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
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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
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~~[~ D~~BT ~OR ITS CLIENT AND ANY y
IN THE COURT OF COMMON PLEAS YORK COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK,
~-,
Plaintiff "=,'
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,. ,, __
vs. Civil Action No. 2006-SU-1940-Y01 `'~ f=~ °'
:+J: ,4~
TINA M REED ::-j: =,-
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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
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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
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Case no: 2000-SU-1940-Y01~1 `` ~'~
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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
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05032
04087
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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
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