HomeMy WebLinkAbout08-4339IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK (USA),NA
Plaintiff No: ?g - 41334
VS.
JUSTIN A DOBROWOLSKY
COMPLAINT IN CIVIL ACTION
Defendant FILED ON BEHALF OF
Plaintiff
COUNSEL OF RECORD OF
THIS PART'?-T:
James C. Warmbrodt,42524
WELTMAN, WEINBERG & REIS CO., L.P.A.
436 Seventh Avenue, Suite 1400
Pittsburgh, PA 15219
(412) 434-7955
FAX: 412-338-7130
06571703 C N Pit BLK
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK (USA),NA
Plaintiff
vs.
JUSTIN A DOBROWOLSKY
Defendant
Civil Action No 3 ? / c:,41 Tz~"
COMPLAINT AND NOTICE TO DEFEND
You have been sued in court. If you wish to defend against the
claims set forth in the following pages, you must take action within
twenty (20) days after this complaint and notice are served, by entering
a written appearance personally or by an attorney and filing in writing
with the court your defenses or objections to the claims set forth
against you. You are warned that if you fail to do so the case may
proceed without you and a judgment may be entered against you by the
court :without further notice for any money claimed in the complaint or
for any other claim or relief requested by the plaintiff. You may lose
money or property or other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LA14YER 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. ICE MAY B ABLE
IF YOU CANNOT AFFOO MATIOONRABOUT LAWAGENCIESYER, OFFERELEGAL
TO PROVIDE YOU WITH INF
SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
LAWYER REFERRAL SERVICE
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
(717) 249--3166
COMPLAINT
1. Plaintiff, CAPITAL ONE BANK (USA),NA is a corporation with offices
at 15000 CAPITAL ONE DRIVE RICHMOND , VA 23238
2. Defendant is adult individual(s) residing at the address listed
below:
JUSTIN A DOBROWOLSKY
366 STOUGHT RD
CARLISLE, PA 17015
3. Defendant applied for and received a credit card bearing the
account number XXXXXXXXXXXXXXXX0436 .
4. Defendant made use of said credit card and has a current balance
due of $1086.49 , as of May 20, 2008 .
5. Defendant is in default by failing to make monthly payments when
due. As such, the entire balance is immediately due and payable to
Plaintiff .
6. Plaintiff is entitled to the addition of interest at the rate of
28.1000 per annum on the unpaid balance from May 20, 2008 A copy of
Plaintiff's STATEMENT is attached hereto, marked as Exhibit I'll, and
made a part hereof.
7. Although repeatedly requested t: do 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 , JUSTIN A DOBROWOLSKY INDIVIDUALLY , in the
amount of $1086.49 with continuing interest thereon at the rate of
28.100% per annum from May 20, 2008 plus costs.
James C . ""a rmn r 0 U L WELTMA., EINBERG & REIS CO., L.P.A.
436 Sev n h Avenue, Suite 1400
Pittsb,.rg , PA 15219
(412) 434 7955
FAX: 412 338-7130
0657 '103 C N Pit BLK
This law firm is a debt collector atte pt.'?g to collect this debt for
our client and any information obtain d 1.)_ be used for that purpose.
CapitaloW
what's in your wallet?
NOT PAYING YOUR DEBT 5=13
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 amtount due on your statement within 30 days to keep your acmum from being charged off.
500013-08503
® 2006 Capital One $crvica, Inc. Capital One is a frdrmUy redistercd service mark. All righn rzsrrrsrd.
Previous Balance Payments 6 Credits FINANCE
Trantsadiorts New Balance Minimum Payment Due Date
CHARGE
- $0.00
C$725
78D
+ $17.58
.36 Mar. 20, 2007
+ $29.00 = $772.36 $272
. .
2007 - Feb. 20, 2007
21
Jan Page 1 of 1 n6tse nor AT uFnsT tuns wtorxm
,
. Your account is six payments behind. If we charge off your account due to late payments, we will report the
st statement
MtaCard Platlnum Account
36 due
bbeeaa to o ally our outstanding balances. Act now to prevent this from happen Please pay the
l
f
your
o
on you r statement o give us a call at 1.800.955.8800. Well work with you so you can take contro
unnt Information account and start rebuilding your credit with Capital One.
TOTAL CREDIT LINE $500.00
TOTAL AVAILABLE CREDIT $0.00
CREDIT LINE FOR CASH $500.00
AVAILABLE CREDIT FOR CASH $0.00
for on)
Balance rate Periodic riling NCE
Finance Charges (Please sea rever7perW:28-15%
CO-SrR RGE
applied to rate
Purchases $675.86 0.077126.16
Cash $59.31 0.077121.42
ANNUAL PERCENTAGE RATE applied ® At Your service i4011403-3637
r to reports lost or sWw card
To all Customer Relations o
® send payments to:
Capital One Baik • P.O. Box 70881 • Charlotte, NC 28272.0994
A Send Inquiries to:
Capital One -P.O. Bar 30285 • Sao Lake Cry. UT 84130-0285
"Important Notice- Under the terms we previously disclosed to you, your account is nay eligible fir an increase
in Annual Percentage Raise (APRs) ertridive immediately. Hoeever, Cal" One has elected not to raise your
APRs at this time. Please be advised that if you fall to keep your account in good standing, Capital One reserves
the right to raise your APRs in the future.
Pavments, Credits dr Adiusiments
Transactions EE $29.00
1 20 FEB PAST DUE F
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 Wirt 7 business days for your minimum payment to reach
Capital One.
- Please Note - Some of the terms of your accourd are changing. Please reed the enclosed no ficatbn.
r-vulBff
1 7 20 070220 PAGE 1 of 2 OIBC6056
6056 506
PLEASE RETURN PORTION BELOW WITH PAYMENT
CaMAWOW I 0 5178052561500436 20 0772360733320272369
what's in your wall Account Number. 5178-0525-6150-0436
New Balance Minimum Payment Due Date
C$772.36 $272.36 Mar. 20, 2007
PLEASE PAY AT LEAST
THIS AMOUNT
Amount Enclosed
Capital One Bank Irlttl%IIIt IN lltlrrl
P.O. Box 70664
Charlotte, NC 26272-0664
Inltllnlutlrllualtalrllltell rl,ls,lultsllnltill llnrll
Meese print address or phone number changes below using blue or black ink.
address
Home Phone Amemate Phone
f-mail address ?
•90052960955834800 NAIL ID NUMBER
JUSTIN A DOBROWOLSKY
46 YOUNG CIR
NEW FLORENCE, PA 35944-6339
I LrdLLLldrtdtaLhdLtlrrd6att1161tttlralLdrtltrll
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.
JUSTIN A DOBROWOLSKY
I. Hour to Mold. RoWoe Champs. pen W of } e. fsraw MPwiomL Haut ? dw w rww Wrdv.r. rww 25
b~ weft-, naW .Parisi Par"' end new odw
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scads os wMr V. bmprtam Ndlos far payments belo4
and m lime for It to be osdrd by Your nor statement
closing daft. Then is rho pee Pealed m rash ad-
end Mw:w bnmaam. In addMem4 there e no grew period
on MV paysarae if you do not Pay
paIg Fli Charge- TranYCfma wMdh my not
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period in fro, fdWM CtdW • OWINsIll funs This
unp.id trine m,M Uft unpaid bwmoa is pad m
moans aw you may to owe hence sopea, s"en t You
pay tlo amw New Barhw Whayrd on",, ermt Of but did -rdo
For the the Pma. namWh pad - charges are added
a
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period or Yours
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armed is eh K8jdod ed ft a •whaa drpa. S nkhYOan Idal
F1WAMcE CHARGE of S6.60 vY be applied.
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dot to rwt assess bU.9 period.
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!Irony onew "for saw seomet. 'Aft add hp to mallr
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for
yours wu.L To gam V. dsW-for each segment 01
youayaae.wmksteebega"mnfb I for seen
segment end so my never transadeMl end My palodi"
tne. creep" O.Assdm a. WwAc-dayrs balmas for
VW seposr0. We #m eebaad arty psYmw "or t edtla
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pyre rritedry that segment of y
gives a Ins eePama day bbowt Nefor each w Bsle"lhoam on
yo,,, r.HIji;sw,Hyou pad 1h"
y or old senmwt in 0W er HYama row oserrst w
taro or . a eaYl eeow.), new Yamhaediorr, wifdt less to
Yam Pmadr a a spec el pumaee segmarr .m taw
to the day bsmor. We oaloeaU the *VOW* dab
been. by adding all the dally bawwes together end
dWW? T Olio Wet" Ytes tWlIfntmclaw" in the y chart dY
billing cyan.
==of des. biros byvo duly periodic nee and by 7.
days In te being P-- our b -sis"O on a
8.
day b ls or dw b ninMarm 6mmos dwge r mwrrnt,
tlea may be a v.rlen. b w~ IN. laliormlatl n and IM
.moum of burps OMW
3. Mnu.l Prtosarga RaftsRar" nrry "Fe's"
.. The ft. "Areal P.r=-P
as "APR" on fns Warr Of Oft "Mermen" LIBOR), C
b. it the cod. P (Duw" Pdma). L (Ousmrm'Y
(OrMriy CO), aft S Mwkc rd Prime) aPM•rs m the from
of Oft ststmrnt nee[ No tee Psrtoco man(s)' p"" Peebdk
rmr and corresponding ANNUAL PERCENTAGE RATES
MY very qu tft andrwy i narae or chaser bw dm
Wise ipp e f slitter. sw found in The W W Stets Joanel, Plus
lee ampere Preerualy drdos.d b you. The" drupes w1
be aSaedw m ft fan day of your b ling Period wmid by
Your pmoAe see mrd ending in the mosfr of Jsmrry,
ff # Apdi. oA and Oclobel Pray), F (MorMy LIBOR), or G
(Tmway LIBOR) app..- on ft Woo of yaw srftmme t
reed to the Pariodc rats(.), fee p.rioac mar. end
oweepmndmg ANNUAL PERCENTAGE RATES may vary
_,y and may swear or dsasasw brad on to card
Indbr, m fond In The Well Street JOt", ON the
mrrgin pnMoueN disclosed to you. Teas. dwVw ell be
sf.oisw m IM Ike dry of Your ON pwW swot month.
4. A...0111-It of Let" OvrgmH and Astrmrd Psyrasrd
Fey. Under to W" of Yom awns" agraemerf, w
resemw tee might b W" or not to SSW" any fe" *W o d
priornotloedm 10 YouwMwnwsulnt orright10 taboo It*
.I" or sml.rrr r a M rs-
trlarre T 6. pbt *mg YarAemrmL t e nrerer" fee ? ?
si a
on tee trod d yow gbe mrnt you t- 30 days r lift atWMM wes nesled to you so avoid Psyi g tee
tee a to htee such fee aa3tad to you it you anon your
aoaotmm WNWA having to pay- ---m* f -To
.,teal yo,,. aoow#. Yom mud mwffy m by slag aw
Grsomsrer Rsaforr Dope"-! and P•Y YoII"T w
B.imoe in ful(enhdbg Ow MWM-m *fw)prorr
fo end of ft 0frtyday Period.
ton d, HYalh Cow Yaw Account Vol Olm request to does yon
accord by oeling our Cudmw Rsl.foes DePSmaaem- Vau
mud destroy you Credit osrd(s) and accou. gauss O*d'6
omW es p.rmtlar?d bleg and asses, using Yom .
Nor your repast to des. H your consne, to Inm edor do
0o elder OW of a d.W bmimg to`W rivet
aandropen. of dep. Y- mcum wit not be dom d
Thy aanwd open Addihm yYoua
trantfolore; rr you have .uftOdawd, Mom cargos. Few du.
s taw, remmf leas, raamrrd P•ymem taw, cash atlvaaa
sir and eery Weer *m sa..essd to Your so"""t Yea am
added maporrbl. for thy. anrrr wlteites, ow al9 my"
soots" at the lima You requeo to doss the closet taor y
set atymred subsequent b Your mWest
This mmy _hM in drmgr "Pre mmg on yo.-mount err You
have mprsted the W-M to be dyed.
that Yaw AaoowL Yatr osrd or account 4. tr.d in
cp neclon with a" Inftmd B.rbW g
Node About Elsdrelic Chwk ConvONSWIL
When You Provide a deck as payment, you mtwtss r
sisw to rmM arfarnnaaon fnm yaw dlaaW to Its" a ase-O"
r yotr benk waceard or to propose
the payment es 0 dock bayadlmYAwr w use
M oft Wan you erok to Inssw m aletwonic fund
trammfer, funds may be wMtdrrm Wan your bank DWWM as
not recd" yam chock hack from yourArnds Inst"o t.
BALING RIGHTS SUMMARY
In Case of Enom or Ousellor¦ abadYaw BM)
yyo ft* yaw bM is ImIg, or f you need ?idamu SO soon All
ine s iabon or big. WIND to us on a "Pei"
pysiies at fw address for tmtghirrs shoat on the Warr of M
sfttsrnem. We must her Wom you no low fun 60 dsys after w
amt you des SM bill on "ffoh 1M error m problem eppwmed. You
fun csR or Cufwner Resod" rw mW. W doing so -Al not
pmessm yam ngNL In Your rtrr, gm us the following
kfmmatlar: yon rww Wd socomt reel~. the doW awm-t
of the suspected error. a description of the wor and an
emplenedw, R possible, d why you peeve two r an mw. or if
you need nee edarn abon.. desorption d the Ran you am
umre sbouL You domes have to psy ya onee, in q WAY'ms
.A& we me WtwMgalMg it, but you we
parr of yam bill 00 an not In *NOW. While w 1nvesig"
yer queerrb w osmd report you se defrawnt or our any
emdion r ibfe for Credit Card Pwdom
S. T Specie hew a Pmbl.am w
Rh 1M qusb of PmoprlY,mr!wkrs that
you ou p
y purchases wM+a oredh rem and you hew trod le 11"odht
r mind the ponsini vMh Ww merdtn, You mrro)' Ire fns ng rtpm
ptx pry was ono
not No ramsirarp rrw?t ckee on Ow V*WtY or
tha .
You h haw tlft fs tw WDMdiDn only than $50.00 and nd Wes p tadhr. sees made in your home seta a
vAmah 100 mom of your mw" odors. Of w caw a open"
to nwdrnt, or f w mWW your the aawmsee"m for fee
property or seNys, an Praehesss me covered regardless of
amaad a incision, of PuohW J Posse remember to sign all
owrowwwrrs.
T Doss not &A* to wnermrr non•mIdf cam arrows
Does rot-A*ID huekhetc rhOn-00 ll auk D"o"do
Capital Ons aWpoft inrrredw prNr.Y pmmreeWor: W our
wabalr d ym
capital Oro ts a fedaraly regtsrmd swww metro of Capital Onto
Fow KW Corporation. AN fens m amwed. 02006 COW One
OJBCWW-6-1212106
Ypeled Ilallea: Psynsr Yoe mti b u M r modal b yaa.omad r dlhe bhYetdrywreeke 1,1ne'ed (Il yah seed fee
bafan pawn afr atwtrhtad yee dad b I -dead wNdwaesit, sed (2) yumprymrrd. remind in wPmaoMYg Ims'
by 3 p.m ET (12 ram FIT). Pier Yoe 6tirt1M (R) Oudrw darifa teed d"wry lprpwae roan by us telm ofe leatlon win
any dlrfam mry re bloselad r sty dsYw w- arm. Orr burr drys ore Modry lha9h Se"Wey. swonrg Imo W""
Para do no e" sepia. pow dips, r:. sfir Pura; ' ye"pe""'
VERIFICATION
CAPITAL ONE BANK (USA), N.A., successor-in-interest to Capital One Bank
vs
DOBROWOLSKY, JUSTIN A
The undersigned does hereby verify subject to the penalties of 18 Pa.C.S. Section 4904 relating to unswom
falsification to authorities, that he/she is, TRACY TAYLOR, Authorized Agent, of CAPITAL ONE BANK (USA), thorized
this N.A., successor-in-interest tat f ? eth?e? ing Complaint m Civil Action areutrue and orrect?to the best of
Declaration, and that the facts set
his/her knowledge, information and belief.
TRACY YLOR
Notary Pub is
SHApON MUSENS
NOTARY SZAL
DEKALB COUNTY GEORGIA
MY COMMISSION EXP. OCTC3ER 16 201
5178052561500436
A049
WELTMAN, WEINBERG & REIS CO., L.P.A.
r.?
W C.
C .,
o 0
e -n
, ,
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77
0
SHERIFF'S RETURN - REGULAR
CASE NO: 2008-04339 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
CAPITAL ONE BANK USA NA
VS
DOBROWOLSKY JUSTIN A
MARK CONKLIN , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT Sc NOTICE
DOBROWOLSKY JUSTIN A
was served upon
the
DEFENDANT , at 0015:20 HOURS, on the 1st day of August 2008
at 366 STOUGHT RD
CARLISLE, PA 17015 by handing to
JUSTIN DOBROWOLSKY DEFENDANT
a true and attested copy of COMPLAINT & NOTICE together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing 18.00
Service 7.00
Affidavit .00
Surcharge 10.00
00
p/b5/bp 3? 5.00
Sworn and Subscibed to
before me this day
So Answers:
R. Thomas Kline
08/04/2008
WELTMAN WEINBERG & REIS
By:
- - 1' -17-,'?
eputy Sheriff
of A. D.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK (USA),NA
Plaintiff
VS.
JUSTIN A DOBROWOLSKY
Defendant
No.08-4339-CIVIL TERM
PRAECIPE FOR ENTRY OF JUDGMENT
BY CONSENT
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#06571703
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK (USA),NA
Plaintiff
vs.
JUSTIN A DOBROWOLSKY
Defendant
Civil Action No. 084339-CIVIL TERM
PRAECIPE FOR JUDGMENT BY CONSENT
TO THE PROTHONOTARY:
Kindly enter Judgment against Defendant, JUSTIN A DOBROWOLSKY, in the amount of $1134.36 plus costs,
based upon the consent of the parties.
CONSENTED TO:
WELTMAN, WEINBERG & REIS CO., L.P.A., JUSTIN A DOBROWOLSKY,
By:
Attc
Ww
r
By:
Defe t
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK (USA),NA
Plaintiff
vs. Civil Action No. 08-4339-CIVIL TERM
JUSTIN A DOBROWOLSKY
Defendant
STIPULATION OF THE PARTIES FOR PAYMENT
AND FOR THE ENTRY OF JUDGMENT BY CONSENT
TO THE PROTHONOTARY:
Kindly enter Judgment in favor of Plaintiff and against the Defendant, JUSTIN A DOBROWOLSKY, above-
named, in the amount of $1134.36 pursuant to the Stipulation of the Parties for Payment and for the Entry of Judgment
by Consent, as follows:
Defendant admits indebtedness to Plaintiff in the amount of $1134.36 with continuing
interest thereon at a rate of 6% per annum plus costs from date of judgment.
2. To secure the repayment of said indebtedness, Defendant agrees that Judgment by Consent will be
entered in favor of the Plaintiff and against the Defendant, JUSTIN A DOBROWOLSKY, in the amount of $1134.36
plus continuing interest thereon at the rate of 6% per annum from date of judgment and costs.
3. Plaintiff agrees not to execute on its Judgment so long as Defendant causes to be delivered to Plaintiff
the following payments in full by 12:00 NOON on the following dates:
(a) $200.00 due by 8/13/08;
(b) $200.00 due on the 13TH day of each consecutive month thereafter until the Judgment amount
plus accrued interest and costs are paid in full.
4. All payments are to be made payable to the order of "CAPITAL ONE BANK (USA),NA"
5. All payments due under this agreement are to be received at the offices of Weltman, Weinberg & Reis,
Co., L.P.A., 2718 Koppers Building, 436 Seventh Avenue, Pittsburgh, PA 15219. All future payments are to be
mailed to the offices of Weltman, Weinberg & Reis, Co., P.O. Box 5430, Cleveland, OH 44101-0430.
6. In the event of default, each payment received shall be first attributed to costs, interest and then to
principal.
7. Time is of the essence of this agreement and should the Defendant fail to have in the hands of Plaintiff
or Plaintiff's counsel any payment in full within five (5) calendar days of the stated due date, then Plaintiff shall be
immediately free to issue Execution as well as pursue all other remedies, in law or in equity, to collect the full balance
of the Judgment entered hereunder plus appropriate additional interest and costs.
8. No act or omission of the Plaintiff, nor of anyone alleged to be acting on its behalf, shall constitute a
waiver, estoppel, or any other excuse for non-performance of any duty undertaken by the Defendant in this Stipulation
which the parties agree is final and complete. y?
9. Intending to be legally bound, the parties set their hands and seals this L?day of
20 V
WELTMAN, WEINBERG & REIS CO., L.P.A.
By:
JAMES C 4kMBI
PA I.D. #4252
WELTMAN, INBER
1400 Koppe B ilding
436 Sevent Av nue
Pittsburgh, A 5219
(412) 4- 955
.06571703
By:
MOMMINLak
endant, JUS OWOLSKY
, Esquire
& REIS CO., L.P.A.
4.+ 02 ? r
o ?
c.rt
105,
c?
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK (USA),NA
Plaintiff
vs. Civil Action No. 08-4339-CIVIL TERM
JUSTIN A DOBROWOLSKY
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 $1134.36 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
( ) Default
( ) Verdict
( ) Arbitration
( ) Award
(XX) By Consent
Prothonotary
JUSTIN A DOBROWOLSKY
366 STOUGHT RD
CARLISLE,PA 17015 By:
PRO ONOTARY (OR DEP OA;25
-o.
,.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK (USA), NA
Plaintiff
vs.
JUSTIN A DOBROWOLSKY
Defendant
No. 08-4339-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) 434-7955
WWR#06571703
-i,:
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK (USA), NA
Plaintiff
vs. Civil Action No. 08-4339-CIVIL TERM
JUSTIN A DOBROWOLSKY
Defendant
PRAECIPE FOR SATISFACTION OF JUDGMENT
At the request of the undersigned attorneys for the Plaintiff, you are directed to satisfy the above-captioned
Judgment.
Sworn to and subscribed
before me this VIM
day, anuary, 09
_QAei? L.
N ARY LIC
CONNOWWALTH OF PENNSYLVANIA
Notarial Seas
Jennaer M. Borowski. Notary Public
Cfty of Plltabix", Allso" County
C=Wd9 n E!en Feb. 22, 2012
WELTMAN, WEINBERG & REIS CO., L.P.A.
By:
James C. armbrodt, Esquire
PA I. D. 524
WELTMAN, WEINBERG & REIS CO., L.P.A.
1400 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR #06571703
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