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Home My WebLink About09-1220r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff No: 09 - 1aa0 Civ;l ex VS. COMPLAINT IN CIVIL ACTION NATALIE C STEFFY 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 07061764 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 NATALIE C STEFFY 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 w 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: NATALIE C STEFFY 416 C ST CARLISLE, PA 17013 3. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXX7911 . 4. Defendant made use of said credit card and has a current balance due of $1457.19 , as of November 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 25.100% per annum on the unpaid balance from November 18, 2008 . A copy of Plaintiff's STATEMENT is attached hereto, marked as Exhibit 111" and made a part hereof. w J 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 , NATALIE C STEFFY , INDIVIDUALLY , in the amount of $1457.19 with continuing interest thereon at the rate of 25.100% per annum from November 18, 2008 plus costs. James C. a ro t,42524 WELTMAN, W NBERG & REIS CO., L.P.A. 436 Sev t Avenue, Suite 1400 Pittsb g , PA 15219 (412) 3 -7955 FAX: -338-7130 07061 4 C N Pit IAS 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. FINANCE Prswbeea Rdwx Payments 6 QWb CHAIM Truwdlona New BabLra a MldRo m Peganart Due Dab C$1,155.68 - $0.00 + $24.97 + $39.00 $1,219.66 $204.00 Mtey. 06, 2008 Mar. 06, 2008 - Apr. 05, 2008 Page 1 of 1 tllasarCeltt Pblirsn llcealrt N754W3M* M1 Your AtaoDlRtt lRIm fig n TOTAL CREDIT LINE $750.00 TOTAL AVAILABLE CREDIT $D.OD CREDIT LINE FOR CASH $750.00 AVAILABLE CREDIT FOR CASH $0.00 Ruatn:e awoes (Pow sea averse far arpabra nW t n) Bebnce rate Parodic Cmvgmn*g FINNCE Row b rate APR CWIROE Pl VMM $1,16536 0.08BM D 25.19% $24.97 Cash $0.00 0.06590% D 25.19% $100 ANNUAL POC'9iE TADS RATE appNd a* pabd: 33 M ® rwla 1tpPrb re t7 -road Oebrrr & Mum orb sport a bit or sban csd ® land peyraerr b: 0rpW0r*9(t1SgNA•PO Bm7L1BB4.Otatb,NCZWM Saved k"welw b: Opibt ow P 0 Buk 3aPq5•Shcde C1, Ur 54L3C M tore a queen" dodo derga on yam dale aunt? PbwreferbtleBorgR ft SunnarymI»backcfymr statenlert or vet %nvwpapWInepmVdwubs P EASE MM AT LEAS' 'HIS ASIA NT Your mmut o ask oaymrtente baled Ifwe Grego off ymr amour de b bb oymarm, we vd report Be dugsktdF stairs b sand no" salt t oom and the Redone APR es reflected on lrs atalemert wd be ap AW b d yaw oubmndng belorm Act war b moot Ble ham wpo," Plesee aytloamoudd onymydelo leltor gaeusacall d1W09% 60 WAwaawlaryousoymcan taro catbd dyw oum nt and dart redidly yw seat win C.ptd Ore "Mm ako NOW* Under thetrmeweplaamydoted byou,yamaaautasrowefgbbteron ranw n And Pe cat bge Raley (APRs) o feebe aramklatey Fb NWW C M One hey ebciad notbroosi rAPRsdthebme Plowbooiindtd(youfdbWWyourmcwitngood atardrg, Capiol Oro reserves the rgtkt b ra®e ymrAPRs n the Wo. . Crta to dE Alalefinellb TrlBleaatlotls 1 OS APR PAST DUE FEE $3900 Yar o=urt a 90 days past due ad your Payment ftl ecton cwmlge has been ausperbad As stated nyourPotmiotRol comae sonto ymrbmmWendmarshy0"w9bo meaebtedoncope saw t is nD topper 90 rays pad are. You may all be dgbb br 1 , efile b be pd b yar amount for bayevertbdeeabednyorPeymentp,01 chasepeemattCalSbrnbKWOW"Sonimet I-OW527 M b w (yaw sluebm gAffm ter berrelb Your a=urd has gore over b aid init. To avail willixel m acrd bey, plow Fay eraogh to WV yourbdaeae briaryouraedt int mmedeiey. endmd?esusyouroman bebwyaraedtisd Plow be an b eccvrat far ery iLra purchase, bee. era Illeloe dorges You were e9waed a past ds be became yam minintan peymaty ea rot rebsved by the de dab To mord tMa lean the babe, we moamniv tttdyau dew d lead 7 bkereea dye foryomw somas payment b mach GWM One. till 1? PLEASE RETURN PORTION BELOW WITH PAYMENT OR LDG ON TO WiMW CCAPMALONECOM TO MAKE YOUR PAYMENT ONLINE ??..a?? 0 5178057325067911 05 1219650210000204007 ?.APUNO' what's in your wallet?` Account Number: 5175-0573-2506-7911 New Babace Mkimu I Payment Mlle Dale Pbara prat addrec or phone number dionget bebw ung bko or bb& ink $1,219.66 $204.00 May. 05, 2008 Ad*W PU7LSE PAYAT LTAST scary Anerrr yo,,, THISAMOUNT Errrrao6lea Amount Enclosed #9009764178390129# MAIL ID NUMBER NATALIE C STEFFY 418 C ST Capital Ors Bk(USA),NA ?r?tr?rrm??rr?r?r??rr? CARLISLE, PA 17013-1633 P.O. Box Charlottol,C426272-0664 7061764 Pleas write y9ur account nwrbor on your dooi or ITaauy order made paysbleto Capial one sIdUSN,NAarLd mail with th's ookryon in the encloeed errrebpe. CAPITAL ONE BANK (USA), N.A., Plaintiff, V. NATALIE C STEFFY Defendant(s). VERIFICATION The undersigned does hereby verify subject to the penalties of 18 Pa.C.S. Section 4904 relating to unswom falsification to authorities, that he/she is an authorized agent of 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. 2,A-2 Dated: Darious Nelson A049 WELTMAN, WEINBERG & REIS CO., L.P.A. ? O atv% tp V _ Sheriffs Office of Cumberland County R Thomas Kline qtr of t isfnbrrfi? Edward L Schorpp Sheriff 4610 Solicitor Ronny R Anderson Jody S Smith Chief Deputy !OFFICE of rHE EHERIRF Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 03/05/2009 10:41 AM - Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on March 6, 2009 at 1041 hrs she served the within Complaint and Notice upon the within named defedant, to wit: Natalie C. Steffy, by making known unto Richard Steffy, husband of defendant, at 416 C Street, Carlisle, PA and made known unto him the contents thereof. SHERIFF COST: $32.50 (PAID) SO ANSWE S, March 09, 2009 R THOMAS KLINE, SHERIFF Docket No. 2009-1220 Capital One Bank (USA), NA v Natalie C. Steffy -Deputy She i n- Fn , Y ?J IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA), NA Plaintiff VS. NATALIE C STEFFY Defendant No. 09-1220 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#07061764 Judgment Amount $ 1,607.31 r I IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA), NA Plaintiff VS. Civil Action No. 09-1220 CIVIL TERM NATALIE C STEFFY Defendant TO THE PROTHONOTARY: PRAEC11PE FOR DEFAULT JUDGMENT Kindly enter Judgment against the Defendant, NATALIE C STEFFY above named, in the default of an Answer, in the amount of $1,607.31 computed as follows: Amount claimed in Complaint $1,457.19 Interest from November 18, 2008 to May 07, 2009 at the legal interest rate of 25.10% per annum $150.12 TOTAL $1,607.31 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: IN ?-- Williafn T. Molczan, Esq / e PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 14)0 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#07061764 Plaintiffs 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: 416 C ST, CARLISLE, PA 17013 i'f IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA), NA Plaintiff VS. NATALIE C STEFFY Defendant Case no: 09-1220 CIVIL TERM NON-M1TdTARY 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, NATALIE C STEFFY 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, NATALIE C STEFFY is not in the military service. Further Affiant sayeth naught. AFFIANT SWORN TO AND SUBSCRIBED in my presence this a day of Gi 'c4m . NO RY PUB comma W P INSYLVANIA Neurw $01 Wayne A. Jop,", Nohry Public Ctty ly at PNhb ANeOMny county My of P N4R ,RIM 20, 2010 Noterm Member, Penn?yN etlon of Request for Military Status Department of Defense Manpower Data Center } Military Status Report Pursuant to the Servicemembers Civil Relief Act Page 1 of 1 MAY-04-2009 07:14:42 ., Last Name First/Middle Begin Date Active Duty Status Service/Agency STEFFY NATALIE 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. y6t 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. H 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: hM://www.defenselink.mil/'faq/pis/PC09SLDR.htm1 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: VVDCGPFTIG https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 5/4/2009 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff VS. NATALIE C STEFFY Defendant TO: NATALIE C STEFFY 416 C ST CARLISLE, PA 17013 Date of Notice: Case No. 09-1220 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 WELT *N, WEINBERG & REIS CO., L.P.A. By: - Me ew 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 7061764 N PIT M4C t"O rIC TH Y ,. u Pi,I 12 -- e 20lu 91'i a '12' pp AN*'/ ? 1q', o0 ?? 4o4bcc+?Ep ou "U)AW I , ` IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA), NA Plaintiff VS. Civil Action No. 09-1220 CIVIL TERM NATALIE C STEFFY 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 S/ L AD To on (xx) Assumpsit Judgment in the amount of $1,607.31 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 ( ) t: onfession (xx) Default ( ) Verdict ( ) Arbitration Award Prothonotary By: PR THONOTAR TY) 2AY4 NATALIE C STEFFY 416 C ST CARLISLE, PA 17013 Plaintiffs address, is: c/o Weltman, Weinberg & Reis Co., L.P.A., 1400 Koppers Building, 436 7`s Avenue, Pittsburgh, PA 15219 1-888-434-0085