HomeMy WebLinkAbout08-7021
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK (USA),NA
Plaintiff
VS.
JOANNE L FREISTAT
Defendant
No : 08 -- '76 a l
COMPLAINT IN CIVIL ACTION
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
06935625 C N Pit IAS
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK (USA),NA
Plaintiff
VS. Civil Action No
JOANNE L FREISTAT
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),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:
JOANNE L FREISTAT
69 KENSINGTON DR
CAMP HILL, PA 17011
3. Defendant applied for and received a credit card bearing the
account number XXXXXXXXXXXX2727 .
4. Defendant made use of said credit card and has a current balance
due of $2195.75 , as of September 16, 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
28.100% per annum on the unpaid balance from September 16, 2008 . A
copy of Plaintiff's STATEMENT is attached hereto, marked as Exhibit
111" 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 , JOANNE L FREISTAT , INDIVIDUALLY , in the amount
of $2195.75 with continuing interest thereon at the rate of 28.1001
per annum from September 16, 2008 plus costs.
James C.
WELTMAN,
436 Sev
Pittsb x
(412) 3
FAX: 1?
0693 6J
W rmbrodt,42524
W INBERG & REIS CO., L.P.A.
t Avenue, Suite 1400
PA 15219
-7955
338-7130
C N Pit IAS
This law firm is a debt collector attempVing to collect this debt for
our client and any information obtained will be used for that purpose.
CapitalOW NOT PAYING YOUR DEBT 5°°013
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 J= 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 Capita! One Services. Inc. Capital One is a federally registered service mark. AU rights reserved 500013-08503
FINANCE
Previous Balance Payments 8 Credits CHARGE Transactlons New Balance Minimum Payment Due Date
$1,416.24 - $0.00 + $34.28 + $35.00 = $1,485.52 $485.52 Jan. 03, 2007
fo.
Nov. 04, 2006 - Dec. 04, 2006 Page 1 of 1
KEASE W AT LEAST THIS AMOUNT
MasterCard Platinum Account Your account is six payments behind. If we charge off your account due to late payments, we will report the
Masbr2&3907latin charged-of 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 information)
Balance rate Periodic Corralpmding FINANCE
applied to rate APR CHARGE
urchases $1,433.87 0.07712% D 28.15% $34.28
ash $0.00 0.07712% D 28.15% $0.00
NNUAL PERCENTAGE RATE applied this period: 28.15%
® At Your Ssrvim 1400403.3837
To all Customer Relations or to report a lost or sedan card
® Send payments to:
Capital One Be*- P.O. B..70684 • Charlotte, NC 28272.0884
A Send Inquiries to:
Capital One • P.O. Box 30285 - Salt Lake City, UT 84130-0285
'important Notice" Under the terns 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
T-04 DEC PAST DUE FEE $35.00
You were assessed a past due fee because your minimum payment was rat received by the due date. To avoid
this fee in the future, we recommend first you allow at least 7 business days for your minimum payment to reach
Capital One.
our
6056 506 1 7
ow- what's in your wallet?'
0 5178052239072727 03 1485520040000485522
Account Number. 5178-0522-3907-2727
New Balance Minimum Payment Due Date
C$1,485.52 $485.52 Jan. 03, 2007
PLEASE PAY AT LEAST
THIS AMOUNT
Amount Enclosed
Capital One Bank
P.O. Box 70&&4 Itlrrlllrrtllrrttrllrl
Charlotte, NC 26272-01164
III III Is 11111 111111ill
061204 PAGE 1 of 1 OIBC6056
PLEASE RETURN PORTION BELOW WITH PAYMENT
Please print address or phone number changes below using blue or black ink.
Address
Home Prone Alternate Phone
E-mail address Q
0903397765&070793• MAIL ID NUMBER
JOANNE L FREISTAT
69 KENSINGTON DR
CAMP HILL, PA 17011-7413
rrdllrrdllrrtod6nllLolLLrtrrlLrdld6JdrtLrr
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.
JOANNE L FREISTAT
1. Her to Awld a Finance Charge.
t e. Grace Period. You VAN Mw a minimum pace period of 25
days wttcut frame charge on new Wrctesea0. new
bdana treaders, new spadal purctwn and new 011
charges if you pay your total'New, Balance', I.
accordance wMh ere Implant NoBa for payments balm,
and In Urns for It to be credited by your need statement
closing dam. Theis is ne pees period on cash scivenceis
arW tpetlsl bYernalams. In addbm drs is ne pace period
on any transaction if you do nail pay tie burl •Nw
balance.'
''. b. AcarWng Finance Charge. Transacdons which we not
suE)act b a grace period w named finance c arga 1)
from the dam of she Inannoion or 2) from the data err
transaction is lormea d to your Account r 3) from Net Taal
calendar day of Me current WIN period. AddNawly, t you
din not pay ft Ties Same' kom the pr"us billing
period M full, finance charges rdNnue to accrue to your
unpaid balance unfit fir unpaid balance is paid in full. This
means that you may ON are finance Mapes. aver t you
pay the amore New Balance Miamd on err from of your
stammers by the next ateialeant closing dam, but did not do
so for the previous month. Unpaid fnance c argea are added
to the applicable segment of your Account
t c. Mbbean Fiance Charge. For anch NBrg period that your
anoint Is subject b a amerce charge. a mkmum total
FINANCE CHARGE of S0.50 will be Imposed.
t d. Temporary Reduction In Fiance Charge, Wa lessen- Ow
right to not apes" any or all finance charges for any given
killing period.
2. Awarsga Daly BaWce (balding New purchases).
Tana charge a calculated by multiplying the daily balance
of each segment of your account (e.g., ash advance,
prnchw, special Bander, and special Wd-) by Our,
ooteaponding daily periodic raft(s) that has been
previously disclosed to you. At the and of won day dung
the Wang period, we apply the daily periodic ram for each
segment of your account to to dally balance of each
segment. Than at err ad of to biting period, we add up the
mauls of thses daily calculations b arrive at your periodic
finance olyrge for each segment vve add up the issues from
eacheapnent b aMae r the iced periodic Mice charge fa
yourarmrm To gal the defy balrrsfor each segment of
your accont we take the beginning balance for each
seprant and dd"new, trenamdons ad any periodic
Manca charge alminred on the pmvba days belanafr
thW segment MM Men rlWW airy payments or cream
posled as of that day that son allocated to that segment. This
givesmtie sel aram defy besrrw for each "Whent of Y"
Brxoum. However. If you paid ere Now SaWCe shown on
your previous statement In ful (a If your new balance was
Coo or a c edit rani), new transactions. which post to
your pumdaa t or special purchase tsgmanm ra not added
to the daily baban. We aktaate the avenge, defy
balance by adding as the dally belanaa together and
dMdng the sum by the number of the days In our arrant
biling cycle. To alumni your tour finances charge, mutipy
your average daily-- by tie dally peridie rate and by
the number of days In to bBrg period. Due b rounding on a
daily bask or due to minimum fiance charge aeeawnent
dkera may be a vartnca between this calculation and the
amount of finale charge actually assessed.
3. Annual Percentage Reims (APft
a. The term 'Annual Percentage Rate' may appear
ore •APR• on the from of this aWament
b. If he Coda P (Quarterly Prima), L (Ousdary LIBOR), C
(Quarterly CD), or S (Baricard prima) appears on the front
of this ssmment neat to the pedodb nin(e), the periodic
rams and cdmespdrxft ANNUAL PERCENTAGE RATES
may vary quarterly and may inCaaee or decisses based an
the stated ini ices, as bred in TM Wag Straat Jaranal. Pks
the margin previously dsdaed b you. Than divinges will
be eased" on gal tM day of your bBkg PWW cow" 'd by
your periodic statement ending In the months of January,
April, July and October.
c. If ale code D (Monthly Prins), F (Monthly LIBOR). a O
(Treasury LIBOR) appears on our from of your shmenent
next to de periodic ra*at die periodic robs and
corresponding ANNUAL PERCENTAGE RATES may vary
monthly and may increase or decease based on the staled
indices, as found in The WWI Seem Journal, plus the
margin previously disdcead to you. Than rdwgm will be
eteWw a the IM day of your bOV period each month.
a. Assessment of LMe, Ovedlmk and Returned ?ayeem
I- Under the bna of your aslonw agreement. ww
reserve the right b -ft or no b wens arty NM "from
pia notification to you wahoa valuing our right to serf a the
somarsimlrfwat aleart-
T S. Renertrg YbirAOceurt. If a membership in appears
on the front of your statement you haw 30 days from tM
dam this aemmem ins mated to you to awkl paying the
me or to heirs such be credited to you if you canal your
account without hsWng to pay the membership lee. To
carrel your ao=^ you must notify us by albg our
Cnlpner Relations Department and pay yourTlew
Balance' In full (excluding the membership fee) prior to
ft and of the Nrttdsy period.
5. N You Close Your Account. You an request to dose your
scomod by calling our Cuwmer Relations Dpsronem. You
must destroy your credit and(s) and account access checks,
amoral all prsautlpized billing and own using your account
After your request to tins, if you continue to bromesil or do
not cancel preauttcnsed biting anangarmanp, we will
mnsiderrrdpr of a Marge yorsutlxliaaaon to keep your
account open. Additionally your amount will not be dosed
unit you pry M amount you arm us including: any
bansactbns you haw au0rriasd, finance charges, post due
fees, ovaAMl fa it returned payment ion, rah advance
few and any alMrfw aawad to your account. You are
responsible for thou amounts wt ceder they appear on you
amount at the time you request to does the account or they
ans incurred subsequent b your fequeat to dose the account.
This nay result In barges appearing on your amount after you
haw requested tie account to be dosed.
7. Wing Your Account. Your care or account cannot be used in
connection with any Internet garbling transactions.
B. Notice About Elaelmni : Check Conversion.
When you provide a check as payment you authalze us
.inter to use information from your check to make a ons-lime
dedm is hand transfer from your bank accent or to procaea
the payment W a tdectt transactM. When we use
Wrmabon from your Mark to make an electronic fund
tmnde Amft may be vatirtrawn from your bank account as
soon NO the same day we receive your payment and you will
not receive your drills back from your financial Institution.
BILLING RIGHTS SUMMARY
(In Caen of Enors or Ouestlons about Your BB)
If you think your bit Is wrong, or It you need more infi rmetlon on
a transaction a alt, write to us on a separate W" as soon n
press h a at this address for inquiries Shown on the front of tins
statement We mat hear from you no star than 50 days after wo
sent you ft first bit on which tie arm,` or problem appealed. You
an all our Customer Relations number, but doing w will net
proaarw your rights. In your lets, give us our following
bfc medon: your ante and account number. the dollar amount
of the suspected error, a description of the error and an
explanation. It potable, of wiry you baliaw them Is an error, or If
you read mom inlorms ion, a description of the item you am
unsure about You do not haw to pay any amount in quesaon
whin we are inveaagetng t, but you are still obligated to pay the
pas of your bin that am not In quesdon. While we bvntigate
your question, we cannot report you w delinquent m We any
action to coiled ere amount you question.
$, t Special Rule for credit Cord purchaser
If you have a problem with the quality of property or aervkm that
you purchased with a credit card and you haw tried in god faith
to correct No problem with the nrrdaM, you my new the right
not to pay the remaining amount due on the property or "rulces.
You have He pmleWon only when the purchase prim was more
than $50.00 and the purchase wea miss in your hoe state or
wthin 100 miles or your malhg address. Of we own or operate
to nerche L or t we mailed you the advertisement fa the
property or servius, all purchases are covered regardless of
amount or location of purchase.) Pew remember to sign all
t Does not apply to consumer noncmdt card accounts
2 Does not apply to buerace non-crecit card accounts
Capital One supports information privacy protection: ton our
weWlte at wvacJp) stone th.
Capital One It a fedendy ragsmmd swAce mark of Capital One
Financial Corpaason. AN rights reeened. O 2006 Capita One
01 BC6056. 6-1221006
akpemWd Nalba Prynrns you nW m a wB b cmadaed b youraocsnl r oltla busaaa dayse rrsia a, prortlsd (+) you sold tie
barmen pond- of ft aWenwnl and your cad in ftadaed mnMrce snWope and (2) year?spai sncd dhoti prrrg Omer
by 3 pun. ET (12 ram PT). Rases air M isaatte (S) Wainer drolrpoWdd-y. Pgmaa wiled try a o wry alar loaders a In
raymbrfcrmmaynotbaWmdnerdadaywsmohsden DwNWa drysourkidoyhough Samday,c.kdghcldrp.
Plow do let ore eloped, p.W cfp, etC Man pnpasg Yoe pWWC elan You profile ¦ decka payment, you substrate ate b ore
kft=dDn from your deed b main a ww ma aiscacractied reehrmm youasalm or Io prom am payment as a clack hanascmn.
Who we on bmmatlon tom your died b maim an ded *fnd finale, Nora may be *40 from your acrawn a noon as tie aeon
dry M make y+w paymat and you as not racers yarded bad Ban your hwrkl matlmaon.
CAPITAL ONE BANK (USA), N.A.,
Plaintiff,
V.
JOANNE L FREISTAT
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: 10 IV X12 00
9 cv?
Aleksander Cherkis
A049
WELTMAN, WEINBERG & REIS CO., L.P.A.
xj
-^ 'ti
zi-
7Y. -
0
SHERIFF'S RETURN - NOT FOUND
CASE NO: 2008-07021 P
COMMONTWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
CAPITAL ONE BANK USA NA
VS
FREISTAT JOANNE L
R. Thomas Kline Sheriff or Deputy Sheriff, who being
duly sworn according to law, says, that he made a diligent search and
inquiry for the within named DEFENDANT
FREISTAT JOANNE L but was
unable to locate Her in his bailiwick. He therefore returns the
COMPLAINT & NOTICE
NOT FOUND , as to
the within named DEFENDANT FREISTAT JOANNE L
69 KENSINGTON DR
CAMP HILL, PA 17011
PER CURRENT RESIDENT, ZORY ALEMANY, FREISTAT MOVED. PER POST OFFICE
MAIL IS STILL DELIVERED TO ADDRESS GIVEN.
Sheriff's Costs: So answers:
-
" - "
Docketing 18.00 - -,--
Service 14.40
Postage .42 R. Thomas Kline
Surcharge 10.00 Sheriff of Cumbe rland County
Not Found 5.00
4 WELTMAN WE INBERG & RE I S
12/09/2008
Sworn and Subscribed to befo re
me this day of ,
A.D.
IN THE COURT OF COMMON PLEAS Cumberland COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK (USA),NA
Plaintiff
Civil Action No. 08-7021 CIVIL TERM
vs.
JOANNE L FREISTAT
Defendant(s)
PRA X1PE TO REINSTATE COMPLAINT
Kindly reinstate the Complaint in the above captioned matter.
WELTMAN, WEINBERG & REIS CO., L.P.A.
By:
James C. W
PA ID #42$
WELTM4`
1400 Ko . c
,PP
Esquire
& REIS CO., L.P.A.
Buidling
436 Seye Avenue
Pittsbui , PA 15219
(412)'434-7955
WWR #6935625
Dritmjmkl,o?
FtLEQ_ cW9 Ava l! Am 10:11 of
CWth PA
4 b . 00 Pb Any
er ustwu
C07
Sheriffs Office of Cumberland County
R Thomas Kline
Sheri
Ronny R Anderson
Chief Deputy
Jody S Smith
Civil Process Sergeant
?wytr of C111q,rf4,14
Cy _
OFFIC'4 ?-ERIFF
Ft1.ED-U-1-FiC,E
OF THE PPOTT-iONOTAW
2809 AUG 19 AM 9: 14
4VAGl ?: aL rv J i I.)jUN { Y
PENNSYI_yq#t rA
Edward L Schorpp
Solicitor
Capital One Bank (U.S.A.) N.A. Case Number
vs.
Joanne L. Freistat 2008-7021
SHERIFF'S RETURN OF SERVICE
08/17/2009 05:38 PM - Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on August 17,
2009 at 1738 hours, he served a true copy of the within Complaint and Notice, upon the within named
defendant, to wit: Joanne L. Freistat, by making known unto herself personally, at 806 Market Street New
Cumberland, Cumberland County, Pennsylvania 17070 its contents and at the same time handing to her
personally the said true and correct copy of the same.
SHERIFF COST: $43.30
SO ANS
August 18, 2009 R THOMAS KLINE, SHERIFF
By ? ----?7 ?-z....
Deputy heriff
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK (USA),NA
Plaintiff
vs.
JOANNE L FREISTAT
Defendants
No. 08-7021-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#6935625
Judgment Amount $ 2659.08
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK (USA),NA
Plaintiff
VS. Civil Action No. 08-7021-CIVIL TERM
JOANNE L FREISTAT
Defendants
TO THE PROTHONOTARY:
PRAECIPE FOR DEFAULT JUDGMENT
Kindly enter Judgment against the Defendant, JOANNE L FREISTAT above named, in the default of an
Answer, in the amount of $2659.08 computed as follows:
Amount claimed in Complaint
$2195.75
Interest from SEPTEMBER 16, 2008 TO OCTOBER 26, 2009
at the legal interest rate of 28.100% per annum $463.33
TOTAL
$2659.08
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, ?UIRE
PA I.D.#47437
Weltman, Weinberg & Reis Co., L.P.A.
1400 Koppers Bldg.
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR#6935625
Plaintiff's 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: 806 MARKET ST, NEW CUMBERLAND, PA 17070
IN T14E COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK (USA),NA
Plaintiff
vs.
JOANNE L FREISTAT
Defendant
Case no: 08-7021-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, JOANNE L
FREISTAT 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, JOANNE L FREISTAT is not in the military service.
Further Affiant sayeth naught.
L?47-*kA'
AFFIANT
SWORN D SUBSCRIBED in my presence this VAday
Of 0C
coM?no_NwF1u THQE.13ENNSYLVAN A
N ARY PU Notsft SOW
VV** L. GRA Notary Public
City & P&Wurgh. AllOOWY coumy
dTULIV CaMniepoo 1 B, 2010
Member. Anodatton NoEaAes
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK (USA),NA
Plaintiff
Case No. 08-7021 CIVIL TERM
V&
JOANNE L FREISTAT
Defendant
IMPORTANT NOTICE
TO:
JOANNE L FREISTAT
806 MARKET ST
NEW CUMBERLAND, PA 17 70
Date of Notice: 10 12 0
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, )*-INBERG & REIS CO., L.P.A.
By: 1
Matthew Urban
P.A.I.D.# 90963
WELTMAN, WEINBERG & REIS CO., L.P.A.
436 Seventh Avenue, 1400 Koppers Building
Pittsburgh, PA 15219
Phone: (412) 434-7955
6935625 N PIT L4Q
Request for Military Status
Department of Defense Manpower Data Center
rs Military Status Report
Pursuant to the Servicemembers Civil Relief Act
Page 1 of 1
OCT-14-2009 10:50:42
-< Last Name First/Middle Begin Date Active Duty Status Service/Agency
FREISTAT JOANNE 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.
IA.
Awt pq
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. nil/fa"is/PC09SLDR.html
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: BCQMFHDJDSD
https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 10/14/2009
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IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK (USA),NA
Plaintiff
vs. Civil Action No. 08-7021-CIVIL TERM
JOANNE L FREISTAT
Defendants
NOTICE OF JUDGMENT OR ORDER
TO: ( ) Plaintiff
(xx) Defendant
( ) Garnishee
You are hereby notified that the following
Order o Ju gment was entered against you
on
(xx) Assumpsit Judgment in the amount
of $2659.08 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:
ROTHONOT DEPUTY)
JOANNE L FREISTAT
806 MARKET ST
NEW CUMBERLAND, PA 17070
Plaintiffs address is:
c/o Weltman, Weinberg & Reis Co., L.P.A., 1400 Koppers Building, 436 7"' Avenue, Pittsburgh, PA 15219
1-888-434-0085