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HomeMy WebLinkAbout08-4804N IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA), NA Plaintiff No: Og ' q%oq Cwi VS. COMPLAINT IN CIVIL ACTION BARBARA GHAFFAAR Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: 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 06792604 C N Pit CFR IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA), N.A. Plaintiff VS. Civil Action No BARBARA GHAFFAAR 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 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. 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) 249-3166 COMPLAINT 1. Plaintiff, CAPITAL ONE BANK (USA), N.h.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: BARBARA GHAFFAAR 708 STANWIX CIR APT 1 CARLISLE, PA 17013 3. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXXXXXX1776 . 4. Defendant made use of said credit card and has a current balance due of $1269.28 , as of June 28, 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 19.900 per annum on the unpaid balance from June 28, 2008 . A copy of Plaintiff's STATEMENT is attached hereto, marked as Exhibit I'll, 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 , BARBARA GHAFFAAR , INDIVIDUALLY , in the amount of $1269.28 with continuing interest thereon at the rate of 19.900% per annum from June 28, 2008 plus costs. James C. WarmbrodtyX2524 WELTMAN EINBERG & REIS CO., L.P.A. 436 Se en h Avenue, Suite 1400 Pitts urg , PA 15219 (412) 434 7955 FAX: 412- 38-7130 067 2604 C N Pit CFR This law firm is a debt collector atteriptiAg to collect this debt for our client and any information obtaine w ll be used for that purpose. Cap talOne` NOT PAYING YOUR DEBT 5=13 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 fW 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 vnithin 30 days to keep your account from being charged off. O 2006 Capital One Services, Inc. Capital One is a federa4 registered service mark. All rights resrrued 500013-08503 FINANCE Previous Balance Payments 8 Credits CHARGE Transactions New Balance Minimum Payment Due Date $917.20 - $0.00 + $15.64 + $29.00 = $961.84 C$461.64 Mar. 03, 2007 f:• Jan. 04, 2007 - Feb. 03, 2007 Page 1 of 1 KEA% PAY AT uAST THS AMOUNT Visa Platinum Account 4862-3625.1543-1776 Your Account Information TOTAL CREDIT LINE $500.00 TOTAL AVAILABLE CREDIT $0.00 CREDIT LINE FOR CASH $500.00 AVAILABLE CREDIT FOR CASH $0.00 Finance Charges (Please see reverse for important information) Balance rate Periodic Co ng FINANCE applied to rate APR CHARGE Purchases $818.53 0.05452% 19.90% $13.83 Cash $107.14 0.05452% 19.90% $1.81 ANNUAL PERCENTAGE RATE applied this period: 19.90% Al-tS At Your Service 1.800955.7070 To cat Customer Relakns or to report a lost or stden card: ® Send payments to: Capital One Banc • P.O. Box 70884 - charlotte, NC 28272.0884 A Send inquiries to: Capital One - P.O. Box 30285 - Salt Lake City, UT 84130.0285 Your account is six payments behind. If we charge off your account due to late payments, we will report the charged-off status to several national credit bureaus, and the Purchase APR as reflected on this statement will be applied to all your outstanding balances. Act 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. 'important Nobce•• Under the terms we previously disclosed to you, your account is now eligible for an increase in Annual Percentage Rates (APRs) effective immediately. However, Capital One has elected not to raise your APRs at this time. Please be advised that M you fail to keep your account in good standing, Capital One reserves the right to raise your APRs in the future. Payments Credits 8 Adjustments Transactions 1 03 FEB 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 still be eligible for benefits to be paid to your account for loss events described in your Payment Protection agreement. Call Stonebridge Benefit Services at 1-888-527.6904 to seed your situation qualifies for benefits. You were assessed a past due fee because your minimum payment was not received by the due date. To avoid this fee in ft future, we recommend that you allow at least 7 business days for your minimum payment to reach Capital One. - Please Note - Some of the terms of your account are changing. Please read the enclosed notification. qtr 6056 506 1 7 3 070203 PAGE 1 of 2 OIBC6056 PLEASE RETURN PORTION BELOW WITH PAYMENT 0 4862362515431776 03 0961840075000461847 ?° what's in your wall Account Number: 4862-3625-1543-1776 New Balance Minimum Payment Due Date C$961.84 $461.84 Mar. 03, 2007 PLEASE PAY AT LEAST THIS AMOUNT Amount Enclosed Capital One Bank P.O. Box 70884 Irlrrlllrrrrllrrrrlrll Charlotte, NC 26272-0884 LdrlLrLrddlrrxL•IrIllrrr6rhlrrLJrJLJrrlrrlhrrll Please print address or phone number changes below using blue or black ink. Address Home Phone Alternate Phone E-mail address @ #9003590983077486• MAIL ID NUMBER BARBARA GHAFFAAR 337 AMY DR CARLISLE, PA 17013-6810 nrlllorlllunnllnllrlalrlnlunlllluuulllnrlullr 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. BARBARA GHAFFAAR 1. Horn to Avoid a Finance Change. t a. Grace Period. You "I have a minimum grace period of 25 days without fiance charge on new purchases, caw balance transfers, new spedal purchases and new, ocher charges It you pay your total 'New Balance, in accordance with the Important Notice for payments below, and in fine for l lo be credited by your red statement dosing deal Thera s no grace period on rash advances and special berhefem. In addiion, them Is no pace period on any unrsaciion if you do not pay the total -New balance." b. Accruing Finance Charge. Transactions which are not suh)ed to a grace period are...... W finance charge 1) from the date of to i arsisctionn or 2) from the data the transaction is processed to your Account or 3) from the first calendar day ot the cement boiling period. Additionally, If you did not pay the -New Belari from the pryilow boiling period in full, firsnce charges continue to accrue to your unpaid balance until die unpaid balance is paid in full. This means that you may, aadd owe fnerce charges, even l you pay the entire New Balance Indicated on the front of your statement by the nerd smmme d closing date, but did not do so for the previous mcnth. Unpaid force charges am added to the applicable segment of your Account, t c. M innianm Finance Charge. For each billq pointed that your account is n11}ad to a tnerce charge. a minimum total FINANCE CHARGE of SO.50 will be Imposed. t d. Temporary Reduction In FTearhce Charge. We reserve the right to not assess any or all hence charged for any given billing period. 2. Average Daly Balance (I nchMing New Purohasil Finance charge is calculated by multiplying the dry balance of each segment of your account (eg, cash advance, purchase. special tranal and special purchase) by fie cona spo dirg dry periodic rote(s) ther has been previously disclosed to you. Al the end of each day ding tone 6ilng period, we apply the dally perludit rate for each segment of your account to am daily balance of each segmast. Than at to end tithe bill perfce, we add up the results of theta dry calculations to arrive at your periodic Amerce Berge for each segment. We add up the mails from each segment to arrive at the total periodic frnance change for your account To get Me dally balance for seen aegmem of your amour, we lake 2. begairki bWnae for each segment and add any newtrwacaon and any periodic finance charge calculated m the previous days balance for that segment. We than subtract arty payments a credhs pealed as of tW day that am allocated to Mat segment. This gives us the separalo daily balance fa each segmarrit of your account. However, If you paid the New Balance shown on your previous statement In hill (or It your new, balance was zero or is a ilk amours), new hansacicr e, which post to your purchase or special purchase sagmerts am not added to the dally balances. We calaaats fie average trolly balance by adding all the dally basncec together and dividing the sum by the number of the days in the current billing cycle. To calculate your total finannce charge, multiply your average daily balance by the daily periodic rate and by the number of days in the biling period. Due to rounding an a daily bass or due to minimum finance charge assessment, there may be a variance between this calculation and the amours of finance charge sctudy ass road. 3. Annual Percentage Rates (APRJ- a. The term'Annuef Peroerdage Rate'rtey appear as 'APR' on the from of the statement b. If the code P (Ouarteriy Prima), L (Ouarterly LIBOR), C (Quarterly CDC or S (Sw*..rd Prime) appears on the Root of gds statement nest to the periodic aisle(s), the poniodic rated and corresponding ANNUAL PERCENTAGE RATES may wry quarterly and may increase or decrease based m the slated indices, as fazed in The Wall Street Journal, pus the mange previously disclosed to you. These ranges will be effective on ft fired day of your bgimg period covered by your periodic statement ending in the months of Jarwary, April, July and October. a If the coda D (Monthly Prima), F (Monthly LIBOR), or G (Treasury LIBOR) appears on the front of your simmers nod to the periodic rate(s), die periodic rams and corresponding ANNUAL PERCENTAGE RATES may vary monthly and may Humes or dacresas based on rte stated Indices, as found in The Wall Street Journal, pus the margin previously disclosed to you. These charges will be etectlve on the first day of your billing period each month 4. Assessmend of Lists, Ovw%mk and Ranmad Paymsrd Facts. Under the terns of your ctrsomor egresman, we reserve the ripld to waive or not to own arty Idea; without prior notification to youwithoulwaivi g ourdgfht to assess the same a simlarfees at a latertime. t S. Rersalg YourAmomd. If a membership fee appears on the from of your statement, you have 30 days from the date ttaa statement was mailed to you to avoid psysg to fee or to haw such fee credited to you 6 you cancel your account will having to pay the membership fea. To cancel your accent, you must notty us by calling our Customer Relation Department and pay your New Balance' In ill (excluding the membership fee) prior to the end of the thidyday period. 6. If You Class Veur Account. You can request to dose your account by calling our Customer Relations Department. Voce must destroy your co& card(s) ape e.-.t access dada, ravel all pmaut prized billing and ceeae using your account After your request to close, if you contlme to transact or do not cancel preeuncdaed telling manger ems, wa we consider receipt of a charge your asc horbadon to keep your account open. Additionally your account will not be dosed until you pay all amounts you owe us including: any transaction you have authorized, than charges, past de fees, ovedimk fees, returned payment Ii an adv-. fees and any other loss saaessed to your account You am responsible for these amounts whethar May appear on your around at the time you request to dove the account or they am narmd subsequent to yaw request to dose the account. This may recut in charges appearing on youraccourht after you haw requested the asp 1 to be doted. 7. Uafng Your Account. Your card or account cannot be used in connection wlh any Internet g"Ifing trensocUOns. 6. Notice About Electronic Cheek Conversion. When you provide is check as payment, you authorise us either to use imormetion from your chock to make a one-time electronic fund traMerfran your bank a co id or to process the payment a e Medic transaction. When we use information from your check to make an elections, Mal transfer, funds my be wordrewn eon your bank account as scan as the same day we receive your payment, and you will not receive your check back from your financial Institution. BILLING RIGHTS SUMMARY (In Case of Emem or Oieofiww about Your Bill) If you chink your bill is wrap, or If you need mm info n. ation on a tmnciscien or bill, wrta to ce on a separate sheet sc soon as possible at the address for inquidx shown on the front of this statement We must hear from you w later there W days after we awl you the first bill on which the error or problem appeared. You can call our Customer RetNon$ number, but doing w will nor preserve your rights. In your letter, give us the following kdormation: your name and account number, the dAW amovn of the suspected error, a description of the error and an explanation, if possible, of why you bellow there is an arson, or t you need more information, a description of the item you am unsure about. V do not have to pay any amount in qu etion while we are Investigating h, but you are still obligated to pay the parts of your bill dear are not in question. While as Invesagas your question, we caonot report you as detinquem or take any action to col I the amount you question. I. T Special Rule for Credit Card Purchases if you haw a problem with the quality of property or services that you purchased with a credit card and you have tried in good huh to correct the problem Mtn the merchant, you may hew the rags not to pay the remaining amourn duo on the property or.erMcae. You have this protection only when the purchase price was more than $50.00 and the purchase was made In your home state or Milan 100 miles of your mailing address. (If we own or operas per merchant, a t we nnled you the adwrdsenant for the property or services, all purchases we covered regardless of amount or location of purchase.) Pleaas remember to sign all comespondence. t Does not apply to consumer noncredit card accounts Does not apply to buske.s rercmdft card account. Capitol One supports information privacy protection: we our wabs he at Wwm esptUODM. . Capital On Is a federally registered service mark of Caplal On Financial Corporation. AN rights mderved. O 2005 Capita One 01806656-6-12ai N6 Imported Ndlp: Paymess you mall lo as wd be aedM b your account as of the sales days me" IL provided! (1) you sad the bobenn potion of tits atsamnt and your dledt in the arndwed amaanm envelops and (2) your paymart's mooed n scar processing comer by 3 pm. ET (12 axon FT). Phase alowatlead fle (5) hudms days for postal delivery, payments anted by us of dry ova lcm6nn or in my enQfonrn may not be i adsd nclass day we make tam. Our business drys as Monday through Saba. esdldYg hmldays. Please do eat use sbplon, papercips, at. wile Wee- g your paymed. A VERIFICATION CAPITAL ONE BANK (USA), N.A. vs GHAFFAAR, BARBARA 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, TRACY TAYLOR, 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. TRACY TAYLOR Notary Public 4862362515431776 A049 WELTMAN, WEINBERG & REIS CO., L.P.A. t "' 1. 29, 201 70 A-3 00 W r ca ? -La- "'t" ? ;'. ? ats Ln r , ,. zx r :? r ? f sDg? D r . ? ? 0 SHERIFF'S RETURN - REGULAR CASE NO: 2008-04804 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CAPITAL ONE BANK USA NA VS GHAFFAAR BARBARA MICHELLE GUTSHALL ISheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOVICE was served upon GHAFFAAR BARBARA the DEFENDANT , at 0008:00 HOURS, on the 16th day of August , 2008 at 708 STANWIX CIRCLE APT 1 CARLISLE, PA 17013 SALAHADEN GHAFFAAR by handing to BAND OF DEFENDANT a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing is attention to the contents thereof. Sheriff's Docketing Costs: 18.00 So Answers: Service 5.00 Affidavit Surcharge / g14lD9 01? .00 10.00 .00 R. Thomas Kline 33.00 08/19/2008 WELTMAN WEINBERG & REIS Sworn and Subscibed to By: before me this day Deputy Sheriff 0 f A. D. I. % IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA), NA Plaintiff vs. BARBARA GHAFFAAR Defendant No. 08-4804 CIVIL TERM PRAECIPE FOR DEFAULT JUDGMENT 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#06792604 Judgment Amount $ 1,312.27 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 (USA), NA Plaintiff vs. Civil Action No. 08-4804 CIVIL TERM BARBARA GHAFFAAR Defendant TO THE PROTHONOTARY: PRAECIPE FOR DEFAULT JUDGMENT Kindly enter Judgment against the Defendant, BARBARA GHAFFAAR above named, in the default of an Answer, in the amount of $1,312.27 computed as follows: Amount claimed in Complaint $1,269.28 Interest from June 28, 2008 to October 07, 2008 at the legal interest rate of 19.90% per annum $42.99 TOTAL $1,312.27 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: (/",,, William T. Molczan,);squtre PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#06792604 Plaintiffs address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 1400 Koppers Building, 436 7 h Avenue, Pittsburgh, PA 15219 And that the last known address of the Defendant is: 708 STANWIX CIR APT 1, CARLISLE, PA 17013 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA), NA Plaintiff VS. Civil Action No. 084804 CIVIL TERM BARBARA GHAFFAAR 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 $1,312.27 plus costs. ( ) Trespass Judgment in the amount of $ plus costs. ( ) If not satisfied within sixty (60) days, your motor vehicle operator's license and/or registration will be suspended by the Department of Transportation, Bureau of Traffic Safety, Harrisburg, PA. (xx) Entry of Judgment of ( ) Court Order ( ) Non-Pros ( ) Confession (xx) Default ( ) Verdict ( ) Arbitration Award Prothonotary By PR HONOT (OR PUTY) BARBARA GHAFFAAR 708 STANWIX CIR APT 1 CARLISLE, PA 17013 Plaintiff's address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 1400 Koppers Building, 436 7U' Avenue, Pittsburgh, PA 15219 1-888-434-0085 IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA), NA Case no: 08-4804 CIVIL TERM Plaintiff vs. BARBARA GHAFFAAR Defendant 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, BARBARA GHAFFAAR 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, BARBARA GHAFFAAR is not in the military service. Further Affiant sayeth naught. SWORN of /U AFFIANT BED in my presence this dad . 1" day NO ARY ti Or PENNSYLVANIA P coromo rALT Notan,-M Seal Public LC1tyV\ endy L. Gault, Notary Of Pdtsburgh, F heny County ommis sion Exhirl S ..luly 15, 2010 of Notaries Member, E'ennsytvan ?^ >?'ation 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 40 Military Status Report Pursuant to the Servicemembers Civil Relief Act Page 1 of 1 RJL-02-2008 12:34:11 'K Last Name First/Middle Begin Date Active Duty Status Service/Agency GHAFFAAR BARBARA 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. Abut -40?014- 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: htip://www.defenselink.mil/faa/Dis/PC09SLDR.htm1 WARNING: This certificate was provided based on a name and Social Security number (SSN) provided by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID:BKBSWBUYHAU https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 7/2/2008 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff Case # o?- Ovll-kq BARBARA GHAFFAAR Defendant(s) IMPORTANT NOTICE TO: BARBARA GHAFFAAR 708 STANWIX CIR APT 1 CARLISLE,PA 17013 Date of Notice : I? WWR#: 06792604 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 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. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 J? /?4flW?ej4 1805'"_ BY. PATRICK THOMAS WOODMAN PA I.D. #34507 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 KOPPERS BLDG, 436 7TH AVE. PITTSBURGH, PA 15219 ? n v n C=n c; -,+ •• C:3 =ry CD