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HomeMy WebLinkAbout08-5780D, r. 1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff No: df - 570 TAM VS. MELISSA M MEHAFFEY COMPLAINT IN CIVIL ACTION 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 06899051 C N Pit SMI t IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff VS. Civil Action No MELISSA M MEHAFFEY 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 f I 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: MELISSA M MEHAFFEY 22 SOUTHPOINT DR MECHANICSBURG, PA 17055 3. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXXXXXX1038 . 4. Defendant made use of said credit card and has a current balance due of $1461.39 , as of August 18, 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 29.200 per annum on the unpaid balance from August 18, 2008 . A copy of Plaintiff's STATEMENT is attached hereto, marked as Exhibit "1" 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 , MELISSA M MEHAFFEY , INDIVIDUALLY , in the amount of $1461.39 with continuing interest thereon at the rate of 29.200W per annum from August 18, 2008 plus costs. Warmbrodt,42524 Jay WEWEINBERG & REIS CO., L.P.A. 43th Avenue, Suite 1400 Pih, PA 15219 (4-7955 FA 338-7130 06 C N Pit SMI This law firm is a debt collector atpting to collect this debt for our client and any information obtai d will be used for that purpose. capitalpn• NOT PAYING YOUR DEBT 500013 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 kee 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 within 30 days to keep your account from being charged off. ® 2006 Capital One Services, Inc. Capital One is a federally registered service mark. All rights reserved 500013-08503 FINANCE Previous Balance Payments & Credits CHARGE Transactions New Balance Minimum Payment Due Date $973.87 - $0.00 + $24.50 + $29.00 = $1,027.37 C$180.00 Feb. 27, 2007 Dec. 28, 2006 - Jan. 27, 2007 Page 1 of 1 PLEASE PAY AT LEAST THS AMOUNT MasterCard Platinum Account Your account is six payments behind. If we charge off your account due to late payments, we will report the 5291.1520-9944-1038 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 Your Account Information 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. TOTAL CREDIT LINE $1,000.00 TOTAL AVAILABLE CREDIT $0,00 CREDIT LINE FOR CASH $1,000.00 AVAILABLE CREDIT FOR CASH $0.00 Finance Charges (Please see reverse for important irdarmation) Balance rate Periodic Cnding FINANCE applied to rate PR CHARGE Purchases $986.59 0.08011% P 29.24% $24.50 Cash $0.00 0.08011% P 29.24% $0.00 ANNUAL PERCENTAGE RATE applied this period: 29.24% ® At Your service 11-1100,111113-3637 To call Customer Relations or to report a lost or stolen card ® Send payrrards to: Capital One Bank • P.O. Box 70884 - Charlotte, NC 28272-0884 A Sand inquiries to: Capital One • P.O. Box 30285 - Salt Lake City, UT 84130-M -Important Notice- 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 if you fail to keep your account in good standing, Capital One reserves the right to raise your APRs in the future. Payments, Credits & Adjustments Transactions 1 27 JAN PAST DUE FEE $29,00 When you provide a check as payment, you authorize us either to use information from your check to make a one-time electronic fund transfer from your account or to process the payment as a check transaction. When we use information from your check to make an electronic fund transfer, funds may be withdrawn from your account as soon as the same day we receive your payment, and you will not receive your check back from your financial institution. 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 least 7 business days for your minimum payment to reach Capital One. oawr 6056 506 1 7 27 070127 PAGE 1 of 1 OIBC6056 PLEASE RETURN PORTION BELOW WITH PAYMENT 0 5291152099441038 27 1027370100000180005 ?`I what's in your wallet?' New Balance Minimum Payment Due Date C$1,027.37 $180.00 Feb. 27, 2007 PLEASE PAY AT LEAST THIS AMOUNT Amount Enclosed Capital One Bank P.O. Boz 70884 Irlrrlllrrrrlrlrlrrlrl Charlotte, NC 28272-0884 Inlrllnlurlrllrlolls Irlllurlnlrlnlnlullnlulullnrll Account Number. 5291-1520-9944-1038 Please print address or phone number changes below using blue or black ink. Address Home Phone Alternate Phone E-mail address Ca? #90026177942343340 MAIL ID NUMBER MELISSA M MEHAFFEY 22 SOUTHPOINT DR MECHANICSBURG, PA 17055-4270 rrrllLrrllLrrrldrdJrdrdrddlrrrllLrrrrLlrrhLlrL 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. MELISSA M MEHAFFEY 1. How to Avoid a Fin rust Charge. t e. Grace Period. You wti haw a minimum grace period d 25. days wgoout finance, charge on run, Purchases, new balance tranders. new special purchases and new other chsrgea N you pay your total 'New BalsaW. in accordance vio to Important Notice for payments below, and In time fork to be credited by your rob statement dosing dam. Thera Is no grace period on cash ad-- and special assistant. In addNo . Them Is no grace period on any transedicn N you do not pay the total *Nenv balance.' b. Accruing Finance Charge. Transactions ~ are not euq.d to a grace period are a.eeased finance Mange 1) from the dab of the t arwac8oh or 2) from the dab the transaction is processed to your Account or 3) from Un final -harder day of thus c ment bMV period. AddtiohWy, ryou did not pay tlu'Nsv Balance from the previous bl1 g period in full, fns nce dheages continue to accrue to your unpaid belama until the unpaid besnce is paid in full. This means that you may still owe fkunce charges, even N you pay the entse New Balance Indicated on the from of your statement by the next statement doing date, but did not do so for the previous month. Unpaid finance congas am added to the applicable segment of your Account . t c. Minimum Finance Charge. For eerh bling period that your arrant is subject to a iwnce doge, a minimum total FINANCE CHARGE or SOAD erg be imposed. t d. Temporary Reduction In Finance Charge. We reserve the right to not nun any or all bunco charges for any given taking period. 2. Avenge Deny 9afersca Bncludhug New Purcl as.s4 Finance charge s calculated by multiplying the tidy balance of each segment of your account (e.g., cash advance, purchase, special transfer, and special Purchase) by the carespordkg daily periodic rob(e) IhN has been previously disclosed to you. At the and of each day during the killing period, we apply t the dally periodic rate for each segment of your account to the defy balance of each segment. Then at the and of to bldg period. rare add up the results of stress deity Watgstens fe Who at your Paio6C finance Merge for each segment. We add up the mauls from each segment to arrive at the total periodic finance charge for your account. To gat the dally balance for each segment of your amount. we take the beginning belarus for each segment said std any ruwashrdans and wry pario6c finance char(p celculeiod on at Wevbus days balaroe for that segment ft tag aWaa s my payments or credits posed as of #W day get an el-lod to that eaignwM. This gives us gar separate dW baiarhca for each segmers of your sccoum. However, N you paid ter New Balanco shown on your previous statement in full (a If your new balance wag zero or a credit amcunq, new transactions. which past to your purchase or special purchase segments ere not added to the daily balms. We calculate the average daily balance by adding al the daily basroas together and dividing the sum by to number of the days in the current billing cycle. To calculate your total finance charge, multiply your swage dally balance .bythe daily periodic tab and by the hander of days in the.bitlirg Period. Due to rounding an a defy bass or due to minimum finance charge eseesemenL there may, be a -d- between IN. calculation and the amount of fiance charge actually am-sed. 3. Anmed Percentage Ross (APR). a. The term'Anroal Percentage Rats' may appear ss'APR' on the from ot this statement. In. If 0. code P (Ocanerly Prime} L (Ouertery LIBOR), C (Ou.rbdy CO), or S (Bankomd Prime) app- on the from of this statement nee to du pwtodic rate(s). the Periodic rates and comamohdng ANNUAL PERCENTAGE RATES may vary quarterly and may ncrasse or decrease based an are aimed irdims, as farad in The WNI Street Journal, plus the margin prig-usly disclosed b you. These lang. aril be affect- on thu first day of your billing period coered by your pwb& abbnwt ending In the months of January, April, Judy and October. c If me code O (Monthly Prime), F (Mundy LIBOR), a G (Treasury LIBOR) appease on the front of you statement rest to to periodic rala(a), the periodic mass and corresponding ANNUAL PERCENTAGE RATES may vary monthly end may increases or decrease Posed on the stated Indices, as found In The Wall Street Journal, pits the margin Previously dsdoeed to you. These Menges will be atecilve en the fits day or your bBing furlod men math. 4. A.asssrnant of Left, OwWmil end itstammad Payment Faea. Under the ferns of your customer sgreament, we reserve to rigor to wake or not to aaeea any fees wlthou prior, notl8utlon to you vithoul wNVkg our right to asses, the same or simfsr fees a a labr erne. t S. Rehrtewhtg Yar Account. N a membership fee appears on the amt of your srsorroM you hew 30 days from the data tots assistant: ses ringed In you to avoid paying the fee or to have such fee credited to you if you canal your aowunt ml*tA having to pay the membership fee. To cancel you soon nt, you mud notiy us by calling our Cudonbr Relations Department and pay your Tlew Balance In full (excluding the membership fee) Prior to the end of the thirty-day period. 6. It You Cfeas Your Account You can request to does you amount by calling our Customer Rotation. Department You must destroy you -A ad(s) and amour auras. dodo, cancel all praauMorumd billing and cease using your account After your nquaR to does. N you continue to started or do not cancel prose ncitzed billing amangernems, se era caaidermo kit of a charge your a etwoodon to keep your account open Additionally, your account wilt rut be domed until you pay all amoums you ova us indudarhp: any transactions, you have eutludzW. finance Utrges, post due fees, m"ndf fees, retuned payment him, cash advance teat and any other fees eeseasetl to your-.L You an responsible for these .mounts whether toy appear co your amount at the tms you request to dose the account or may, an Incurred subsequent to your request to dose the aaaura. TNs my result in charges appearig an your accours after you hew requested the account to be dosed. 7. Using Your AcmunL Your card waccount cannot be used in connection with any Internet garrblog tre me (ions. 8. Notice About Electronic Cheek Conversion. When you provide a check as payment, you authorbe us either to use information from your 019M to make a one-time aleckonlc fund trendarfrom your benk cocout or b process the Payment as a Check transaction. When we use infatuation from your check to make an electronic fund trensbr, funds may be wMUgwn from your bank account as soon as the terms day era receive your payment, end you w111 not receive your check back from your financial Institution. BILLING RIGHTS SUMMARY (In Case of Errors or Questions; abort Your Bill) N you think your bill s wrong, or If you need more Information on a transaction or bill, write 1. us on a asporeb shed as scot as Possible at the address for inquites shown on the front of sits statenerK We must hear from you no later than 60 days after we sent you the that oil on vtgch the emor or problem appeared. You con cog our Customer Relations number, had daft so will not preserve your rights In your ktteR give us the foliowirg inkrmanion: your rums and acoomt number, the dollar amount of the suspected error, a description of the error and an explanation, If potiMe, of why you believe tore is an error; or N you need more infonMCn, a description of the item you are unsus abo L You do not have to pay any arrount in question whle we am khweugagng ft, but you are Still obligated to pay the parts of your bill that are not In question. NRtb we inwangate your gmsstian, we cannot report you as degrgaent or take any action to called me amount you question. i, t Special Rule for Credit Card Purchases If you have a pmble m with the quality of property or services tun you purdwsd with a credit card and you heve tried in good faith to coned the Problem with ter rtumlwnt. you may have the rot not to pay the remaining amount due on the property or serAces You have this protection orgy when Its purchase price was mot than 560.00 and the purchase was made in your home state a WWn 100 miles of you mating eddn a s. Of wa own or operate the merchant, or if we mailed you to adwrtssment for the Property or services. all Purchasers are covered regardless of amount a baton of Purchase.) Please remember to sign all correspondence. t Does not applym consumer non-aedl card accounts 2 Does not apply to buirass noncwdt card xmums Copied One supports information ptvacy Prmedion: we our wehalte at f?tfJ . Capital One it a federally regWrad service mark of Capita Oro Financial Copaaton. AV rights reserved. O 2006 Capital One TC-W 01 BC6056 - 6 -12/21MS Ie.Wt. Noapr PyrbyouandtuergtamdVAdbyouaxantndtekSkardsyee Mook k,gashed(I)yousadore bottom portion offs sl*wd and year deck in tlo wsbsetl mme oo a weeps and (2) your payment a rushed in our pounding anlr by 3 Pm. Er (12 noon PT} Rase dos at h utliu(5)business days sr pad ddwy. Pages oohed by a at arty after boom as any othrfom may not be craned as of t e daym motive them. Our outlines dye are Monday fro gh Saksday, excluding hoWeys. Plan do rotas ieples. paprdps, W. who prgmig you Wyman arm you prose a dock as paymnL you aulhorFae a amt o am Intimation Sam youdmerk s male a ahs m escacrgcfund trasMfren your account or s process the peysan1 or e dock eamaallon. who es use l flonsaon stn yourdhed Is mob m asrbarc find smaller, fism6 nay as wthiawn frarrn your armunt a soon ss tla same day w receive your pay neK rd you wa cad move, you cited loo from you toadel Ymtl,Alcn. CAPITAL ONE BANK (USA), N.A., Plaintiff, V. MELISSA M MEHAFFEY Defendant(s). VERIFICATION 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 an authorized agent of Capital One Services, Inc., an affiliate of and service provider to CAPITAL ONE BANK (USA), N.A., Plaintiff herein, and that he/she is duly authorized to make this Verification, 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_ Dated: I Z -7 / We Xloinette Miller A049 WELTMAN, WEINBERG & REIS CO., L.P.A. _ V V 4 C C'..7 r ,..4 t .? 0 TI 2 r'IF= --c SHERIFF'S RETURN - REGULAR CASE NO: 2008-05780 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CAPITAL ONE BANK USA NA VS MEHAFFEY MELISSA M NOAH CLINE Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon the MEHAFFEY MELISSA M DEFENDANT at 0020:30 HOURS, on the 2nd day of October , 2008 at 22 SOUTHPOINT DR MECHANICSBURG, PA 17055 by handing to MELISSA MEHAFFEY DEFENDANT a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 11.00 .00 10.00 .00 39.00 Sworn and Subscibed to before me this day So Answers: "`sl loop ?.?E?,....1 R. Thomas Kline 10/07/2008 WELTMAN WEINBERG & REIS ' By: Deputy Sheriff of A. D. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA), NA Plaintiff VS. MELISSA M MEHAFFEY Defendant No. 08-5780 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#6899051 Judgment Amount $ 1571.54 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. 08-5780 CIVIL TERM MELISSA M MEHAFFEY Defendant TO THE PROTHONOTARY: PRAECIPE FOR DEFAULT JUDGMENT Kindly enter Judgment against the Defendant, MELISSA M MEHAFFEY above named, in the default of an Answer, in the amount of $1571.54 computed as follows: Amount claimed in Complaint $1461.39 Interest from AUGEST 18, 2008 TO JANUARY 9, 2009 at the legal interest rate of 29.2% per annum $110.16 TOTAL $1571.54 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. MO ZAN, 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#6899051 Plaintiff's address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7`s Avenue, Pittsburgh, PA 15219 And that the last known address of the Defendant is: 22 SOUTHPOINT DR, MECHANICSBURG, PA 17055 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA), NA Plaintiff VS. Civil Action No. 08-5780 CIVIL TERM MELISSA M MEHAFFEY Defendant NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the following Order or Jud ent was entered against you on (xx) Assumpsit Judgment in the amount of $1571.54 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: - A, - -___ L?oo2 Wwt??L PR HONOT E TY) MELISSA M MEHAFFEY 22 SOUTHPOINT DR MECHANICSBURG, PA 17055 Plaintiff's address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7 h Avenue, Pittsburgh, PA 15219 1-888-434-0085 IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA), NA Plaintiff VS. MELISSA M MEHAFFEY Defendant Case no: 08-5780 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, MELISSA M MEHAFFEY 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, MELISSA M MEHAFFEY is not in the military service. Further Affiant sayeth naught. F NT SWO O AND SUBSCRIBED in my presence this /-,?7day of JA A Y, 2009. JA. OF PENNSYLVANIA OTARY PUBLIC Notarial Seal Wendy L. Gault, Notary Public City Of Pittsburgh, Allagheny County My Commission Expires July 15, 2010 Member, Pennsylvania Association of Notaries 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. (equost for Military Status 3epartment of Defense Manpower Data Center Military Status Report Pursuant to the Servicemembers Civil Relief Act Page 1 of 1 SEP-02-2008 12:48:05 < Last Name First/Middle Begin Date Active Duty Status Service/Agency MEHAFFEY MELISSA M Based on the information you have furnished, the DMDC does not possess any information indicating that the individual is currently on active duty. lpon searching the information data banks of the Department of Defense Manpower Data Center, based on the information that you ,rovided, the above is the current status of the individual as to all branches of the Military. lot NOV_ Mary M. Snavely-Dixon, Director 3epartment of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 'he 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 ligibility systems. 'he 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 lformation indicating that the individual is currently on active duty" responses, and has experienced a small error rate. In the event the idividual referenced above, or any family member, friend, or representative asserts in any manner that the individual is on active duty, or is ,therwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's active duty status ,y contacting that person's Military Service via the "defenselink.mil" URL provided below. If you have evidence the person is on active-duty nd you fail to obtain this additional Military Service verification, provisions of the SCRA may be invoked against you. f you obtain further information about the person ( e.g., an SSN, improved accuracy of DOB, a middle name), you can submit your request gain at this Web site and we will provide a new certificate for that query. 'his response reflects current active duty status only. For historical information, please contact the Military Service SCRA points-of-contact. See: httv:Hwww.defenselink.miFfaai ip s/PC09SL.DR html VARNING: This certificate was provided based on a name and Social Security number (SSN) provided by the requester. Providing an rroneous name or SSN will cause an erroneous certificate to be provided. 'eport ID: JLASKALVCJ ittps://www.dmdc.osd.mil/scra/owa/scra.prc_Select 9/2/2008 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff vs. MELISSA M MEHAFFEY Defendant TO: MELISSA M MEHAFFEY 22 SOUTHPOINT DR MECHANICSBURG, PA 170,55 Date of Notice: -1-1 I a ?OZ Case No. 08-5780 CIVIL TERM IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA. 17013 (717) 249-3166 WELTMAN, WEINBERG & REIS CO., L.P.A. By: ?61- wbc Vw-" ' atnc Woodman P.A.1.DA 34507 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 Seventh Avenue, 1400 Koppers Building Pittsburgh, PA 15219 Phone: (412) 434-7955 6899051 N PIT KM3 W Q a r ?. r. ? 1 ?I Q ?J r o r ? cv ' r? ?a rJ w