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Home My WebLink About06-3297 . - ,\ .~. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff No. 0(", - 3.2 97 C;Ut'( ~0LVYJ vs. COMPLAINT IN CIVIL ACTION SHARON L MYERS Defendants FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: . ,WiLLIAM T. MOLCZAN, ESQUIRE PA 1.0.#47437 Weltman, Weinberg & Reis Co., L.PA 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#05216048 ! iL~' . IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVI.SION CAPITAL ONE BANK Plaintiff vs. CiVil Action No. SHARON L MYERS Defendants COMPLAINT IN CIVIL ACTION 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 agains\ you. You are warned that if you fail to do so the case may proceed without you and a judgment m~y,peElntered 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 , ,~i: , LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 !- <.,:,:'.'.:, . IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. Civil Action No. 01-- 1~./17 C/~[L ~~I SHARON L MYERS Defendants COMPLAINT AND NOW COMES, Plaintiff, by and through jts counsel, WELTMAN, WEINBERG & REIS, CO" LPA., and hereby files this Complaint against Defendant, SHARON L MYERS, and, in support thereof, Plaintiff avers as follows: 1. The Plaintiff is a corporation with its principal place of business located at P.O. Box 85147, Richmond, VA 23285, 2. Plaintiff is the owner of this account, which is the subject matter of this action. 3, Defendant is an adult individual residing at 31 BUTTONWOOD LN, CARLlSLE,PA 17013 . .1...;./. . 4, Defendant requested the account and rnade use of said account and has currently a balance due and owing to Plaintiff, as of JUNE 1, 2006, in the amount of $2,234.28, . 5, Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed and/or refused to pay the balance, WHEREFORE, Plaintiff demands Judgment in its favor and against Defendant, SHARON L MYERS, individually, in the amount of $2,23428 with finance charges thereon at the rate of 20,65% per annurn from JUNE 1,2006, plus costs, , (. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED SHALL BE USED FOR THAT PURPOSE. WELTMAN, WEINBERG & REIS, CO., L.PA ~ WILLlA , M;~C , ESQUIRE PA 1.0.#47437 Weltman, Weinberg & Reis Co., L.PA 2718, Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 VWVR#: 05216048 . , . .. VERIFICATION The undersigned does hereby verify subject to the penalties of 18 P A. C.S. 4904 relating to unsworn falsifications to authorities, that he/she is ~ o....ra.- r/L-, 1 hIlt (NAME) ~C\e~) of , plaintiff herein, that (COMPANY) he/she is duly authorized to make this verification, and that the facts set forth in the foregoing Complaint are true and correct to the best ofhis/her knowledge, infonnation and belief. " ~ WWR# .' . t " \-:l ~ ~ ~ lrt 8 {f1 .-.' 0 (') (? U1 V. c...:,.'" -n a'" .-\ "'0 () '- :t:-n - \..:r:\', ~,~~ rne. 4 llJ -cJ --nl~ -..Q W I :l.:~~~;? ~ ~ ;,j:"") 0- - ~ ~ ":;'.) ~ ~ ',:-.) n 'f? 0 ':~:J J:- :< t^", SHERIFF'S RETURN - NOT FOUND CASE NO: 2006-03297 P COMMONTWEALTH OF PENNSYLVANIA COUNTY dF CuMBERLAND t " CAPITAL ONE BANK VS MYERS SHARON 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 MYERS SHARON L but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT & NOTICE , NOT FOUND , as to the within named DEFENDANT , MYERS SHARON L 31 BUTTONWOOD LANE CARLISLE, PA 17013 ALTHOUGH NUMEROUS ATTEMPTS WERE MADE, WE WERE UNABLE TO SERVED DEFENDANT AT GIVEN ADDRESS. Sheriff's Costs: Docketing Service Not Found Surcharge 18.00 8.80 5.00 10.00 .00 41 . 8 0 ,,/ ~ !,~ <(_O~ Subscribed to before WELTMAN WEINBERG REIS 07/10/2006 Sworn and me this day of A.D. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff No. 06-3297 CIVIL TERM vs. MOTION FOR ALTERNATE SERVICE SHARON L MYERS Defendant 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. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR #05216048 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff No. 06-3297 CIVIL TERM vs. SHARON L MYERS Defendant PLAINTIFF'S MOTION FOR ALTERNATE SERVICE AND NOW, comes Plaintiff, by counsel, Weltman, Weinberg & Reis Co., L.P.A. and requests this Honorable Court to enter an Order allowing the Plaintiff to make service upon Defendant, SHARON L MYERS, by certified U.S. Mail and Certificate of Mailing, addressed to 31 Buttonwood Ln, Carlisle,Pa 17013, averring in support thereof the following: 1. On or about JUNE 9, 2006, Plaintiff filed a Complaint in Civil Action against Defendant to recover the unpaid balance due Plaintiff from Defendant in the amount of $2234.28. 2. When the Sheriff of CUMBERLAND County, Pennsylvania, attempted to make servIce of Plaintiffs Complaint on Defendant, the Sheriff was unable to do so, as evidenced by the Sheriff's return, a true and correct copy of which is attached hereto, marked Exhibit "1 ", and made a part hereof. 3. Upon receipt of the Sheriff's return of no service, Plaintiff conducted an investigation with the United States Postal Service to confirm the physical address of the Defendant. WWR #05216048 4. Pursuant to Plaintiffs request for information, the United States Postal Service confirmed Defendant's physical address of 31 Buttonwood Ln, Carlisle,Pa 17013, a true and correct copy of Plaintiff s Postal Request is attached hereto, marked as Exhibit "2", and made a part hereof. 5. Plaintiff conducted an online white pages search and was unable to confirm a current address for Defendant of 31 Buttonwood Ln, Carlisle,Pa 17013. 6. Plaintiff contacted the CUMBERLAND County Tax Assessment office, a representative from which confirmed the Defendant's current physical address as 31 Buttonwood Ln, Carlisle,Pa 17013. 7. Plaintiff requested information from the Department of Motor Vehicles for Defendant and there are vehicles registered to Defendant at 31 Buttonwood Ln, Carlisle,Pa 17013. A true and correct copy of the Motor Vehicle Abstract is attached hereto, marked as Exhibit "3", and made a part hereof. 8. Based upon the foregoing, Plaintiff believes and therefore avers that Defendant is attempting to avoid service of process in the above-captioned matter and Plaintiff therefore seeks an Order of Court, pursuant to Pennsylvania Rule of Civil Procedure 430, granting Plaintiff leave to serve its Complaint on Defendant by alternative means. WWR #05216048 WHEREFORE, Plaintiff requests this Honorable Court to enter an Order pursuant to PA.R.C.P. 430(a), authorizing the Plaintiff to serve Defendant by Certified U.S. Mail and Certificate of Mailing sent to an address (31 Buttonwood Ln, Carlisle,Pa 17013) at which Defendant is presently receiving mail according to information obtained from the Post Office, or by allowing service by a competent adult. ~fP~~ William . Molczan, Esq . e PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, P A 15219 (412) 434-7955 WWR #05216048 SHERIFF'S RETURN - NOT FOUND D>2/ 6ot{~ CASE NO: 2006-03297 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CAPITAL ONE BANK .._ ......'."'..."......... _". V., S ~. .-------- ' , ,...,,';,,-"~: .. -'" ( MYERS SHARON 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 MYERS SHARON L but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT & NOTICE , NOT FOUND , as to the within named DEFENDANT , MYERS SHARON L 31 BUTTONWOOD LANE CARLISLE, PA 17013 ALTHOUGH NUMEROUS ATTEMPTS WERE MADE, WE WERE UNABLE TO SERVED DEFENDANT AT GIVEN ADDRESS. Sheriff's Costs: Docketing Service Not Found Surcharge S~ . /' R. Thomas Kline Sheriff of Cumberland County 18.00 8.80 5.00 10.00 .00 41.80 WELTMAN WEINBERG REIS 07/10/2006 Sworn and Subscribed to before EXHiBIT -L- me this day of A.D. BROOKLYN 1-0"8., 01-1 216.739.5100 BURLINGTON, NJ 609.914.0437 CHICAGO, IL 312.782.9676 CfNClNNA Tl, OH 513.723.2200 CLEVElAND, OB 216.685. iOOO WELTMAN, \WJNBERG & REIs CO., LP.A ATIOR.'\'ElS AT LAw t:e&:m.~~~ :~c:;:;)' r.ea~cJ - ~;~:~~E~S COLUMBUS, OH 614.228.7272 DEERFIELD, IL 847.940.9812 DETROlT, l\n 248.362.61 (X) CROVE CITY, OH 6]4.801.2600 PHILADELPHIA, P) 2]5.599.1500 August 2,2006 Postmaster Carlisle,Pa 17013 Request for Change of Address or Boxholder Information Needed for Service of Legal Process Please furnish the r ew 3cJdress or the name and street address (if a boxholder) for the following: Name: Address: ~j,sm:D.l.J~'yers 31 Buttonweod Ln Carlisle.Pa 17013 NOTE: The name and last known address are required for change of address information. The name, if known, and post office box address are required fo~ boxholder information. The following information is provided in accordance with 39 CFR 265.6(d)(6)(ii). There is no fee for providing boxholder information. The fee for providing change of address information is waived in accordance with 39 CFR 265,6(d)(1) and (2) and corresponding p..,dministrative Support Manual 352.44a and b. 1, Capacity of requesrer: WIlliam T. Molczan, Esquire, Attorney for Plaintiff, Capital One Bank 2. S1atute orregLlcltion ihat empowers me to serve process: N/A 3. The name:,> of all knoNn parties to the litigation: Capital One Bank VS. Sharon L Mvers 4, The Court in which the case has been or will be heard: Court of Common Pleas of Cumberland County '5 Tile docket or other identifying number if one has been issued: 06-3297 Tile capClcity ill whict this individual is to be served: Defendant WARNING THE SUBM:SSION OF Ff\LSE INFORMATION TO aSTIAN AND USE CHANGE OF ADDRESS INFORfv1ATION OR BOXHOLDER INFOMRATION FOR ANY PURPOSE OTHER THAN THE SERVICE OF LEGAL PROCESS IN CONNECTION WITH ACTUAL OR PROSPECTIVE LITIGATION COULD PE~~!JLT :N C!~!!\'Ii"!..t.~. PEN/d TiES !"-!('LU!Jii'lG f>.. F:f'.'E (Y IJr TO $1~,Ci~1a OR :r,1Pf~'SC'~n.~EN; OF (2) TO AVe18 PAYM:::Jn or T:i[ fZE FOR CHANGE OF ADDRESS !NFORM/HION CJF NOT MOhr: THAN 5 YEARS, OR BOTH (TITLE 18 U,S,C SECTION 1001) I certify that the above information is true and that the address information is needed and will be used solely for service of legal process in connection with actual or prospective litigation. k""'2 )' .: /' >;/#~//~ - // I Signature "i ) ,.....// I~"""'~ /, WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 EXHiBIT 2 Brandon W. Holmes Printed Name FOR POST OFFICE USE ONLY BOX HOLDER'S POSTMARK __Not known at aodress given. _Moved, left no forward address No such address, __ No change of address on file )f... Good ;:;lS Addressed NEW ADDRESS or NAME and STREET ADDRESS ,/ PLEASE INDICATE PHYSICAL ADDRESS , / VVVVR#0521604<3 '--... '." ",.."~ PENNSVLVANIA DEPARTMENT OF TRANSPORTATION VEHICLE RECORD ABSTRACT 8/31/06 PAGE 1 276002 062430716000061 008 OWNER SHARON L MYERS 31 BUTTONWOOD LN CM6 POOR 8 CARLISLE PA 17013 LESSEE NONE TITLE NUMBER TAG NUMBER VIN 62798760 EWD8802 IFALP13PIVW158509 TITLE DATE REGISTRATION BODV TVPE ODOMETER READING *NOT THE ACTUAL MILEAGE DUPLICATE TITLE COUNT VEHICLE VEAR STOLEN DATE 01/12/06 EXPIRV DATE: 06/07 SON 140,870* MAKE MODEL RENEWAL WID PREVIOUS TAG LIENS STOPS FORD EST 061803902252237 001 o 1997 YES NO TITLE BRAND INFORMATION NO TITLE BRANDS EXIST FOR THIS TITLE LIEN INFORMATION LIEN HOLDER NO. 1 NAME PAVLESS AUTO SALES ADDRESS: 915 NEWVILLE RD CARLISLE PA 17013 EXPIRATION DATE: 02/23/12 ABA NO : ELT IND: NO 2ND OR 3RD LIENS EXIST FOR THIS TITLE EXHIBIT 3 ADDRESS CORRESPONDENCE TO: DEPARTMENT OF TRANSPORTATION VEHICLE RECORD SERVICES PO BOX 68691 HARRISBURG, PA 17106-8691 INFORMATION: (8:00 IN STATE OUT-OF-STATE TDD IN STATE TDD OUT-OF-STATE WWW.DOT.STATE.PA.US AM TO 6:00 PM) 1-800-932-4600 717-412-5300 1-800-228-0676 717-412-5380 05:2 \toQ-~<8 CERTIFICATE OF SERVICE The undersigned certifies that a true and correct copy of the within Motion for Alternate Service was served on the ~D day of~, 2006, by first class, U.S. Mail, postage-prepaid, addressed as follows: SHARON L MYERS 31 Buttonwood Ln Carlisle,Pa 17013 AttO::~~ WWR #05216048 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK NO. 06-3297 CIVIL TERM Plaintiff vs. SHARON L MYERS Defendant AFFIDAVIT PURSUANT TO PA R.C.P. 430 (a) BEFORE ME, a Notary Public, in and for the foregoing County and Commonwealth, personally appeared William T. Molczan, Esquire, of Weltman, Weinberg & Reis, Co., L.P.A., attorneys for Plaintiff, and deposes and says that the following accurately reflects efforts made to ascertain the exact whereabouts of Defendant named in the above-captioned matter. a. Plaintiff requested current address information from the United States Postal Service, which request for information confirmed the current address for Defendant as being 31 Buttonwood Ln, Carlisle,Pa 17013. A true and correct copy of the Postal Service Return is marked Exhibit "2" attached hereto and made a part hereof. b. Plaintiff requested a vehicle search on the Defendant, which shows that the Defendant has a registered vehicle at 31 Buttonwood Ln, Carlisle,Pa 17013. A true and correct copy is attached hereto and marked as Exhibit "3". WWR #05216048 . . Finally, Affiant deposes and says that after the foregoing investigation, the exact whereabouts of the Defendant, SHARON L MYERS, is 31 Buttonwood Ln, Carlisle,Pa 17013. WEL TMAN, WEINBERG & REIS, CO., L.P.A. tv;t0:~ William T. Molc , Es . e PA I.D. #47437 WEL TMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, P A 15219 (412) 434-7955 COMMONWEALTH OF PENNSYLVANIA Notarial Seal . ~...rI., L Gault NotarY PublIC Wt1I1U7' h 'Allegheny County City Of pjttsbUrg , 010 :^"Inn Expires July 15. 2 My eomm~' , Member, pennsylvania Association of Notanes WWR #05216048 L__ 2- ~ G"J "'Q, I' ~; r!,. ~" ~l 1.{, (:~ C;::'C ":/ :2 '2, .:;:;,;) i.:;;t.... ~ ~ ~ ~ ~~ f\ ........ :B'q Q\ri. g._~I~ . ::J:!: . ::>- 9 ~ "-R ~ c.~ I (I r- '."('1, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL V ANIAld CIVIL DIVISION CAPITAL ONE BANK Plaintiff No. 06-3297 CIVIL TERM vs. SHARON L MYERS ORDER OF COURT AND NOW, to-wit, this 3e:t day of p~, 2006, upon consideration of the foregoing Motion for Service of the Complaint Pursuant to Special Order of Court and attached supporting affidavit, it is hereby ORDERED, ADJUDGED AND DECREED, that the service of the Complaint in Civil Action may be made on Defendant, SHARON L MYERS, by permitting the Plaintiff to mail a copy of the Complaint to the Defendant the last known address being 31 Buttonwood Ln, Carlisle,Pa 17013 by Certified Mail and by Certificate of Mailing Postal Form 3817, postage prepaid. Service to be completed upon mailing. 1. 11~3-()fc ~ ~ ys WWR #05216048 \i\\"N j\\),f}>.\\ ,~3d < , ._<' ,_<,~i~\''''/.\ t \" \"r,," ",,\\~l,,\ Iv 1;,;.\,,-1 II.', ..' .,.' , \:(, $, I,\d t- ,()\i ~~~t ,',r,.J\"""'I,'u.\,V,;,j 3\41 .J.O j\o'J,.v: ".,)\ w,,.I~:;.:-..,\ -11.....,,$('\-\ \-\ \b :h"""" ,,. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK vs. No. 06-3297 CIVIL TERM PRAECIPE TO REINSTATE COMPLAINT Plaintiff SHARON L MYERS Defendant FILED ON BEHALF OF Plaintiff I COUNSEL OF RI=CORD OF THIS PARTY: ' I James C. Warm~rodt, 42524 WELTMAN, WEIINBERG & REIS CO., L.PA 436 Seventh Avejnue, Suite 2718 pittsburgh, PA 1$219 (421) 434-7955 FAX: 412-338-7130 WWR#05216048 - .. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. Civil Action No. 0$-3297 CIVIL TERM SHARON L MYERS Defendant PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. WELTMAN, W !INBERG & REIS CO., L.PA By: James C. Warm brodt, 42524 (') c ~ Llli' s:!~/ ' Z! (/) ~<.. ""-.. r-' ~?,~.- ):; I~Z~" -7 :3 " ~ <<:::) = c;r. o fT1 C'") f CJ1 ~ ~:n r-- ~g9 9C) -'1"4 "~t ;;'5'1 :;"'0 l5m -:-/ ~ -< :b> ~ 1..0 N N IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSVLV ANIA ClVILOIVISION CAPITAL ONE BANK Plaintiff No, 06,.3291 CIVIL TERM VS, AFFIDAVIT OF SERVICE OF COMPLAINT SHARON L MYERS Defendant PILED ON BEHALF OF Plaintiff COUNSEL OF RBCORD OF THIS PARTV: WilUl,im T. Molc:zan. E$qube PA 1.0. #47437 WELTMAN, WEINBERG & REIS CO" L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, P A 15219 (412) 434,.1955 WWR,#OS216048 . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION eAPIT AI. ONE 8ANI\ Plaintiff y$" No, 06~n91 CIVIL TERM SHAliO~ L MYERS Defendant AlPIJl! Vl19F sBl;lvleE~F ~2MI!~^~N'f BEFORE ME, the undersigned authority, personally appeared William T, Molezan, Esquire, who according to law deposes and says that a copy of the Complaint in Civil Action has been served on the Defendant, SHARON L MYERS. I. On or about NOVEMBBR 3,2006, Pla.intiffreGeived a sigo@d Order ofCouvt permitting slimtlce, on the Defendant. to be complete and valid upon mailing to the complaint by first class mail, certificate of mailing and by certified mail, return receipt requested. Said Order of Court is attached as Exhibit "1". 2, On or about DECEMBER II, 2006, Plaintiff mailed the complaint to 31 BUTTONWOOD LN, CARLISLE,P A 1 iO 13 . Said certificate of mailing and certified mail receipts are attached as Exhibit "2'\ WELTMAN, WINBERG" REIS, GO" Lfl,A. ""~':'~~~" lA, WHliiim'f: MolQi I PA 1.0, #41431 WEL 'fMAN, W '1NSeR6 & REI8 eo., L.PA 2718 Koppers Building 4SE;l Sev~H'lth Avenue Pitt$burQh, PA 15219 (412) 4~4&~7955 WWR#O~2 16048 ,~ ~A."""H*yAtilc etOfPllltllDa.AltiJlmlQu1ly j My m&klnExpB........O Member. Penn8Vfv8nle Association ofNot8rle8 I ' ~~ L ; -' it' ;- .. r ,"~ r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL V ANIAfi4 CIVIL DIVISION CAPITAL ONE BANK Plaintiff No. 06-3297 CIVIL TERM vs. SHARON L MYERS AND NOW, to-wit, this ORDER OF COURT 3'" day of ~~. 2006, upon consideration of the foregoing Motion for Service of the Complaint Pursuant to Special Order of Court and attached supporting affidavit, it is hereby ORDERED, ADJUDGED AND DECREED, that the service of the Complaint in Civil Action may be made on Defendant, SHARON L MYERS, by permitting the Plaintiff to mail a copy of the Complaint to the Defendant the last known address being 31 Buttonwood Ln, Carlisle,Pa 17013 by Certified Mail and by Certificate of Mailing Postal Form 3817, postage prepaid. Service to be completed upon mailing. -~-""'--, CBYTHE COURT: ') --~ J. fIIItIE ~ '~. ,," TfIII rnvM AeCOfI) . -........r...~. f here unto_",,. the ... aI ., C,- 'Ca.... PI j~'1 /1t~~o1: ~LJ1' WWRM16048 VOG .. "Y U.S. Postal Service!", CERTIFIED MAIL" RECEIPT (Domestic Mail Only; No Insurance Coverage ProvIded) ...a [T' rtJ [T' ...a ...a a- ~ OFFICIAL POlIllIge $ ~ rtJ CJ CerIIIled Fee CJ CJ~~ CJ Reallfcled De/!vely Fee r"I (Endorsement Required) r"I fTI Lt'J CJ CJ I"- Postmark " ""' HeAl U.S. POSTAl.. SERVICE CERTIFICATE OF MAJUNG MAY BE USED FOR COMEsrc PJiO trrE;lNATIONAI. LloIJl.. OOES NOT PROVIOE FOft ~TNASTER . , Roaivwf FRll1C . Weltr.8n, Weinbeig & Rei~ Co., Lp A. Z:"",!g Y.sp.p~ ;:~d;. 436 "jff1 Avenue Fitt..bw.gl.. F.:' 1:;;;t; (412) 434-7955 PS Form 3817. JanJaty 2001 I 0(00) . . ~ Il)g ~ I. ~ ~: ~ ~II~ g; 8 I ~ w <.) ~,ii: "70 ~ .p 0>2 ~ rl ~ ~ $. '''}:2;:; 0 '-a, :-or.,...c ~,,::l ?'~ ~ N g <( QJ..!INO Co Co :2 II r-.3 = = --' <- .....,... 2: ~ ~-n i-I1P1 -O~ ~ny qQ -c:i-l i-)t~ :2,.n o --I ~ CD -0 ::t: c.;? o w IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK, Plaintiff No. 06-3297- CIVIL TERM VS. PRAECIPE FOR DEF AUL T JUDGMENT SHARON L MYERS Defendant 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. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, P A 15219 (412) 434-7955 WWR#052] 6048 Judgment Amount $ 2575.57 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, Plaintiff vs. Civil Action No. 06-3297- CIVIL TERM SHARON L MYERS Defendant PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter Judgment against the Defendant, SHARON L MYERS above named, in the default of an Answer, in the amount of $2575.57 computed as follows: Amount claimed in Complaint $2234.28 Interest from JUNE I, 2006 TO FEB. 26, 2007 at the legal interest rate of 20.65% per annum $341.29 TOTAL $2575.57 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 PA I.D.#47437 Weltman, Weinberg & Reis Co., L.P.A. 2718 Koppers Bldg. 436 Seventh A venue Pittsburgh, P A 15219 (412) 434-7955 WWR#05216048 Plaintiffs address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7th Avenue, Pittsburgh, PA 15219 And that the last known address of the Defendant is: 31 BUTTONWOOD LN, CARLISLE,PA 17013 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK, Plaintiff vs. Civil Action No. 06-3297- CIVIL TERM SHARON L MYERS Defendant NOTICE OF JUDGMENT OR ORDER TO: () Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the following Order or Judgment was entered against you on .:} l:l.l I {')1 I I (xx) Assumpsit Judgment in the amount of$2575.57 plus costs. () Trespass Judgment in the amount of$_ plus costs. () Ifnot 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 SHARON L MYERS 31 BUTTONWOOD LN CARLISLE,PA 17013 ) Plaintiffs address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7th Avenue, Pittsburgh, PA 15219 1-888-434-0085 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff Case # L)~ - 3'J. 9 '7 C Iv r L- iff( pt.... SHARON L MYERS Defendant(s) IMPORTANT NOTICE TO: SHARON L MYERS 31 BUTTONWOOD LN CARLISLE,PA 17013 Date of Notice: WWR#: 05216048 3~;} -61 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. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 BY: ~ -;:X~4A (,.()ooe"'40-- PATRICK THOMAS WOODMAN PA 1. D. #34507 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 KOPPERS BLDG, 436 7TH AVE. PITTSBURGH, PA 15219 IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK, Case no: 06-3297- CIVIL TERM Plaintiff NON-MILITARY AFFIDAVIT vs. SHARON L MYERS 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. S 521. Affiant further states that based upon investigation it is the affiant's belief that the Defendant, SHARON L MYERS 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, SHARON L MYERS is not in the military service. [/~~ AFFIANT D SUBSCRIBED in my presence this ~ day . ct) "7 COMMONWEALlH Qf..PENNSYLVANIA Notaria! Sf';'!\ . C~ ,.," "'ry Public Wen'."'l .,;w, ,'."d CityOf'pJ:-,~;,.,r", '. ,,(~.C\nenyCounty I"""~ _" 010 My Comrr',.,,'<if' '-\JY ,duly 15, 2 !") 1~~V:;n-;-A;:;ociatior, of Nota(ie~ Member. ,ef'll Further Affiant sayeth naught. 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 Page 1 of2 Department of Defense Manpower Data Center . Military Status Report Pursuant to the Servicemembers Civil Relief Act FEB-26-2007 11 :19:43 < Last Name FirstlMiddle Begin Date I Active Duty Status I Servicel Agency MYERS SHARON L 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 ofthe 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. ~y.\. ~-~ 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. #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 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: ~ttp) /www.defenselink.millfaq/pis/PC09SLDR.html WARNING: This certificate was provided based on a name and Social Security number (SSN) provided https:/ /www.dmdc.osd.mil/scral owalscra. prc _Select 2/26/2007 Request for Military Status Page 20f2 by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID:BWEOPEKVBVX https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 2/26/2007 ~ G'i\~ ~ 0 ~ :;() ~ -V ~ ~ ~ f ~ Vi ~ :tJ t~--J:=. ~ o c S. l.i O..J :~_!.~.rc; (/ ~ J~ (.'_; 5~ ~ ~ = = ......... :::;: :P" :;::0 N W :::z -"-~ ~ ~,:tI nr- -om :0 1? 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