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Home My WebLink About06-4743 ., . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff No. 0(" - i./^lL/3 C"uJ.J T~ vs, COMPLAINT IN CIVIL ACTION CHRISTINE E HARRIS KENNETH R HARRIS 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 FAX: 412-338-7130 WNR#05214649 .' IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs, Civil Action No, CHRISTINE E HARRIS KENNETH R HARRIS 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 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 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. 01.0- (!;v~t/~ CHRISTINE E HARRIS KENNETH R HARRIS Defendants COMPLAINT AND NOW COMES, Plaintiff, by and through its counsel, WELTMAN, WEINBERG & REIS, CO" LPA., and hereby files this Complaint against Defendants, CHRISTINE L HARRIS AND KENNETH R HARRIS, 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, Defendants are adult individuals residing at 22 RABBIT LN NEWVILLE,PA 17241 , 4, Defendants requested the account and made use of said account and has currently a balance due and owing to Plaintiff, as of AUGUST 14, 2006, in the amount of $3371.27, J ,- 5, Although repeatedly requested to do so by Plaintiff, Defendants have willfully failed and/or refused to pay the balance, WHEREFORE, Plaintiff demands Judgment in its favor and against Defendants, CHRISTINE L HARRIS AND KENNETH R HARRIS, jointly and severally, in the amount of $3371,27 with finance charges thereon at the rate of 25,90% per annum from AUGUST 14, 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 W If. T, M LC PA I.D,#47437 Weltman, Weinberg & Reis Co., L.PA 2718 Koppers Bldg, 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 VVVVR#: 05214649 ./ VERIFICATION The undersigned does hereby verify subject to ~~ 18 P A. C.S. 49?4 relating to unsworn falsifications to authorities, that he/she is f ( ) In I () (NAME) C?-.~.h. ~Vl..t..v1~\C , plaintiff herein, that (COMPANY) Po. . ~) of 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 (SIGNATURE) WWR# l .&Q. tA \n ~ ~ - "-> 6 ~ ~ :U ~ ~ r ~~~ "- 2-~~8 ;:, ~ ~:::tl \3';1\'........ ~ :o,~ ~;tL ~ bb. (n.:-:, :~'"1'"' .,...<..",'. .p::;~ .;;:C --<:l ,~Q 7'; C '% '15fT' ~<c: <.? ~ ~ _ A ._ cP SHERIFF'S RETURN - REGULAR. . CASE NO: 2006-04743 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CAPITAL ONE BANK VS HARRIS CHRISTINE E ET AL HAROLD WEARY , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon HARRIS CHRISTINE E the DEFENDANT , at 0955:00 HOURS, on the 30th day of August , 2006 at 22 RABBIT LANE NEWVILLE, PA 17241 by handing to CHRISTINE HARRIS a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 9.68 .00 10.00 .00 37.687 q /;)"1 loy .r%:.~~~ R. Thomas Kline ~. 08/30/2006 WELTMAN WEINBERG REIS Sworn and Subscibed to By: 7WiJ. Deputy Sh-:Aff before me this day of A.D. SHERIFF'S RETURN - REGULAR C' .. CASE NO: 2006-04743 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CAPITAL ONE BANK VS HARRIS CHRISTINE E ET AL HAROLD WEARY , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon HARRIS KENNETH R the DEFENDANT at 0955:00 HOURS, on the 30th day of August , 2006 at 22 RABBIT LANE NEWVILLE, PA 17241 by handing to CHRISTINE HARRIS, WIFE a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 6.00 .00 .00 10.00 .00 16.00/' c;/ .2 1/ ()& So Answers: _;""" 0 ".0;(7 . ?;'<"~: ---,;,;t?o' L...~:;, _., .,."",~,.t' /,d'~:.R' <:i''' .,.".....-~')(..."'~-~ , . '..-' ~,~ ,....~./ .-.- ,..... R. Thomas Kline ~ 08/30/2006 WELTMAN WEINBERG REIS Sworn and Subscibed to By: '7U0~ Deputy Sherlff before me this day of A.D. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPn AL ONE BANK, Plaintiff No. : 06-4743-CIVIL-TERM VS. PRAECIPE FOR DEFAULT JUDGMENT CHRISTINE E HARRIS KENNETH R HARRIS 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.P.A. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#05214649 Judgment Amount $ 3639.19 -- 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. : 06-4743-CIVIL-TERM CHRISTINE E HARRIS KENNETH R HARRIS Defendants PRAECIPE FOR DEF AUL T JUDGMENT TO THE PROTHONOTARY: Kindly enter Judgment against the Defendant, CHRISTINE E HARRIS KENNETH R HARRIS above named, in the default of an Answer, in the amount of $3639.19 computed as follows: Amount claimed in Complaint $3371.27 Interest from AUGUST 14,2006 TO DECEMBER 4,2006 at the legal interest rate of25.9% per annum $267.92 $3639.19 TOTAL 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: tJ~' WILLIAM T. MOLC AN PA LD.#47437 Weltman, Weinberg & Reis Co., L.P.A. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, P A 15219 (412) 434-7955 WWR#05214649 Plaintiff's address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 ih Avenue, Pittsburgh, PA ]5219 And that the last known address of the Defendant is: 22 RABBIT LN NEWVILLE,P A 17241 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK, Plaintiff vs. Civil Action No. : 06-4743-CIVIL-TERM CHRISTINE E HARRIS KENNETH R HARRIS Defendants 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 Uc:r. 13 :too<.. I (xx) Assumpsit Judgment in the amount of$3639.19 plus costs. () Trespass Judgment in the amount of$_ plus costs. () Ifnot satisfied within sixty (60) days, your motor vehicle operator's license and/or registration will be suspended by the Department of Transportatiol1, Bureau of Traffic Safety, Harrisburg, PA. (xx) Entry of Judgment of () Court Order () Non-Pros () Confession (xx) Default () Verdict () Arbitration A ward Prothonotary BY~ PROt'HONOT PUT',',,", CHRISTINE L HARRIS KENNETH R HARRIS 22 RABBIT LN NEWVILLE,PA 17241 Plaintiffs address is: clo Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 ih A venue, Pittsburgh, P A 15219 1-888-434-0085 1!~V::~::: t::,Jp," l'::lii~ 'I' I;~~~~' i!~I'" i,:'I,!If!~'i~'!i" Ii!, ! 11'1'! j'II' !,'I",', " ;",;, ,I i;;~ it.1 I IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Pllintiff I I CHRISTINE L HARRIS Case # D~. L/7 Lf) lr'VtLT;:/?~ Defendant(s) IMPORTANT NOTICE TO: CHRISTINE L HARRIS 22 RABBIT LN NEWVILLE,PA 17241 Date of Notice: II-~ I-(){,. WWR#: 05214649 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 O~JECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLE,S YOU ACT ~ITHIN T~ DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED ~GAINST 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 ASiOCIATION 32 SUTH BEDFO STREET__._~_~ CARL SLE, PA 17013 ~.. ,,' (717~ 249-3166 fa, /1i---------.-.~ ~ ! I ! BRODT, ESQUIRE 42524 CO., L . P . A . 7TH AVE. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION KENNETH R BANK I ! I HARRIS CAPITAL ONE Pl+ntiff Case #06-4743 (rvILTfif~ Defendant(s) IMPORTANT NOTICE TO: KENNETH R HARRIS 22 RABBIT LN NEWVILLE,PA 17241 Date of Notice: WWR#: 05214649 I/-J. f-O~ YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR ,BY ATTORNEY AND FILE IN WRITING WITH THE COUR~ YOUR DEF~SES OR 0 JECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLE,S YOU ACT ~ITHIN TE DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY B~ ENTERED ~GAINST 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 AS OCIATION 32 S~..UTH BEDFOr STREET CARL SLE, PA 17013 (717) 249-3166 -"-'-~'~---:> ~ '" " ..-"-- , ;yL--- .-,.." \ ....." \, .\ BY: , JAMES WARMBRODT, I PA LD. #42 WELTMAN,i W 2718 KOip PITTSB ESQUIRE 24 NBERG & REIS CO., L.P.A. S BLDG, 436 7TH AVE. , PA 15219 IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK, Case no: : 06-4743-CIVIL-TERM Plaintiff NON-MILITARY AFFIDAVIT vs. CHRISTINE E HARRIS KENNETH R HARRIS Defendants 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 111 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, CHRISTINE E HARRIS KENNETH R HARRIS 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, CHRISTINE E HARRIS KENNETH R HARRIS is not in the military service. Further Affiant sayeth naught. u4~ AFFIANT SWORN TO AND SUBSCRIBED in my presence this 4.r- day l:>ectl"'bu . <100(., . NIA COMM~\W~I:'-.u~~g[.P~NNSYL;JVA '.\lul.':Y';~ ;:,ea, . He~' '''e\I~. Notary PubliC \ C"Y~'-~\)"'.. i ' >, . f"~,mmlSSlOn EXplres Nov, (" :~.:::;, . ~-:-sv'vania Associatic.. " /,,,5 'U".........,....."'. eL1f\ This law firm is a debt cdllector attempting to collect this debt for our client and any information obtained will be used for that purpose. R~quest for Military Status Page 1 of2 Department of Defense Manpower Data Center . Military Status Report . Pursuant to the Servicemembers Civil Relief Act DEC-04-200605:12:29 < Last Name FirstlMiddle Begin Date I Active Duty Status I Service/Agency HARRIS CHRISTINE 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 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 ofthe Military. ~~ ~-~ Mary M. Snavely-Dix.on, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, V A 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 De'fense 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 currentlion 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 :(urther verification of the person's active duty status by contacting that person's Military Service via t~e "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 ofDOB, 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 ~urrent active duty status only. For historical information, please contact the Military Service SCRA points-of-contact. See: http://WW1Y.defenselink.mil/faq/pis/PG03SLDR.hwl WARNING: This certificate was provided based on a name and Social Security number (SSN) provided \ https:/ /www.dmdc.osd.mil/scra! owa! sera. prc _Select 12/4/2006 R~quest for Military Status Page 20f2 by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID:BCSOWSEDKVR https:/ /www.dmdc.osd.mil/scra/owa/scra.prc _Select 12/4/2006 R:quest for Military Status Page 1 of2 Department of Defense Manpower Data Center DEC-04-200605:12:56 Military Status Report Pursuant to the Servicemembers Civil Relief Act < Last Name FirstlMiddle Begin Date T Active Duty Status I Service! Agency HARRIS KENNETH R 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. ~Y't. ~-~ Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, V A 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 Ion 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 fa'il 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 ofDOB, 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: hltp;l!www.ddenselink.mil/f~qlpisIPC02~LJ2R.htmJ WARNING: This certificate was provided based on a name and Social Security number (SSN) provided https://www.dmdc.osd.mil/scraJowaJscra.prc_Select 12/4/2006 R~quest for Military Status Page 20f2 by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID:BCSPLKONGTH https:/ /www.dmdc.osd.mil/scra/ owa/scra. prc _Select 12/4/2006 t ~ ~ :;x:) 7' ~ ~ . \\ D "';> 0 t.::::::J 0 c~:) -n ~ ~ L~ """- CJ --I -V -.- (" ~ f'Y1 fi '; 'T1 \' t-; r- - ~n~ ~ r >:)C? Vl ~ w ,~ (.') ~ ()J -~J'f, llJ' f: ~J -: -,"j ~ - ~J. ,--') ... -'''' ~ ~ i:-n -C (..) -~ ~ ~o (.n -<