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Home My WebLink About08-5077J, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA), NA Plaintiff No. S7677 U L VS. CHRISTOPH A EDWARDS Defendant COMPLAINT IN CIVIL ACTION 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#5996964 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA), NA Plaintiff VS. Civil Action No. CHRISTOPH A EDWARDS 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 23059. 2. Plaintiff is a corporation with offices in 140 EAST SHORE DR GLEN ALLEN, VA Defendant is an adult individual residing at 111 HERSHEY RD LOT S SHIPPENSBURG, PA 17257 3. Defendant applied for and received a credit card issued by Plaintiff bearing the account number 4862362560974530 . 4. Defendant made use of said credit card and has currently a balance due and owing to Plaintiff, as of JUNE 24, 2008, in the amount of $1,708.57. 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 that 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 demands Judgment in its favor and against Defendant, CHRISTOPH A EDWARDS individually, in the amount of $1,708.57 with continuing finance charges thereon at the rate of 25.90% per annum from JUNE 24, 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. JAMES C. BP PA I.D. #4 52 WELTM N, W INB. 1400 Ko pers B ildin 436 Sev nth Av nue Pittsb , P 15219 (412) 4-7 5 , Esquire & REIS CO., L.P.A. WWR#:5996964 Q-11FI wo $G' whaft lnyoar wum?* Your account is about to charge off as a bad debt. • We report an R9 rating to credit bureaus when an account charges off. • Lenders and employers nationwide can access credit bureau reports. • An R9 will limit our ability to offer you financial solutions. • You will still be responsible for repaying the debt. The purpose of this letter is to collect a debt Arty iilormation obtained will be used for that purpose. O 2004 Capital One Services, Inc. Capital One is a federally registered service mark. All rights reserved. 045-0404 /Cw• Account S Previous Balance $894.72 Payments, Credits and Adjustments S.00 Transactions $29.00 Finance Charges $19.90 New Balance $943.62 Minimum Amount Due $943.62 Payment Due Date February 17, 2006 Total Credit Line $500 Total Available Credit $.00 Credit Line for Cash $500 Available Credit for Cash $.00 PLATINUM VISA ACCOUNT 4862-3625-6097-4530 DEC 18, 2005 -JAN 17, 2006 Page 1 of 1 Payments, Credits and Adjustments Transactions 1 17 JAN PAST DUE FEE $29.00 Your account has recently been past due, overlimit, or has had a returned payment. We request that you keep your account in good standing. We value you as our customer and appreciate your business. Thank you for choosing Capital One. This account's Non-Introductory Rates as of 12/20/05 are: purchase A.P.R. = 21.3096V, rash advance A.P.R. = 21.3096V and special transfer A.P.R. = 21.3096V. If the A.P.R. is followed by "V," then your corresponding A.P.R. is a variable rate. You were assessed a past due fee of $29.00 on 01/17/2006 because your minimum payment was not received by the due date of 01/17/2006. To avoid this fee in the future we recommend that you At your service allow at least 7 business days for your payment to reach Capital One. /J ^ /n/ &q To all Customs Rdstions or to report a lost or stolen card: 5 1 lA1 Iv 1-800-955-7070 1 Send P ymsns to: Send inquiries to: Ann: Remittance Processing C.pinl One Back Capital One P.O. Bak 790216 P.O. B. 30285 St Louis, MO 63179-0216 SLC, UT 84130-0295 Good news - it's not too late. • Call s48oo-955-66oo for payment options. • Pay with our free Chedc by Phone service. • If you have online account access, log on to your account and pay now at www.capitaione.com. • If you prefer, simply use the remittance coupon below. ??/t sYl l F-manse Charges Pkase sm rmntetide for important infarmatmer Ba r,?r ?g MUSE pptvdto ratr PURCHASES $790.36 .07096% 25.90% $17.39 CASH $113.94 .07096% 25.90% $231 ANNUAL PERCENTAGE RATE applied this period 25.90% PLEASE RETURN PORTION BELOW WITH PAYMENT Q*101 ow 0000000 0 4862362560974530 17 0943620000000943620 New Balance $943.62 Minimum Amount Due $943.62 Payment Due Date February 17, 2006 Total enclosed $ Account Number. 4862-3625-6097-4530 Capital One Bank P.O. Box 790216 III111'1Illtlrr11rr1r1 St. Louis, MO 63179-0216 11111aIIIII I IIIIItttIItIIIIlraurl,lurl6llnurl6ILt6rl,l Gry Sore ZIP Home Phone Alornete Phone #9001848941072375# MAIL ID NUMBER CHRISTOPH A EDWARDS 2004 PHILADELPHIA AVE r LOT 42 a CHAMBERSBURG PA 17201-1463 P! -prior sr a ., ad&-a and,6, -..W b-r, belom-mg blur a Mani mk Saeet Apt / r Pleare write your account number on your dick or money ardn mart payable to Capital One Bank and mail in the enclosed envelope. 8 O? o nu? .- r N . Now To Avoid A Firm- . periodic rate. To obtain the average daily balance for the your amount if it has already been closed. For example, = a. grass Peeled. You will a miniman grace period of biRinp pad covered by thin statement, we take the ba if you authorized a purchase from a merchant and we 26 days without firwrce charge on new purchases, new balance inanstes, new special purchases and new other " lance of each segment each day, add any hew 6epkrwp transactions to sech sera: and wbtract any paMn receive the trareecdon from the merchant after your account has been closed, Your sccaem wiR be recpared, ql M dded t our accourt f he a Now Balance , in degps if you pay yar renal or credits. Ilf the code N apPaars m the horn of this ' a , t c rpe w o y the smaam o If I f h eccorNnce M h the Important N,Itice for payments below, Baience Rare Applied To: vw ales statement new to or piii;n t ere s a and you will be reaparWda and In tine for it to be credited by your next sutearem drrge Included in the 1- oumrea any unpaid finance membership fee for yae account, the fee will contkoe dreeg date. There is m gtace period on cash adrurcea of ot each sep?m 1 TNs gives os the daily bell. each dd all the balances for each Ti to be ch , to the a cold peirted by law, urW accost balance Il been paid m in AM as defined abothe ve and npeda. trsrrtere. in aoldltion, they u no grace period on eery vwrsaieh if you N het pay the tom 'New en, vw a eeprnem. up = seprnen for the bilflrg pod end divide by the total eri . 7. lutip Vac Asewat.Yau cad or account cannot be W Wince.' periae. This puss os the nnnbar of days n tie biNkp used hh cotrhsetion wmi, any Internet gambling h. issuing flhaea pwnga. Transschlorn winch are riot aulhject to a grace period ors messed firwhce Gharge 1) average dally bslrxte of Beth asPmoxn. 3. Mtol Paaertp Iptes fAPRI. trerrection. R. Molise Not Elsobsis Orok Colwarad n. When you horn the dare ot the tramsction or 2) from the date the a. The term 'Annual Percanape Rare' muY appear as provide a deck as psymant, you authorize us char to transaction is processed to your Accent or 3) from the 'APR' on the from of this stmme.. use information from Your check to make a roe-time fins calendar hay' of the arrant bilkng pedod. Additionally, b. If the code P (Prom), L (3-mo. LIBOR), C iCertificav of alectmac krnd trammel from your bank amount or to If you did het pay the 'New Balance' from the prawns hieirhp perictl n hs, flnsnce tluryps mmkae m accts to Deposit), or S (fienkcaN Pans) appesre on the feat of tlaa nmehtem next m the periodic rme'a), tie ludic prooees tie payment n a deck transaction. When we cage In;== Gram Yam check to make an electronic idd b k f f d b ft t yyoouur uysid bsiarnce udl the unpaid baance I. paid hn full. even if owe finance riurges TMs mane that " rates and mneaoorn.di7 ANNUAL PERCENFAGE RATES mry very gwrtsdy and may Inc se or decrease based e w rawn - ywx an uba trans er, un s may accoun as soon as the ssme day we receive your , you pay the entiirhdicated on the front of =W. - on the sated Ihdicas, es loud in The WsN Slrsar peymeM, and You! will not reuh m your check back from your steamer by ihe text staramoxt coairg date, brr did E Jounsl, pis the margin Previously diwaosed io you. Ymur fimncial ireounion. N se tar the pravfoos month. Urpsid flnsnce charges These chnhgas wifi W etWdw on the Rest dry of your ate added m the appgC?le sepnem of Your Account' bluing period coveted by your pedodc statement ending BILLING RIGHTS SUMMARY tc. tlfitrktrer Fieaase Qrgs. For arh bluing pedod that the marls January, April, Jrlyy and October. 1 LIBOR 0 (3- P F i (in Gee Of Errors Or Questions Abort Your Bill) ou need more our bill a rvnonn or If If ou think your account Is sd*W to a finance durge, a minimum totai RNANCE CHARGE of $0.60 will ba imposed If the round finance doge from the on. Your mo. ) or c. If the rode 0 ( me), -mo. 4 r LIBOR Repriced Monday) e m on the from of your meemant mm to the periodic ntels), the Periodic rates p, Y y y infor--ion on • transaction or hifi, wee to us an e ""raft sheet as soon as passible at the address for periodic ree(s) a I- than 30.60, we 11 ubtsct that and mneapondinhp ANNUAL PERCENTAGE RATES may irqudes shown an the imt of this sm erant. We must amount from the $0.60 mkdmum and the diffe-ne will be vary mastay std may inoreass or decrease based on tie hear from you no later tan BO days after we set you the biked m the pucMse se?nert of your amours. 1' d. Tatgasy RMMton in FYssws Ora We rexrve the arced khdcw, as lard M TM Wend Shea Jotesl, plus the marpn preMounhy difdosed to you. These Wrhpee And bill on which the error or problem appeared. You can call our Customer Rcetiore nrnWr, bra doing ao wig not right to not sssess any or all finance charges tot any given i d will be effet'tlve on [he fins day of your billing period each march preaerva your rigiss. M your utter, pot os the kabwinp the drtlar mmrtmalbre your mnna and accart number bieitq per o 2. Aneaga Dally Besrw Ikskrding New Purdrssssl. . 4. Ass ammo t of Late, OvremB and Reined =F. ns. , :mourn of the suspected error, a description of the error a. Fkhahce carpe Is calculated by multiplying the dally Your account will be assessed no more then fees and an expurstlon, if p=, of why you beibve then Is balance of each seg-ra of your .,morn le.q., cash limed here that omur during any billing period. Under the an cane, or it you rased more ntemutim, a description of dverxx, purchase, special trareter, and spade) purdeaeI 'ems ot you r ,os omer agreement, we "I'm the ripe to the item you are ue ms sbou. You do not he" to pay any by the cerrosparhoig dally periodic relNsl that has bamh to waive or not to amass any tees without prior notificat iionu s amour in question vdals we as invasdpatlq t, but you ar dlL that ere not th at till di ud [ the PreNed Y dimmed to you. At the and of each day during h v te d l h d il i di r m you M[heur waiving scar rigls to assess the name or Res ar a cairn time y are s a w o pay pa we tarot YYldb we investigate , question in question c re r eac the NWg petlo . owe app y t e a y per o esgrnea of your ecrnut to Me uisRy Wumce of each dd f he bin ri d Th he d . 6.tRsrsrNrp Ysr Aeaut. If a memWMlp fen ose on to Gras of this stehsnorn you have 30 a , . report you es deerhquan or cake any adlon to collect the arnars You q-oim. up t rg pe o , we a segment. en at t en o the metals of same dally calculations to ardw at your periodic finsrhu charge, ton each wquhart. We add up the M , pp cep horn the date Ws mstemen was mailed to you to avdd paykg the hs or to Mw wash fio credited to you t,t Spedn Rule For Credit Cam Purchases . periodic resets frost each e g. to arrive m the if you urhM yar aecwnt. During thiT4% you may finance charge for Yale smara. To = , Nay Wlarhca oontlree to ass Your amount w/mdn pay the If you Mve a problem with the quality of property or for each septet of, ., the bagiming . ma6WMip tee. To ce-W your amour, yon must services that you purchased with a credit cant and you balance for each segment and add any new trensectias rnotliV u by celgnp our Customer Reietiare Depervent ' Mve tried in goad fslm to torreot the Problem wadi the and airy ppeariiodic firhrhce dhege celoxlmed on the Previas than a61tec st f than nt W ha ' b ( M kal (exdu ding the and pay you New Bdsnea fee) prior to to and of to ihirtY-Ny ppd members x nrhemthart, You may have the tips raw to pay the -Ar l i Y h hi ry aree or segme . e y s a pw w nadirs ported an of that clay gut an dlecated to tatyma sepmrs. Tale pots m the gepeme Nfilance id the H if V' f p . 6. N Yom Clow You Aeeaat. =m mn request to dose your amwt g our m Relatlae our credit caNle) end Y%= desw arbnem aw t amount due on to property or serv ces. ou s pmadion orsy when the Par se price urea more then $60.00 and the I...z. wss made r your home arm, or owever, ' pa for each sepnam o your accouas. New Balance shown on your previous stmemnt in lull (or y y . account access decks, caned all p-danized bflflrg, within 100 miles of Your m IWV address. (If we own or operas the merchant, or If we mailed You the it your new balane wss zero or a credit amount, new rid cease Ueng Yaw amour. N You N ant carncd advemam rt for tie prapeny or setvicw, NI purdssen ttaneaCliom Mach poet to your purchase or apadd preeuried: ernrhganeMS,.ve will consider mverod regardkw of amoran or bratbn of purchase.) puroiess seprwtts as not atldsd to ihe daily balames. We receipt d a dugs yar authorizaoon te reopen you please remember to sign and correspondence. uloxaate the average daily balance by adding all the daily emourtl. Additionally, your account Me not ba d Wasd be, of 1,11%; tep ,std claT the wan bV tie - ss indudrq: any all until you pay = 1"'A t goes mot -Ply m censorrrner non-credh cell -counts your total the Np in the cures bfifln To ulW cycle. sm finerhce charge, mcdplyy your avere(p daily baience by the Nily c ma and by the nunbar of Np in the billing ed, finsnce dupes, gam u hamacr ms you 1 due fees, overgmh feel, mumed payment fees, cash advenee lees and any afar few aaeeesed to your t flies not apply to badness none edix cab xcornts pe Due to mndirg on a daily bass, then may be a sight vadance between this calc latim and the amount of accent. You are responsible for these a= Mheher [hey appm on Vona secant at the time you requrere to Cepim One wrPPOSS infameion privacy protection: see our finance dsrge aauN1Y sssewd. I- If the code 2 or N appesn m t - frost of thin ..,-a. dose the sworn or they are inaxned a6sequeru is your requee to dose the account. This may ream 1n wale. m wow. lone.com. 0 red Ors is ¦ rely registered service mark of Capital .e Financial Corporation. AN rights reserved. o 2003 text to 'Balance Rae Applied To,' we mddply the _. __- -- -._.._ In derges appesrinp on your sccaum after you have .........o .w_ _......,,,».,, ti ..n....,r ,,, rn,. ,?...n,y„n ..r Capital One OILGLBAK Irrportst MoNes: Paymets you mss m os MN W credited to your ran s of the business day we receive it, prowdad 0I you send the bottom portion of this stateme a and your deck "naaing owner by 3 P.m. ET 02 nosh PT). Plow allow at Ian five (6) busirms dap br posW delivery. In ::.W=,= irtsthce and (2) your payment is received In 'sap Peby os m any rxhm location or in any otter form my non be credited as of the Nyy rm aiwe them. Our I n all dap an Monday through S day exdudiro hdidep. Please do not use maples, paper di mc.suwlen preparing Yee payment. When yy?o0u1n send os e dnekla), you authod:e os to make a one-time electronic trensur ebro fmn your bank account for the amount of the check This thorixarun applies to ass docks received dudng tha billing cycle even if gent by mean else. If we canvhot P. ft transfer, you authorize rot 10 make a charge against you bank account using the disk, a paper draft or other item. VERIFICATION CAPITAL ONE BANK (USA), N.A. vs EDWARDS, CHRISTOPH A The undersigned does hereby verify subject to the penalties of 18 Pa.C.S. Section 4904 relating to unworn falsification to authorities, that he/she is, 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. T CY TAYLOR I Notary Public 4862362560974530 A049 WELTMAN, WEINBERG & REIS CO., L.P.A. pia<A ?r.'.GIA MY CUMMISS' a, S OCT. 29.2011 i o ! . - T _n `w J w\ ? V ti ..? 6 SHERIFF'S RETURN - REGULAR CASE NO: 2008-05077 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CAPITAL ONE BANK USA NA VS EDWARDS CHRISTOPH A STEPHEN BENDER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon EDWARDS CHRISTOPH A the DEFENDANT , at 0945:00 HOURS, on the 3rd day of September, 2008 at 111 HERSHEY ROAD LOT S SHIPPENSBURG, PA 17257 TERESA SHEW, GIRLFRIEND a true and attested copy of COMPLAINT & NOTICE by handing to together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 20.00 Affidavit .00 Surcharge 10.00 ??(URIU? ?" 00 48f00 Sworn and Subscibed to before me this day of , So Answers: R. Thomas Kline 09/04/2008 WELTMAN WEINBERG REIS By. puty Sheriff A. D. 46. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA), N.A. Plaintiff VS. CHRISTOPHER A EDWARDS Defendant No. 08-5077-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 Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#05996964 Judgment Amount $ 1947.40 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), N.A. Plaintiff vs. CHRISTOPHER A EDWARDS Defendant TO THE PROTHONOTARY: Civil Action No. 08-5077-CIVIL TERM PRAECIPE FOR DEFAULT JUDGMENT Kindly enter Judgment against the Defendant, CHRISTOPHER A EDWARDS above named, in the default of an Answer, in the amount of $1947.40 computed as follows: Amount claimed in Complaint $1708.57 Interest from JUNE 24, 2008 TO NOVEMBER 28, 2008 at the legal interest rate of 25.900% per annum $238.83 TOTAL $1947.40 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: "X4?z -- WILLIAM T. MOL AN, ESQUIRE PA I.D.#47437 Weltman, Weinberg & Reis Co., L.P.A. 1400 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#05996964 Plaintiffs 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: 111 HERSHEY RD LOT S, SHIPPENSBURG, PA 17257 IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA), N.A. Plaintiff VS. CHRISTOPHER A EDWARDS Defendant Case no: 08-5077-CIVIL TERM 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, CHRISTOPHER A EDWARDS 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, CHRISTOPHER A EDWARDS is not in the military service. Further Affiant sayeth naught. AFFIANT S TO D SUBSCRI in my presence this 2 day of ?. COMMONWEALTH OF PENNSYLVANIA Notarial Seel N ARY L I C jennder M. Borowski. Notary Public City of P+taburyn, Allegheny County ComnNssbn Feb. 22, 2012 member. Pen A000111 n Of rieS 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. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff Case # t??? ?• `'t CHRISTOPH A EDWARDS Defendant(s) IMPORTANT NOTICE TO: CHRISTOPH A EDWARDS 111 HERSHEY RD LOT S SHIPPENSBURG,PA 17257 / O Date of Notice: t u n1 WWR#: 05996964 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 BY : ?c?` F ru vvt l w &0-m4'o- --- 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 Request for Military Status w Department of Defense Manpower Data Center Military Status Report Pursuant to the Servicemembers Civil Relief Act 1W Page 1 of 2 DEC-05-2008 06:40:20 'K Last Name First/Middle Begin Date Active Duty Status Service/Agency EDWARDS CHRISTOPHER A 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. 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.defenselink.mil/faq/pis/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 12/5/2008 -b?- O 00 ?? ex+ gn ?'3 C:7 't fiz µ ' ? { 'yr -< ? ko IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA), N.A. Plaintiff VS. Civil Action No. 08-5077-CIVIL TERM CHRISTOPHER A EDWARDS 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 $1947.40 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: P, 7 10 ROTHO RY R DEPUTY) CHRISTOPH A EDWARDS 111 HERSHEY RD LOT S SHIPPENSBURG, PA 17257 Plaintiffs 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 OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA), NA Plaintiff vs. CHRISTOPHER A EDWARDS Defendant(s) No. 08-5077 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) 434-7999 WWR#5996964 CFR IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA), NA Plaintiff vs. CHRISTOPHER A EDWARDS Defendant(s) Civil Action No. 08-5077 CIVIL TERM PRAECIPE FOR SATISFACTION OF JUDGMENT At the request of the undersigned attorneys for the Plaintiff, you are directed to satisfy the above-captioned Judgment. WELTMAN, WEINBERG & REIS CO., L.P.A. By: James C. W PA I.D. # 4'6 WELTMAI, 1400 Kopp 436 Seven PittsburghVA 15219 (412)434- 999 WWR #5996964 Sworn to and before me thi day of Octgy, NOTARY PUBLIC Esquire & REIS CO., L.P.A. coa TM Or KNKSn-vANa Sod WW* LiG NOWY P Chou Cftyc 01 pw 9 7090 MO MW, ^ ^ F?LED..: 2004 NOY 10 Ali Cc:;,- 29 $9.00 PA ATT-Y CIL?`S?to e" t