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HomeMy WebLinkAbout09-0273IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff No. ~Q - ~,~`f3 ~~ V ~`, L ~C/L-~ vs. TINA M REED Defendant PRAECIPE TO FILE FOREIGN 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#4914708 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. TINA M REED Defendant TO THE PROTHONOTARY: Civil Action No. COQ - a~3 PRAECIPE TO FILE FOREIGN JUDGMENT Please file the enclosed certified transcript of Judgment in accordance with Section B of the Uniform Enforcement of Foreign Judgment Act (42 Pa. C.S.A. Section 4306), and also mail notice of the filing of the Judgment to the Judgment-debtor at the address shown on the attached verification. Amount of Judgment computed as follows: Principal Amount of Judgment $2098 39 Paid on account Interest at the rate of 25.9% per annum on $2098.39 from July 29, 2006 to December 15, 2008 1293.94 Damage Prior Costs 532.05 Total Judgment $3924.38 WELTMAN, WEINBERG &REIS CO., L.P.A. Date: ~~ 1' ---~ By:. William T. Molcza ,Esquire PA I.D. #47437 WELTMAN, WEINBERG &REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 VERIFICATION The undersigned does hereby verify subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities, that the undersigned is the attorney for the Judgment Creditor, Capital One Bank; that the last known address of the Judgment Debtor is 90 Springers Lane Canno, New Cumberland, Pa 17070; that the last known address of the Judgment Creditor is c/o Weltman, Weinberg 8~ Reis Co., L.P.A., 1400 Koppers Building, 436 Seventh Ave, Pittsburgh Pa 15219; that the Foreign Judgment is valid, enforceable and unsatisfied, and that the facts set forth in the foregoing Praecipe are true and correct to the best of the undersigned's knowledge, information and belief. WELTMAN, WEINBERG &REIS CO., L.P.A. William T. Molc ,Esquire PA I.D. #4743 WELTMAN, WEINBERG &REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff TINA M REED vs. Civil Action No. Defendant NOTICE OF JUDGMENT OR ORDER TO: ( )Plaintiff (xx) Defendant ( )Garnishee You are hereby notified that the following Order or Judgment was entered a ainst you on (xx) Assumpsit Judgment in the amount of $3924.38 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 ( ) Default ( ) Verdict ( ) Arbitration Award Prothonotary TINA M REED gy; 90 SPRINGERS LANE CANNO PROT ARY (O DEPUTY) NEW CUMBERLAND PA 17070 , y i OFFICE OF TIE PROTHONOTARY Of York County Pamela S. Lee Prothonotary Billie Jo Bones Deputy Prothonotary Gregory E. Gettle Solicitor York County Judicial Center 45 North George Street York, Pennsylvania 17401 Telephone (717) 771-961 1 CAPITAL ONE BANK Case No. 2006 SU 1940-01 Plaintiff Vs. TINA M REED Defendant To Whom It May Concern: I certify that judgment was entered in favor of CAPITAL ONE BANK and against TINA M REED on the 10TH day of AUGUST, 2006 in said case in the amount of $2,098.39. Total costs paid by plaintiff to the York County Courts equals $532.05. IN TESTIMONY WHEREOF, I have hereunto set my hand and affixed the seal of the Court, on the 2ND day of DECEMBER, 2008. ISG~- ~. Prothonotary By ----------- U~put~ . , ~~W L R ~; • IN THE COURT OF COMMON PLEAS OF YORK COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK, Plaintiff vs. TINA M Rl?ED Defendant No. 2006-SU-] 940-YOl PRAECIPE FOR DEFAULT JUDGMENT .. FILED ON BEHALF OF ~ _ ,y Plaintiff COUNSEL OF RECORD OF THIS I'AR'I'Y: WILLIAM T'. MOLCZAN, ESQUIRE PA LD.#47437 Weltman, Weinberg & Reis Co., L.P.A. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412)434-7955 Vti'WR#04914708 Judgment .4mount $ 2098.39 'T'HIS LAW FIRM 1S ATTEMPTING TO COLLECT _ ~ INFORMATION 013TAINEU WILL BE USED FOR `T'HAT PURPOSI?. ~ ~~ o H O d. O v-- ~ W ~ CN li o N F= U aS Q~ Y W U y- d ~~ N G `s ~, o °~ ~ ~I- ...~Q...1.~.. (.}.~,].~ ~ Fie ~~[~ D~~BT ~OR ITS CLIENT AND ANY y IN THE COURT OF COMMON PLEAS YORK COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK, ~-, Plaintiff "=,' -_ ,. ,, __ vs. Civil Action No. 2006-SU-1940-Y01 `'~ f=~ °' :+J: ,4~ TINA M REED ::-j: =,- - --~ -~ ~_:_~ _ Defendant ;~- PRAECIPE FOR DEFAULTJUDCMENT ~ - TO 'THE PROTHONOTARY: Kindly enter Judgment against the Defendant, TINA M REED above named, in the default of an Answer, in tl~e amount of $2098.39 computed as follows: Amount claimed in Complaint $1993.55 Interest from MAY 16, 2006 TO JULY 29, 2006 at the legal interest rate of 25.9% per annum $104.84 TOTAL $2088,39 1 hereby certify that appropriate Notices of Default, as attached have been mailed in accordance with PA R.C.P. 2>7.1 on the dates indicated on the Notices. VVELTMAN, WEINBERG & RE1S CO., L.P.A. By' ~ --- ~ ~ _~ WILLIAM 1~. MOLCZAN. 1'S UIRF-. PA LD.#47437 Weltman, Weinberg & Reis Co., L.P.A. 2718 Koppers 131dg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 4'4-7~.~..,~.. WWR#`~9~~-~42~9 Plaintit~'s address is: c/o Weltman, Weinberg & Reis Co., L.A.A., 2718 Koppers Building, 436 7`" Avenue, Pittsburgh, PA 15219 And that the last known address of the Defendant is: 90 SPRINGERS LANE' CANNO, NI;WCUMBERLAND,PA 17070 IN THE COURT OF COMMON PLEAS YORK COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff TINA M REED Defendant(s) Case # _ ~C~C~ ` SC~ - I ! ~l (~ ` l C,y 1 i ~:~ ~~. x-- - ti-- c: _- - = v-s-, - ;~ _.., _~, ~.:~_ _,_ „ ~ IMPORTANT NOTICE TO: TINA M REED 90 SPRINGERS LANE CANNO NEWCUMBERLAND,PA 17070 rI. Date of Notice : ~ ` ~~"'CsC.~ WWR#: 04914708 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. 222097 030219 LAWYER REFERRAL SERVICE OF THE YORK COUNTY BAR ASSOCIATION YORK COUNTY BAR CENTER 137 EAST MARKET STREET YORK, PA 17401 (717) 854-8755 JAMES.WARMBRODT, ESQUIRE PA I.:D.~ #42524 WELTMA.I~, WEINBERG & REIS CO., L.P.A. 2718' KIPPERS BLDG, 436 7TH AVE. PITT'S~URGH, PA 15219 IN THE COMMON PLEAS COURT OF YORK COUNTY, PENNSYI_VAN~IA CIVIL DIVISION ,_, ~ ~,, CAPITAL. ONE BANK, r~ i~=:W -! r-' "7 r_. ~..-J - ..... ~^ ' Case no: 2000-SU-1940-Y01~1 `` ~'~ .~ -~, c Plaintiff NON-MILITARY AFFIDAVIT ~-- `"' _ vs. • ' '4` ;~. TINA M REED { Defendant The undersigned, who first being duly s~~~orn, aeccu•din~~ tip l,iw. delx~c~ <mci states as follows: That he/she is the duly authorized agent of the Plaintiff in the within matter. Affiant further states that the within Aftidavit 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, TINA M REED 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, TINA M REED is not in the military service. Further Affiant sayeth naught. N AFEIANT / SWORN TO AND SUBSCRIBED in my presence this ~f day '' .~ - ~ CQMMONWEALTH OF PENN"'~VA_NIAt 1 i' r~ tar ~~ ga ~~ ~__~. h c; , , y ~ ~ j A PUBLIC ,f ~ ,..~~, nt,. ~,+,~{ ~.... ~~ L4i0~'~1'~V'~V4~1#XI~~.t11L1 A5FJf ~Vti,:~'. '~F3~i i "Phis 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 1Vlilitary Status age o Department of Defense Manpower Data Center JUL-29-2006 08:00:04 t~~K"ter .~~ Military Status Report ~ ~~ .~ Pursuant to the Servicemembers Civil Relief Act .~' ~== Last Name First/Middle Begin Date Active lluty Status Service/Agency REED TINA M Based on the information 9u 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 oi' Defense Manpower Data Center, based nn the information that you provided, the above is the current status of the individual as to all branches of the Military. ,- ~. :_~ r _.:. ___ ______-_. .. - "5~ - - _,-, Mary M. Snavely-Dixon, Director ~ -- y u _ Department of Defense -Manpower Data Center ~-, "`' - 1600 Wilson Blvd., Suite 400 M_ -- Arlington, VA 22209-2593 "1'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 eligibility systems. 1'he Department of Def=ense strongly supports the enforcement of the Servicemembers Civil Relief Act [50 USCS Appx. #167;#167; 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 oI'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" iJRI_ 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., ar~•~;,~•iared accuracy of•DOB, a middle name), you can submit your request again at this Web site ~~~~~ ~~l~~~wide a new certificate for that query. This response reflects current active duty status only. I'or historical information, please contact the Military Service SCRA points-of-contact. See: http /,~www.defense]ink.mil/f~q/pis/PC'O~SLD~html WARNING: This certificate was provided based on a name and Social Security number (SSN) provided https://www.dmdc.osd.mil/sera/owa/scra.pre_Select 7/29/2006 by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID: BRXNAMVHCAK ~...~... 22091030219 hops://www.dmdc.osd.mil/scra/owa/scra.prc_ Select 7/29/2006 IN THE COURT OF COMMON PLEAS YORK COUN"i'Y, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK, Plaintiff vs. Civil Action No. 2006-SU-1940-Y01 TINA M REED Defendant N01'ICE OF JUDGMENT OR ORDER TO: ( )Plaintiff (xx) Defendant )Garnishee -'_~' You are hereby notified that the foll,~~~ im~ Order Ju/dygment was entered against you r= •' on 1-L~~ ._ '' (xx) Assumpsit Judgment in the amount .- - ..~. _ of $2098.39 plus costs. '~~' y ,..., ( ) 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, Harrisbw•g, PA. (xx) Entry of Judgment of ( ) Court Order ( ) Non-Pros ( ) Confessiun (xx) Default ( ) Verdict ( ) Arbitration Award Prothonotary B y ----------------- .___--_._.. PROTHONO"GARY (OR DI?PUTY) "TINA M REED 90 SPRINGERS LANE CANNO NEWCUMBERLAND,PA 17070 Plaintiffs address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 136 T~' Avenue, Pittsburgh, PA 15219 1-888-434-0085 b j~ ~ ~ YORK COUNTY PROTHONOTARY Page 1 of 2 12/2/2008 2006-SU-001940-01 CAPITAL ONE BANK vs. REED, TINA M Action 05/11/2007 *SHERIFF RETURN OF SERVICENVRIT OF 04088 EXECUTION AS DIRECTED BY GOLDBECK ( Volume: 00076-Blip: 00383 ) MCCAFFERTY AND MCKEEVER ATTY FOR THE PLTF SHERIFFS SALE CANCELLED 04/30/2007 *PRAECIPE FOR WRIT OF EXEC/PERSONAL .04583 PROPERTY ( Volume: 00062-Blip: 00523 ) 04/30/2007 *WRIT OF EXECUTION ISSUED ON PERSONAL 04312 PROPERTY TO YORK CO SHERIFF ( Volume: 00062-Blip: 00523 ) 04/30/2007 *WRIT OF EXECUTION ISSUED NAMING GARNISHEE 04310 MID PENN BANK ( Volume: 00062-Blip: 00523 ) JUDGMENT AMT: $0.00 DEBTOR(S): <D001GARN001>MID PENN BANK 04/30/2007 *INTERROGATORIES TO GARNISHEE MID PENN BANK 04315 ( Volume: 00062-Blip: 00524 ) 08/10/2006 *JUDGMENT BY DEFAULT ENTERED AGAINST=DEFT 04083 FOR FAILURE TO ANSWER ( Volume: 00103-Blip: 00279 ) JUDGMENT AMT: $2,098.39 DEBTOR(S): <D001DEFT >REED, TINA M 08/10/2006 *FILING FEE ( Volume: 00103-Blip: 00279 ) 08/10/2006 *DEFAULT NOTICE RE: PA R C P 237.1 (DEFENSE) DATED 7/25/06 UPON DEFT ( Volume: 00103-Blip: 00279 ) 08/10/2006 *AFFIDAVIT OF NON-MILITARY SERVICE ( Volume: 00103-Blip: 00279 ) 08/10/2006 *NOTICE GIVEN RE: PA RCP 236 W/DOCUMENTS FILED MAILED @ 3PM TO DEFT (Volume: 00103-Blip: 00279 ) 07/12/2006 *SHERIFF RETURN OF SERVICE compalint served ON TINA REED ON 6-24-06 ( Volume: 00090-Blip: 00151 ) BY YORK CO SHERIFF 06927 04116 02010 05032 04087 o~ 0 N o "' .1 io ~~ ~ ~_ o ~o a oa ~ r- ~, J ~ = N ~- V 'a ~ Y >`~ bjI ~ y YORK COUNT' PROTHONOTARY Page 2 of 2 12/2/2008 2006-SU-001940-01 CAPITAL ONE BANK vs. REED, TINA M Action 06/16/2006 *COMPLAINT IN A CIVIL ACTION=AMT DEMANDED 04063 $1,993.55 W/INT AND COST ( Volume: 00080-Blip: 00240 ) Party Type Party Name G MID PENN BANK P CAPITAL ONE BANK A WARMBRODT, JAMES C D REED, TINA M Total Number of Pages 0 Z F N ^~' l l- N ^~ (? !^^-' l.,• VCL (V ..._ ) ~/ C'? C~° ~. ~'` C~ w t.._ ;s.:~ ~~.? r~'~ J "z'F i , -rt ;~.? ~.t =*°- ..~ ... `..---•~ 0 ~, ~• ~ ~- ~ ~ .~ ~ ~- ~ , -~ _ .~- ~- . ~~ 0 ~ h~