the duration of the inaesaed rates Remember: ff we receive Your minimum monthly payment on time for 12 consecutive bung cycles, this amount will be reviewed for a possible realm to your Non-Introductory APR When you provide a check as payment, you authorize us either b use Information from sow d" to make a One-time electronic fund transfer from your account or to process the payment as a check transaction. Wfnen we use dormation from your check to make an ebdmrric fund transfer, funds may be withdrawn from your account as soon as the same day we receive your P8YMBnt, and you will not receive your check back from your financial institution. 45 For more information on your Small Business account: You ware assessed a past due fee because your minimum payment was not received by the due data. To avoid VWL www.cepwarta caNwnarbuymate this fee in the future, we recommend that you allow at least 7 tattiness days fur your minimum payment to reach Capital One. 6056 506 1 7 7 070108 PAGE 1 of 1 O18C6056 PLEASE RETURN PORTION BELOW WITH PAYMENT cm~ 7 4115072425215798 07 0819390070000319392 Q- I whirs in your aallet7' New Balance Minimum Payment Due Date C$819.39 $319.39 Feb. 07, 2007 PLEASE PAY AT LEAST THIS AMOUNT Amount Enclosed c:::= Capital One, F.S.B P.O. Box 70665 I1Iu11lose riislnlsI Charlotte, NC 26272-0665 Inlsl6sluslsllsIslas lrlllur6Melse It I III1In61I11 11I1 ItI Account Number. 4115-0724-2521-5798 Ptease print address or phone number changes below using blue or black ink. ?4ddrest Home Phone Ahemate Phone f-mail address 01000163166137337s NAIL ID NUMBER VIDEO REPAIR SERVICE GEORGE E SEIDLE EXHIBIT 613 YERTZVILLE RD ENOLA, PA 17025-1634 ssdllsrsllLsrssIMLLLrssIILTIrssllsrLs>1ssrlLJlsrls>+rl Please write your account number on your check or money order made payable to Capital One, F.S.B and mail with this coupon in the enclosed envelope. GEORGE E SEIDLE t e. Gress Pwlee. You will aM---M ?"Wnlmwn plea period of 25 drys wMhoha tkynca rharys on new purahre0. new your ewrapa daily bhienoa by do daily pariodie ray era( by 7. Usyp Near Aeonhrarl. Y ou tie rwerpar d and aaocoura nnnot a uaetl M m Parlod. Due to rcradinp m a =rMCb i h b8arnar Op- chealao and d,.pr If yprrmW 'N w BaYrwa' Y? ? daily basis a due to riry C'* t. men W a varyna be~ Oft akv- m w t any Mtarnat S. No" About pedroft vanbn. Check anadehoa - try MWSM NOOM for js? and M pall for it mbar aadrad by your reed lybw. teena e amcrnt of inarhee conga carry assessed. 9. Memel P-mate" Rays (APR}, YNan You prmida • check r payment, you autlyrtre a your drNk to era a one-tl ne to - in o g r/akq deM. There . no yatla Wdotl n catlh eewnoe addRar rya Y no ea i d ? ` a. The 'er""A""ust P-Alp es •APR' o thefrom aW?rrwrn Y appear dioka fr m the POrrat es a chock baryeabn. Naha w a uy Proses Your bank aocowt w lo . p per o o 1 iaaea I you balance.' do not WY me Jobe *Nm b. H ar code P (Cks34 y Prlmaj, L (CA., bey LRIOR), C (Duarledy CDC al; (Berikcard Pit") oppeMS on the font W?^ horn Ya+awk m rake an aYCtonic Md h°abr, trewO may be wBhanw ken Your bank amount n d Accruing Fauna gle which AOO b O MoSi el l are not a a sense Pace period Nan d ~ dreg staWrem reed to ale periodic mW,h ry Dariotlb rates and conesPO^deq ANNUAL PERCEMAGE RATES noon n ye ewe day we meshy your pMWWt, and not WOW Your deck back from your fkwow kytlWyon? 2111 oe c rge i) hr tits Of a ed from en li on r btrerampa proceeded m your c or the 3) data a ken tie th f r y cony wary 4u'MY and may karrr or deaeau bard a re slow i dot, r bake in The NON Stress Jana(, pkal BILLMG RIGHTS SUMMARY (M Car of Errom or Ouselio s about Yo Se d e a cardr car" e d that bRkq Period. did Additloraft ryou not peytlle New BWnee' from re prevbue bBM the margin prevpury asdoeetl b You. Then drupes will bee 1110" Onre itrr daydyar hBYhp parlod mwratl by e If YOU ryas your bill is wsmnp, or If you need room m Infametlm o e 2 hapadin a bill wee to ue m e g Pend in hr, ere rem drppes manhwe to aoaue to your utpald billNya a* ry unpaid beYmoe Y pad in full. This Your pabdie raaelhharrt andrp In the mbnths at Jame y. , .fray and Odobr. c H y d . aaprey abed es noon es P10" d the. adder mr Mpades ahow h n ako from dam scaterenit. Wile mat hen from n da assn Q0 YOU low, s aIW '"010114, t ho you MW M Oft 1Meroa riu ryes, even if you pay rte entire New Salerno i dicayd on yu from of our e co a D (MaNay PYin e). F (MorAhly LIBOR), a a (Treeray Lr3OR) appear, W We bad Of adate rrherhl a or y wo acrd You ry ** bbl on which the You an call our Cualanw Pest d Rel ambr b t d in y rateshem ? by IM read relaraam clatl day, but ad not do "'Or lip P-- mash Unpaid Irharww cerpes ere added art to she P as and erANN? eL nth Periodic rRAT ° ANNUAL PERCENTAGE RATES cosy way rn minl aft W will not u , u o g coo will nut w your NW In kah- Mans your lod hasty glue ue the faitowirhp domhrbn: your ems and account raw- die dollar arr m pr aPPitaby eaprhra dYcrrAahohnm. t c. IBnmreath Firrrua Charge. Fore ach bov Pena tlue our o y will may nomeae, d2chaoss baud Iridicea, as fond in The NypaBpeat .mumY• on ft atayd pit. the ant Of the auapechad ant, a description of fins error and an N poaaEle, dwhy you beNaw riera y amblat i KMW m • finance charge, a minkam bW FINANCE OW4E 460.50 wil be MpoW mrgin Previmay dkdord m _ mfb. Otani" on the find day Of YOM diMS Period each mach. 4 A you raraw nr y amt, or H un rM a ?e M?co.' daacoplion a'the no It.. and whams bout You de rut haw b pay dry amount in t it. T billing pe Reduction aRMrhkerra drewrpes mr Men ripnt to not area . - of Lack Returned Paymeot Under Mean" 1M dyes b wgMof your oubmar ww or mak, .. arty fen w1ah a Part d par bill no M W06110n. NCR a WAMO efke we o your ou"atm d 2. Averepa DdY BWnr(mdudinp New Paduar? mange sa*A- by nail l daily balance d o Prior wnaaakn M10Y natWrp ourdpmbapees the t -Rene-1 YbvAeo d r , rn report you r delinquent or low any action ldbbr Credit Cad puncheon eath cash pun*rr, 9special its all, --t Of Y-r, sacks( purchase) by are oares onde d aa , snum6wWphaapeom your stemma, you Iwo 30 dalerm atdememwas coaledlo deri from the gym haw a Problem with the *oft dpropery aarrkr that You W d with a 0114111 card and you have he in pad hhiht t p hp ry Periodic ray(s) that has bean proWPhalY diadaesd to You. At the and leech day during You avoid PayYp dip ise or to ham oxh y° credited to you if you rannoal your ft W IM r y o caaFned era problem wMl M aWdum, you ropy hew the rght Pry lip hot arrant des on the prope d M Pre bhho8 Period, we apply the tidy periodic role for Gem aegmerlt dyoramaat b tlha dory hales d each each a hxokra wMpd havkftv Pay cancel You --.*, you dour n the uemwdmmlipfee. To by calling olr G t h W*-*m a ss y a r o Y- 0118 phinh:60.00 old Only wipe titre pumheee prbe vas more pinholes was made M ou h it " sapmara. Then d M and dhp i Peanut rho lip 1M mealy Of der dolly tabkaaroa to aMW at your Periodic n natorrher RalMlar DaPartnh ad pay Be~ M full caner D Mss the rnraccohip fed) Drier to th y ome scale a 100 mar d Within your mehV adder. (tr wa own or operate pea ^ardpm, a it we nhalatl you the adwrareerit f p e and of de tladysyy Period leharhoe enaga for each aapnee. lAO sdtl up tip reams ken S. rYos Clues Parr day Pori You can each espnpm m WM drpmlr perioae -crarge fa realer m dot your or a Property a services. all purchase are covered ragrdyn at arrow coarse d Purchase.) Pales remember m i il ent of Yyra?rKTo b?Mh awn breech a and and an a k account b call Our Customer ROWAMM Department, You dour destroy your Oadit and(s) and account acosais dtaft cancel PrMultaind dh usin s gn a correspond tDon not?. apply AD -Is~ -WK.& card accoures s w y w ayaclons and any paiodo a yd nft preian drA balance for g now amdo After y- -Wm to close. h you continue to a t S Door not OPptyto brMre natdsat cord amarn tlhr We OW dayrhatarata ?M?bryto amdy PeetadesofaW se t no anal pmudWeed lade Onanpemema, we w/I casid ekaipt dadhapeyoursurydatlmmkWyeur ?I Oa wPPdY immrmetbn wmMly rymly, , Privacy WPteLtiark:sr our vnen . glues us to rpaay defy bakers for esdh sepnert of your account. Now-, r You paid lip New Brarha shown On uIml ? an nhY, Your account will not be dosed You ?: any ue Capital Oa Y a yaarrly rayayred service mark of Cacao One Financial Corporation- AN righca reserved 02006 C Your Pmwau ecaWam M full for If your new balance was traheedlOe you maw autlhoas4 rrpnca ldt past due f n . apital One data a • OUR somead), near krona idfae, which pod to your purdhns aspect Pwdp espmarea are not added h asa, ovwi * few, r kWW PMWAM ftre fey Pry any olhrfees aaasse to your . a t account you a die m- drybrnatViamWftmaavaapedry balance by adding all the dry belesoe cop ow end rhwpahrble for pees amaaaa whet er vvy p at amardatthecone acco all Yaw YOU MQU69 to air ft amount or np bilkhp cycle, To alo"M Y- t of tip days I. trM °'r taw fahrros d ID YO r are Incurred es bWUM r equest to it* ?y n Ch1VM appearing on your aeooan after you er mubgY 1O M hew rsqu esytl tip ekxdnl m be d dosed. v1dcetl56-6-12/21M holbin ParonrrceaYbrnmtar lea A yaedbd b your account a df lowness dry we rapine It poWded(1)you err lea Yeadnc In to rrJOar han*.-eeebpe ed (2) yourpayoert is modred OarpmNrp any g3PA.Er(12allot Fr Pkeralesathead are(5)MWnassdayslapostal dakwy.PaymmYndehedgprayarwYoamnrob P?WSemnotes ndcaaemdndthe etym. code tlrm. Orpree mpnMOaOSy rhnhuplSnNay aehhmpholdsya etlpln pepardps, ft MM pasesq pow paYesa Wen Yes palm s chsa n rmnretldhlmm yarrdlrk b coke a aeAia dedmaeAad nnafakan Ydeaomleta b prowls W PeMer m a seek ka eabo.? day M ewha leanderkbmeynradmbhOd rardar, ham my he wilhkan Awn you, & owasoon as die eero you w7 nut oaks Yowdeck lack earn me *Now kapdnn. VERIFICATION CAPITAL ONE BANK (USA), N.A. vs SEIDLE, GEORGE E 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, DUDLEY TURNER, 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. DUDLEY T Notary Public Si-1A40N r?EU9ENS C?EKAI '' 4115072425215798 A049 WELTMAN, WEINBERG & REIS CO., L.P.A. Request for Service R. Thomas Kline Sheriff Cumberland County Office of the Sheriff One Courthouse Square Carlisle, PA 17013 Ph: 717.240.6390 Fx: 717.240.6397 Plaintiffs: Court Number: Expiration Date: Type of Action: Defendant/s: Serve Upon: Address for Service: Alternate Address for Service: Type of Service: ? Personal ? Adult in Charge ? Deputize ? Certified Mail ? Posting (copy of court order required) Special Service Instructions: **If service is to be made by deputized service to another county please specify which county Filing Attorney's Information: Name: Address: Telephone: C v v C') C -L, r . Gr J ? O c? `rt v Y'S K SHERIFF'S RETURN - REGULAR CASE NO: 2008-04228 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CAPITAL ONE BANK VS SEIDLE GEORGE E ET AL TIMOTHY REITZ , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon SEIDLE GEORGE E ET AL DEFENDANT the at 0014:31 HOURS, on the 23rd day of July , 2008 at 813 WERTZVILLE ROAD ENOLA, PA 17025 by handing to ALISON MACADAM ADULT IN CHARGE 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 15.00 Affidavit .00 Surcharge 10.00 .00 7/?S/08 43.00 Sworn and Subscibed to before me this day of , So Answers: I ?- ?; 0 P-,?o Z? R. Thomas Kline 07/24/2008 WELTMAN WEINBERG & REIS ?I By: Depu Sherif A.D. Y, 11. CASE NO: 2008-04228 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CAPITAL ONE BANK VS SEIDLE GEORGE E ET AL TIMOTHY REITZ , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon SEIDLE GEORGE E D/B/A VIDEO REPAIR SERVICE the DEFENDANT at 0014:31 HOURS, on the 23rd day of July , 2008 at 813 WERTZVILLE ROAD ENOLA, PA 17025 by handing to ADULT IN CHARGE 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 Sworn and Subscibed to before me this of So Answers: 6.00 .00 .00 10.00 R. homas Kline .00 16.00 07/24/2008 WELTMAN WEINBERG & REIS By: - day De uty er'ff A.D. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. No. 08-4228-CIVIL PRAECIPE FOR DEFAULT JUDGMENT GEORGE E SEIDLE individually and D/B/A VIDEO REPAIR SERVICE Defendant 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#06677300 Judgment Amount $ 1,254.39 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. GEORGE E SEIDLE individually and D/B/A VIDEO REPAIR SERVICE Defendant Civil Action No. 08-4228-CIVIL PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter Judgment against the Defendant, GEORGE E SEIDLE individually and D/B/A VIDEO REPAIR SERVICE above named, in the default of an Answer, in the amount of $1,254.39 computed as follows: Amount claimed in Complaint $1,162.80 Interest from June 5, 2008 to September 24, 2008 at the legal interest rate of 25.90% per annum $91.59 TOTAL $1,254.39 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: Mattw 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#06677300 Plaintiff's address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7`h Avenue, Pittsburgh, PA 15219 And that the last known address of the Defendant is: 813 WERTZVILLE RD ENOLA,PA 17025 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff GEORGE E SEIDLE individually and D/B/A VIDEO REPAIR SERVICE Defendant TO: George E Seidle 813 Wertzville Rd Enola,Pa 17025 / Date of Notice: OR- W WR#:06677300 CASE#: 08-4228-CIVIL IMPORTANT NOTICE 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: l" 66000" 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 #06677300 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff GEORGE E SEIDLE individually and DB/A VIDEO REPAIR SERVICE Defendant TO: George E Seidle DB/A Video Repair Service 813 Wertzville Rd Enola,Pa 17025 I_? Date of Notice: 01 W WR#:06677300 CASE#: 084228-CIVIL IMPORTANT NOTICE 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, WEINNBERG& R?EI`S CO., L.P.A. By: ?ak;'? J 1"CJd W??B" PATRICK THOMAS WOODMAN PA I.D. #34507 WELTMAN WEINBERG & REIS CO., L.P.A. 1400 KOPPERS BLDG, 436 7.. AVE. PITTSBURGH, PA 15219 (412) 434-7955 WWR #06677300 IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. GEORGE E SEIDLE individually and D/B/A VIDEO REPAIR SERVICE Defendant Case no: 08-4228-CIVIL 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, GEORGE E SEIDLE individually and D/B/A VIDEO REPAIR SERVICE 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, GEORGE E SEIDLE individually and D/B/A VIDEO REPAIR SERVICE is not in the military service. Further Affiant sayeth naught. A FIANT SWO TO A D S BSCRIBED i my presence this 4k?ry DA0 2CO of COIIAMONWEAITH OF PENNSYLVANIA kft SSW NOTAR PUBL C L Oadt, Ncdry PubMc MY aCanW*Wm Erq*uj* 15, Me I ber, Penney) _M Aeeo sum of Nobrie, 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 Pursuant to the Servicemembers Civil Relief Act Page 1 of 2 SEP-24-2008 13:18:36 ,< Last Name First/Middle Begin Date Active Duty Status Service/Agency SEIDLE GEORGE E 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 . Ev??_ 4"1- 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.defenseliiik.mil/faq/r)is/PC09SLDR.html 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 9/24/2008 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 ID:BODTRDRUEBM https://www.dmde.osd.mil/scra/owa/scra.prc Select 9/24/2008 D O Ry 00 S a CIO F ? , Y .n.. $... y4? • IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. GEORGE E SEIDLE individually and D/B/A VIDEO REPAIR SERVICE Defendant Civil Action No. 08-4228-CIVIL 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 /0/0 a /02 (xx) Assumpsit Judgment in the amount of $1,254.39 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 wil I 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 GEORGE E SEIDLE 813 WERTZV ILLE RD ENOLA,PA 17025 By: PROT OTA R DE PTY) Plaintiff's 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 CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. Civil Action No. 08-4228-CIVIL GEORGE E SEIDLE individually and D/B/A VIDEO REPAIR SERVICE 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 / 03 D$ (xx) Assumpsit Judgment in the amount of $1,254.39 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 GEORGE E SEIDLE D/B/A VIDEO REPAIR SERVICE 813 WERTZVILLE RD ENOLA,PA 17025 By: - 4?!444q4z PR ONOT R D UTY) /91 Plaintiffs address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7`" Avenue, Pittsburgh, PA 15219 1-888-434-0085