HomeMy WebLinkAbout08-7337
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK (USA),NA
Plaintiff No: - erm-
vs.
COMPLAINT IN CIVIL ACTION
FREELAND M NGUYEN
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
06899100 C N Pit CFR
1
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK (USA),NA
Plaintiff
VS.
FREELAND M NGUYEN
Defendant
Civil Action No
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:
FREELAND M NGUYEN
903 APPLE DR
MECHANICSBURG, PA 17055
3. Defendant applied for and received a credit card bearing the
account number XXXXXXXXXXXX0287 .
4. Defendant made use of said credit card and has a current balance
due of $1218.75 , as of September 29, 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
27.100% per annum on the unpaid balance from September 29, 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 , FREELAND M NGUYEN , INDIVIDUALLY , in the amount
of $1218.75 with continuing interest thereon at the rate of 27.100%
per annum from September 29, 2008 plus costs.
Jamn43 armbrodt,42524
WEL EINBERG & REIS. CO., L.P.A.
436 h Avenue, Suite 1400
Pit, PA 15219
(417955
FAX38-7130
068 N Pit CFR
This law firm is a debt collector atte Vng to collect this debt for
our client and any information obtaine will be used for that purpose.
capml iclw NOT PAYING YOUR DEBT 500013
what's in your wallet? DOESN'T MAKE IT GO AWAY.
In fad, even if we report your account as charged off, you'll still be responsible
for paying your debt. So why not call us to see what we can do together to keep
you from receiving such a serious mark on your credit record?
We're here to help. Please contact us to
find a solution that's right for you.
You can make a payment with our free 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 by the due date to eliminate the risk of being charged off.
0 2007 Capita! Oar Servim, Inc. Capit d One it d fea&wfly reguomd service mani. All rfg a >rsR ed
FINANCE
Previous Balance Payments & Credits CHARGE Transactions New Balance Minimum Payment Due Date
C$896.72 - $0.00 + $20.59 + $39.00 = $956.31 $456.31 Dec. 31, 2007
Nov. 06, 2007 - Dec. 05, 2007 Page 1 of 1 n>nsr AT Eur M AMOM
MasterCard Platinum Account
517&05262869-0287
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 infamatbn)
Balance rate Periodic Cprt?pa?dtng FINANCE
applied to rate APR CHARGE
Purchases $914.36 0.07507% D 27.40% $20.59
Cash $0.00 0.07507% D 27.40% $0.00
ANNUAL PERCENTAGE RATE appNed this period: 27.40%
® At Your Service 11-81*91113-3637
To call Customer Relations orb report a lost or sWenard:
® Seed payments to:
Capital One Bank - P.O. Box 70884 - Charlotte. NC 28272-M
Your account is six payments behind. t 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. Wall work with you so you can take control of your
account and start rebuilding your credit with Capital One.
'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 9 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 30NOV PAST DUE FEE EXHIBIT $t900
A Send inquiries to: Your account is 90 days past due and your Payment Protection coverage has been suspended. As stated in
Capital One - P.O. Box 30285 Salt Lake City, UT 84130-0285 your Payment Protection agreement, your coverage and mor" Charge will be reinstated once your account is
® Have a question about a charge on your statement? no longer 90 days past due. You may still be eligible for benefits to be pad to your account far loss events
Please refer to the Billing Rights Summary on the back of described in your Payment Protection agreement. Cell Stonebridge Benefit Services at 1.888527.6904 to see if
your statement or visit www califtlone cortJdisoutes• 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 the future, we recommend ttat you allow at leash business days for your minimum payment to reach
Capital One.
6056 506 1 07 5 071205 PAGE 1 Of 1 OIDM6056
PLEASE RETURN PORTION BELOW WITH PAYMENT OR LOG ON TO W W W.CAPrrALONE.COM TO MAKE YOUR PAYMENT ONLINE
what's in your wallet?'
New Balance Minimum Payment Due Date
C$956.31 $456.31 Dec. 31, 2007
PLEASE PAY AT LEAST
THIS AMOUNT
0 5178052628690287 05 0956310015000456312
Amount Enclosed
Capital One Bank
P.O. Box 70684 Irlrrlrrllnrllrrrlrlr
Charlotte, NC 26272-0664
lulrllalurlrllt,rlrtlrlllxrrlulrlgill lnll„lult,llnrll
Account Number: 5178-0526-2869-0287
Please print address or phone number changes below using blue or black ink.
Address
Home Phone Ahemate Phone
E-mail address
#9034079749587494# MAIL ID NUMBER
FREELAND m NGUYEN
903 APPLE DR
MECHANICSBURG, PA 17055-3406
rrrllLrrllLrrrlrlrrhhcell„hrlllr,Jr,I,IlrarrrllrrLr
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.
FREELAND M NGUYEN
1. Now to Avoid a Finance Charge.
t a. Grace Perlod. You will have a mlntmum grace period of 25
days without Nonce charge on new purchases. raw
balance trwters, new, special putdhasss and new other
charges r you pay your loM'Near Balance-. In
accordance with the Imponent Not" fd payments
below, and in tens for it to be cradled by your payment
due doe. Them is no grace period on own advances
and spacial eansfam. In addition, tam Is no grace period
on arty baruaclbn If you do not pay the total -New
balance.'
b. Acwing Finance Charge. Transactions which we not
whjed it. a gram pebd w assessed finance charge 1)
from the dab dlhe trarsactm or 2) fnen the dW t e
bensemm ie pponaed b you Amount d3) Nom tlo Gat
calendar day d the ameet bBlg period- Additionally, fiyeu
did not pay the ONew Balance tom the previous bBMg
period in full. Nunn charges continue to ac crw to your
unpaid balance unit the unpaid balance is paid in ful. This
nears that you may suit cwt finance charges, swan l you
pay the erase New Betero Indicated m tea hat of yar
statement by dike peymard due dab, but did not do so for
to pevbue month. Unpaid! finance charges am added to
he applicable segrant of your Account.
t c. tlsdnaae F6urhce Charge. For each billing period Mat your
account Is euA*M to a finance charge, a niradan tool
FINANCE CHARGE of $0.50 will be Mnposed.
t d. Temporary st d coon In Finance Charge. We remove the
right to not assns any or all grwnce changes for any given
CNrq Period.
2. Avemga Daly Balance (tedhadMS New Pumheees4
Finance charge is mladebd by traalMying the dally balance
of each wegr ont of your sccoant (e.g., rash advance,
phxdrse, spacial No We. and spacial purchase) by aloe
corresponding deity parbdc rate(s) that has Man
previously disclosed to you. At the and of each day during
the bluing period, we apply the daily periodic Mat for each
segrmm of youraccmrnt to the daily balance of each
aegnwd. Then at is and alts bltg period, we add op to
coeds of toes dally calculations to arrive at your periodic
tnance charge for each segment we so up the fo$Ub from
each begrms b arches at the tow perlock lesnce change for
your account To gat the daily balance for each seyneht of
your aooouht we Oekt to be& ning belrnos for each
segment and add wry mew transactions and my Periodic
finance Charge opk~ on the previous deft balance lor
that sapment We aura subtract any payments or credits
posted sa of that day lug am allocated! to Bud segment. The
giros us su separate defy belenm fort r each aepmwit did you
account. However, 5 you paid the New Balance shown on
your pmwous stetamarnt in NI (or 5 you maw balance was
zuo or e credit anout), new Irwardons, whloh post to
you purchase or special purchase tagmarts are not added
to the daily balances. We c&Wo%so anal dally
balance by adding all the dally bswnraa together cut
dMdrhg the sum by the number of the days In tla current
blbg cycle. To ralculeb your taw finance durgR mhasply
yourewraps dasy bslence byte dmiyr periodic role and by 7. Using Yaw Amount Your card or account cannot be used in
emnection with any Internal gha bkv vw-cbms.
the number of days M to blkhg period. Due to rowhmg on a
Daly bask or due to mkhtrnum finance charge ese0aan k 8. Notice About Ekm*Mic Clinch Ctanvw Ice .
sent may be a variane, between eta calculation end the Wish you prw da a check = payment, you sudhorize us
amount of finMIG charge s swty assamed. sitter to use idemationn from your clhack to make a ona-0me
3. Annual Percentage Rates (AP4 electronic: hind Vernier from your bank acccram er to process
a. The v rrn'Am"Pecentage ROW may appear
es 'APR' on the from of this statement. 1hs psymem as a check transaction. 1Atorn we use
kaI -dex from your shack b make an awaronk had
b. If diva coda P (Quarterly Pdme), L (Ouerte ly LIBOR), C "redw, tunds may be wNatawn tram your bank ecccun as
(Quarterly CD), or S (Bahkcard Prone) appears on the front soon as M vane day we receive your payment, and you will
of this stsbnhem notd to to periodic rate(s), the periodic not receive your back back from your financial Institution.
races and corresponding ANNUAL PERCENTAGE RATES
may vary quarterly and may Increate or dsaesr based on BILLING RIGHTS SUMMARY
(M Case of Errors or Ouslacr a shout Your Bill)
to dated adims, as found in The Wall Slrsel Journal, plue,
you. Then dwilaw va
to
o
ly
to inalgIn pu
If you fi, your tail is vamp, or If you need not inftvmetlon on
a tremaafLpn or bill, vats b us on • separate shoal as each as
n the ft A
of f yy
tiro day day
billing Pwlod covered by
our b
M aft Wve on pest at as address Ip n*~ shown on the front a (this
your onMAc settlement ending in V. months of January, atatemarR We must hear from you no later awn 80 days after we
July October If0 . otel and ond* Pne F (MmWy LIBOR), G
e If tins code D Monthly huam you ft final bill on which the error or problem appeared. You
can dl cur Customer Relations mantter, but daft so will not
on fiat from of tent
pipeli (TmasfrY LIBOR) .,A(ts on your wasm
P Pe tutee lied
non s tin pedANc preserve your fights. In your Inter, Vw us the hhlowing
Information: your rams and account marhber, the dolar snore
AL
mrrnpennd ANNUUM. PERCENTAGE RATES may vary
decrease bred on the soled
i
wean
or
momhy echo of the suspected error, a descrptlon of the error and an
explanation, N pose II I d Wry you believe tam lean error; or t
and d
SbeNJ
Wall
in TM
indices, as, fee
the margin previously put changes will be
to you. These
mach y disclosed
you need nom Mdrhaem, a description of the iten you ara
unoass about You do nod have in pay any arrmullt m qussflon
of
.
each moth
t
billing
on the fired dry dyour while we em kwsadgatMp t. but you are edit obligated to pay the
Ps
sm
ill Returned
4. Fews. Und-1 her yo a and lignwrhOrt -
Assassmand of l.
ep
-sWw wa Untlsr the lemll Of d yea
pan of yw bill that am not In qused0n. Welk vin investigate
we cannot report you as delinquent or take any your question,
lw Lq
0 Sam
reaaNa ate right to waiwa or not b aseaas any Tate without
priornodlicuioh to you without waiving ourrigtt to asaesithe edlon to colact to an-rd you question.
*, t Special Poite tar Credit Cad Purchases
nmaorakdterfaea ate tetertarm.
t 5. Reras, g YarrAeoeruR If a membaftllp few aPP"m if you ham a problem w ten the quality of property W 9-1084 that
you purchased wan a credit card and you have tried in good faith
on the from of your sunscreens. you have 30 days trom the
data this sarerront was milted to you to avoid paying to to mined the probs. with the msronan, you may maw the night
not to pay the rpmeldng amout due m far property or "Most.
Ise or to have such M credited to you if you pmaal your
soccrat wNtsur loving to pay the nwhbauhipfas. To You have this protection only when the purchase price was mom
en 550.00 and to purchase van mate In your hen state or
th
cancel your scmu m, you onus notify us by calling our
C,e ooer Relator Department and pay your Tlsw, wthn 100 miss of your ma1Mp address. Of we own or operate
hithe mer0harrL or M we orated you to edwmnment for to
rag the nhhmhMmhlp lee) prior to
ful
Balance' Map" or services. a1 puadhrss are covered mgardlen Of
iny-da
the anddtlu WRydryPeriod-
f
your
request to time
Account. You inn
Year
Class
8. it You amount or location of pundame.) Plea me re riser ber to sign all
dame
t. Moatu
iococcount
Reiff
our
calling calling
a
onus destroy tear uedkuasd(s) and amount apaccee- ss che duds.
.
T Dose not agaty te ocnsunha nonc?redlt cord accouus
carhael d "NAwrized bh&V ad was using your atraum. ; Does not appyb busian ncrn omdf card &amounts
After your rsputat to done, If you continue to Warned or do Capitol Privacy protection: sae our
not cancel pmkg*dmd bm g wmrgemem, we wfil
comdermcelpl da charge your authorization b keep your
account open. Adt itlondy, your amount will not be dosed Caviar One Is a federally registered 80Vlm mark of Capes One
Financial Corpo dlon- M rights multved. O 2006 Capital One
until you pry all i nvoums you owe as including: any
transactions you taw su ftrited. Nance deluges, post due
fees, ovarlrahl feet, returned payment fees, cash advance
lees and my atwsas aaeeased fat your account You are
responsible for trees amounts whether toy Wpm w You
atMlaht M the Yma you m0uest to don the account or goy
am Incurred atteequsm b you mQhhast to close to account
TNa rosy resultM ldlalgas eppswkg m your amountafar you
have MWBS ed fine accaunl to be closed.
OI DM6056 - 1. 04/10/07
knparwa Nose: Paymak you rea l u u wui becradtsd byer aomu t matte bates dry ae moshil R. parido (1) yos sad TO
tern path dare sshahhhhntedyw drA h is aaraead hehmtwher anabpeeihd (2) Yaks psymae k haos+ed b w pdaaro comas
by 3 pm ET (12 man Pro Plea abrr s4edNe (S) h.k" dyst r peril deeiwy. Ptpub braked by wis any oMe localbn Win
shy rtlheifam cry M te sewed ss dri Mara hacrM sun. Qr buAhut dui w l1crM tvdph SeaorP. anAtwg Ihdwya
Pkae do not use sVn, Pperdp, gt. who pepemhg lour Psynenk-
CAPITAL ONE BANK (USA), N.A.,
Plaintiff,
V.
FREELAND M NGUYEN
Defendant(s).
VERIFICATION
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 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: 1 tL4--X)R
Davina Johnson
A049
WELTMAN, WEINBERG & REIS CO., L.P.A.
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CASE NO: 2008-07337 P SHERIFF'S RETURN - REGULAR
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
CAPITAL ONE BANK (USA) N A
VS
NGUYEN FREELAND M
MARK CONKLIN
Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according
says, the within COMPLAINT & NOTICE to law,
NGUYEN FREELAND M was served upon
DEFENDANT the
at 1900:00 HOURS, on the 30th da
at 903 APPLE DRIVE Y of December 2008
MECHANCISBURG, PA 17055
by handing to
ADEN MILTON, FRIEND,
ADULT IN CHARGE
a true and attested copy of COMPLAINT & NOTICE
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service 18.00
Affidavit 9.90
Surcharge 00
10.00
0
--- .00
37.90
Sworn and Subscibed to
before me this
_day
of
So Answers:
R• Thomas Kline
12/31/2008
WELTMAN WEINBERG REIS
By:
Deputy Sheriff
A.D.
z fti
r -D
C.r
or
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK (USA), NA
Plaintiff
vs.
FREELAND M NGUYEN
Defendant
No. 08-7337 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#06899100
Judgment Amount $ 1,073.64
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. 08-7337 CIVIL TERM
FREELAND M NGUYEN
Defendant
TO THE PROTHONOTARY:
PRAECIPE FOR DEFAULT JUDGMENT
Kindly enter Judgment against the Defendant, FREELAND M NGUYEN above named, in the default of an
Answer, in the amount of $1,073.64 computed as follows:
Amount claimed in Complaint
Amount paid by Defendant
$1,218.75
$250.00
Interest from September 29, 2008 to April 01, 2009
at the legal interest rate of 27.10% per annum $104.89
TOTAL
$1,073.64
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: , v4i??
William T. Molczan, Es ire
PA I.D. #47437
WELTMAN, WEINBERG & REIS CO., L.P.A.
1400 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR#06899100
Plaintiff s address is:
c/o Weltman, Weinberg & Reis Co., L.P.A., 1400 Koppers Building, 436 7s' Avenue, Pittsburgh, PA 15219
And that the last known address of the Defendant is: 903 APPLE DR, MECHANICSBURG, PA 17055
IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK (USA), NA
Case no: 08-7337 CIVIL TERM
Plaintiff
vs
FREELAND M NGUYEN
NON-MILITARY AFFIDAVIT
Defendant
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, FREELAND
M NGUYEN 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, FREELAND M NGUYEN is not in the military service.
Further Affiant sayeth naught.
I
AFFIANT
TO A,ND SUBSCRI ED in my presence this
0rt ( 0f.
?? day
COMMONWEALTH OF PENNSYLVANIA
al
tary Public
ty
heny Coun
s July 15, 2010
Member, Penns?rlvania 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.
Request for Military Status
r
Department of Defense Manpower Data Center
Military Status Report
Pursuant to the Servicemembers Civil Relief Act
Imow
Page 1 of 2
APR-01-2009 10:20:54
"< Last Name First/Middle Begin Date Active Duty Status Service/Agency
NGUYEN FREELAND M 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/fa_q/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 4/1/2009
i
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK (USA),NA
Plaintiff
vs.
FREELAND M NGUYEN
Defendant
TO:
FREELAND M NGUYEN
903 APPLE DR
MECHANICSBURG, PA 17055
Date of Notice: _
Case No. 08-7337 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: j
Matthew Urban
P.A.I.DA 90963
WELTMAN, WEINBERG & REIS CO., L.P.A.
436 Seventh Avenue, 1400 Koppers Building
Pittsburgh, PA 15219
Phone: (412) 434-7955
6899100 N PIT KM3
F LtE -Cl FICF
(jc E ti', frig _rn1; y
2009 APR 20 PM 3: (4
* 14.00 P o A'n'`(
Rl* aayoo I
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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. 08-7337 CIVIL TERM
FREELAND M NGUYEN
Defendant
NOTICE OF JUDGMENT OR ORDER
TO: ( ) Plaintiff
(xx) Defendant
( ) Garnishee
You are hereby notified that the following
Order or ud ent was entered against you
,,;
on YZ.
(xx) Assumpsit Judgment in the amount
of $1,073.64 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:
,T (OR PUTY)
PR ONO
FREELAND M NGUYEN
903 APPLE DR
MECHANICSBURG, PA 17055
Plaintiffs address is:
c/o Weltman, Weinberg & Reis Co., L.P.A., 1400 Koppers Building, 436 7s' Avenue, Pittsburgh, PA 15219
1-888-434-0085
7 1a P om
COUNT
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK (USA),NA
Plaintiff
vs.
FREELAND M NGUYEN
Defendant(s)
No. 08-7337 CIVIL TERM
PRAECIPE FOR SATISFACTION OF
JUDGMENT
FILED ON BEHALF OF
Plaintiff
COUNSEL OF RECORD OF
THIS PARTY:
Lyndsay E Rowland, Esquire
PA I.D. # 205520
WELTMAN, WEINBERG & REIS CO., L.P.A.
1400 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR#6899100 NPE
ct 4-77 x 48
e1 AB sq3
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK (USA),NA
Plaintiff
vs. Civil Action No. 08-7337 CIVIL TERM
FREELAND M NGUYEN
Defendant(s)
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, WFINBERG & REIS CO,,, L.P.A.
By: (.... r-
Lyndsay E R wland, Esquire
PA I.D. # 205 20
WELTMAN, EINBERG & REIS CO., L.P.A.
1400 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR #6899100
Sworn to and suoscried
before me this 1 COMMONWEALTH OF PENNSYLVANIA
day of i Notarial Seal
IJ Wendy L. Gault, Notary Public
City of Pittsburgh, Allegheny County
i My Commission Expires July 15, 2014
NOTARY PUBLIC Member. Pennsvlvania Association of Notaries