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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 chrges R yw Pay yrwr steel 'law Baeny", in 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 woo F.rnw b. Ab)sct r • g ray peri perked od ors asawe.d frymxa ermg" 1) from ft der of on "r eamion or 2) Wam 00 d0le M" w...dion is prooes"d to yon A o-m or 3) Wan the fiat ,eider dey d fro orlleht beat m jMW. AdmWbyrY, V You bllfirg did net pry the Tlew SeWhy" rpm cram 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 so For .ious W of to tiro en Rusbr pPmSe Fm each ,Aa000 billing m. period or Yours } c YMknua to Aarg"• armed is eh K8jdod ed ft a •whaa drpa. S nkhYOan Idal F1WAMcE CHARGE of S6.60 vY be applied. } d. Temper" or all ,. my fktance charges vft for MY Oren dot to rwt assess bU.9 period. 2. brag. 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We #m eebaad arty psYmw "or t edtla if our until you psy so amounts ts 1ou our es odm mar and 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 , , ? J 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 S `r, rrl