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Home My WebLink About06-6034 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE F.S.B. Plaintiff No: O~. {PO 3lJ C~ I.t- vs. COMPLAINT IN CIVIL ACTION PEGGY WILSON 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 2718 Pittsburgh, PA 15219 (412) 434-7955 FAX: 412-338-7130 05358629 C N Pit SGM IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE F.S.B. Plaintiff Civil Action No ()/.., ~ (", 0 3\f ~ IQ.A-.. vs. PEGGY WILSON 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 COMPLAINT 1. Plaintiff, CAPITAL ONE F.S.B. is a corporation with offices at 100 EAST SHORE DR GLEN ALLEN , VA 23059 . 2. Defendant is adult individual(s) residing at the address listed below: PEGGY WILSON 202 W MAIN ST MECHANICSBURG, PA 17055 3. Defendant applied for and received a credit card bearing the account number 5178051793383231 . 4. Defendant made use of said credit card and has a current balance due of $1075.83 , as of August 22, 2006 . 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 25.900% per annum on the unpaid balance from August 22, 2006 A copy of Plaintiff's STATEMENT is attached hereto, marked as Exhibit "1" and made a part hereof. 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 , PEGGY WILSON , INDIVIDUALLY , in the amount of $1075.83 with continuing interest thereon at the rate of 25.900% per annum from August 22, 2006 plus costs. ?:':::><;- Warmbrodt,42524 , WEINBERG & REIS CO., L.P.A. eventh Avenue, Suite 2718 burgh, PA 15219 434-7955 C N Pit SGM / This law firm is a debt collector qtyempting to collect this debt for our client and any information obta1ned will be used for that purpose. r--------------------------------------------------------------------------------------------------, 003 Remember: Mother's Day is Sunday, May 14th 1.800.flower~om~ Call1-800-FLOWERS. (1-800-356-9377) or Click www.1800flowers.com today! Your florist of choice. ! L__________________________________________________________________________________________________~ Show Mom your love! Special savings for Capital One" Cardholders! . ' 15 OJ( * Save 0 on your next purchase when you use Promotion Code CAP66 (See reverse for details) Save this code! Offer good all year long! Capita.One" PLATINUM MASTERCARD ACCOUNT 5178-0517-9338-3231 MAR 24 - APR 23, 2005 Page 1 of 1 Account Summary Previous Balance Payments, Credits and Adjustments Transactions Finance Charges Payments, Credits and Adjustments $751.18 $.00 $33,00 $16.70 Tmnsactions 1 23APR CAPITALONEMONTHLYMEMBERFEE 2 23 APR PAST DUE FEE $4.00 29.00 New Balance Minimum Amount Due Payment Due Date $800.88 $800.88 May 23, 2005 $400 $,00 $400 $,00 You were assessed a past due fee of $29.00 on 04/23/2005 because your minimum payment was not received hythe due date of 04/23/2005. To avoid this fee in the future, we recommend that you allow at least 7 business days for your payment to reach Capital One. Total Credit Line Total A vailahle Credit Credit Line for Cash Available Credit for Cash At your service To call Customer Relations or to report a lost or stolen card.: 1-800-955-7070 Send paymmts to: Ann: Remittance Processing Capital One, F,S,B, P,O, Boo< 790217 St LoW., MO 63179-0217 Send inquirie to: EXHIBIT (I I II Capital One Services P,O, Box 85015 IUcbmond, VA 23285-5015 Finance Charges Cl " '" '" PURCHASES CASH SPECIAL TRANSFERS Baltmu "alt appluJto $418,37 $,00 $340,98 PkllJe see rt'VeT.U .Jide f(}T important information Pr;;:K C""'lPRJing ~8~ ,07096% 25,90% $9,20 ,07096% 25,90% $,00 ,07096% 25,90% $7.50 ANNUAL PERCENTAGE RATE applied this period 25.90% T PLEASE RETURN PORTION BELOW WITH PAYMENT T CapIta'One" 0000000 7 5178051793383231 23 0800880045000800881 New Balance Minimum Amount Due Payment Due Date $800.88 $800.88 May 23,2005 PltllSt print 1Miii1l& adJnss tmJ/or t-mlliI changes 11t10fJ) using blUi or blid id. Street Apt,' I 5178-0517-9338-3231 City s~" ZIP Total enclosed Account Number: Home Phone Alternate Phone Email Address @ -, Capital One, F.S.B. I I P.O. Box 790217 1,1"lmll,I"I"I, St. Louis, MO 63179-0217 1,11""11""111",11,1"11.""1,1",111,,,1,,,111,,,1,11,,1 - ",- .. M "' g - #9011487416775721# MAIL ID NUMBER PEGGY WILSON 202 W MAIN ST MECHANICSBURG PA 17055-6227 r - - - Please write your account number on your check. fir money urier 11UlIk payable to Capital One, FS.B. /Jntl mail in the enclosed envelope. . . . peoplepc'. online '--/ A better way to Internet. UNLIMITED INTERNET ACCESS ~ 1.888.587.9669 ~ Mention Offer Code: DOLLAR Visit www.peoplepc.com/go/dollar PeopIePC ~ solely rospon~ble for th~ offer, and ~ not affiUaled with Capil~ One, Cap~~ One does nol provide, endorse or guarani.., and ~ nOl affiliated w~h, any product or service shown here, Any trademarks mentioned heren are solely owned by lhe respective entity, .AJI rights reserved, By reaponclng 10 this offer, you may be conmricating information aboot yourself 10 the company that pw.;des 111~ product - for example, 1I1al you arl! a Capnel Ooe customer, 'PeoPePC Oome: First 3 months ... biRed al $4,97 per month; $9,95 per month 1I1""after: Offer available to new diaH.ip subscribers at 1eas118 years of age and may no! be redeemed wi1l1 any other offer, Offer sL.tJject 10 change at any lime. Phone lechniceJ support available for $\,95 per minu1e. tAcceJerator ~ flee lor 12 months. Offer good for limned lime. After the first 12 months, the AcceJerated service will automaticoJly revert 10 the at<r1danj PeopIePC Online service. Offer subject to cha1ge at anytlne. Wrth PeoplePC Ooine Accelerated, cel1~n Web page text and lJlIp/lics wid load faster when compa'ed to standard di~-l.ip Internet service, ActuW lOSulls may val}', PeoplePC Online Acceleraled ~ oniy compatible with PeopIePC Online Intemetservice and specified Wrrdows<PI browsee;, PeopIePC Orline Acceleraled is not compatible wilh I'Vindows41 95 with IE 5,5 SP2, Service nOl available in ell areas, _ fees, taxes, and other fees and restrictions may apply, Telephone tOIl c~ may apply, even dCling lIial periods. Yoo are responsibie for determi1in9 _ a ceJl to one of oor access numbers will 1OSl.lt in lelepIlone 101 charges, _ may be limned, especIal~ dtJnng Umes of peak usage, Diel-l.ip numbers may be changed al PeopIePC's discret"n. Continuous use subject to timeout ptOCedures. AU use is subject to PeopIePC Online's Services Agreement and Accept~e Use PolJC}', 56K is the maximum speed of SlllVlce; actual speed may val}', C 2005 PeopIePC Ine, All R'JIlls Reserved, PeopIePC Onr.... and its logos are lradema1<s of PeoplePC in the U.S, and other oountTies, e 2005 Cap~eI One Services, klc, Capital One ~ e federally reg~tered service marl<, AU righls reselVed, - !!!!!!! - - ~ - - - ~ !!!!!!! - !!!!!!! - - - - - - ~ !!!!!!! - - - !!!!!!! - - - - - - - - - - ~ !!!!!!! 1. How To Awid A Fnmc. o,-ve. periocic rate. To ob1ain the average daily balance fOf the t a. Grace hriDd. You will have a minim...,.. grace period of billing period covered by tnis statement, we take the ~Ia~-:t=~~:~..=r ~~chn:w~::a='o= ~~~lt~":~ ::;.:,.~~ :;,.ct;a~~'n;~l!I~~':W charges jf you pay your total "New Balance-, in or credits. (If the code N appears: on the front of this accordance \/VIm the Imponant Notice for payments below, statement next to -Balance Rate Applied To, - we also and in time fOf it to be credited by your next statement subtract any lrIpaid finance charge induded in the balance closing date. There is no grace period on cash advances of each segment.) Ttis gives us the daily balance of each and special transfera. In addition, there is no grace period segment. Then, we ac:k:l up all the daily balances for each on any transaction jf you do not pay the total -Now segment for the billing period and di....de by the total balance. - runber of days in the billing period. This gi\leS us the b. Accnmg Fin~. Dw'ge. Transactions which are not average daily balance of each segment. subject to 8 grace period are assessed finance charge 1 I 3. ArnmI '.cent. Rm.. IAPRI. from the date of the transaction or 2} from the date the a. The term -Annual Percentage Rate- may appear as transaction is processed to your Accolnt or 3) from the - APW on the from of this statement. first calendar day of the current billing period. Additionally, b. If the code P (Primel. L (3.mo. lIBOR), C (Cenificate of if you did not pay the "New Balance- from the previous DepOSit), or S (Bankcard Prime) appears on the front of ~~(lo!;~ ~a~ ~i~c= =~i:o~fJ~~. ~~t~st:~~::~~~ m.:.rr~~cp~~~~~~r~'1~ This means that you may still OVll'e finance charges, even if may vary quarterty and may increase or decrease based you pay the entire New Balance indcated on the front of on the st8ted indces, lIS found in The Willi Street your statement by the next statement closing date, bur did JOUITlIII, plus the margin pre'#iously di8cloeed to you. not do so for the pte\lious month. Unpaid finance charges These changes will be effective on the first day of your are added to the applicabte segment of your AccotJlt. billing period covered by your periodtc statement ending te. ......... F...... C2lIrge. For each billing period that in the months Jarulry, April. JlAy and October. your accomt is Sltlject to a finance charge, a minimum c. If the code 0 (Prime), F (1 -mo. UBORI or G (3-mo. total RNANeE CHARGE of $0.50 will be imposed. If the lIBOR Repriced Monthly) appears on the from of your total finance charge reauh:ing from tho application of your lrtatemem next to the periodic rate(sl, the periodic ratea periodic rate(s) is less than SO. 50, we will aJbtract that and corresponcing ANNUAL PERCENTAGE RATES may amOlrlt from the $0.50 minimum and the difference will be vary momhly and may Increase or decrease based on the billed to the purchase segment of your account. stated indices, as fould in The WaD Street JoumBI1 plus t d. T~ Reductian in FinInceI awg.. We reserve the the margin pre....oualy ditldosed to you. These changes ~~I~topenrod~ssess any or all finance charges for any given ~~ ~=~ive on the first day of your billing period 2. Awnge o.iIy B.-.c. llncludng New 1V1lhB..I. 4. Assenmenl: of L.., ov..... ... R~ p~ F.... a. Anance charge Is calculated by multiplying the dally Your accwm 'Mil be assessed no more than two of the fees balance of each se~ent of '(OIJ account le.g., cash listed here that occur during any biDing period. Under the advance, purchase, special transfer, and special purchase) terms of your customer agreemem, we reserve the right to by the corresponding daily periodic rllte(s} that has been waive or not to IIsseSS any fees without prior notification to previously disclosed to you. At the end of each day during you withotA waiving our rig-.t to I18BeSS the same or similar the billing period, we apply the daily periodic late for each fees at a later time. segment of your account to the dally balance of each 5.tRenewlna Yow Ac.....-.!:. If a membership fee segment. Then at the end of the billing period, we add l4l appears on the front of this statement, you have 30 ~~~~~=Ih.~a~~~~:;,:,.~r~~ :~r the ~d f;~~~:~~ ~~ t~a~~~~~~e;it~ ~uv: resths from each Be\1Tlent to arrive at the total periocic jf you cancel your account. During this period, you may finance charge for your aCCOllU. To get the dally balance continue to use your 8CCOlnt wtthout having to pay the for each segnem of your accooot, we take the beginning membership fee. To cancel your accooot, you must balance for each segment and add any new transactions notify us by calling our Customer RelatiOOll Department da~,:n~t:~odfurfit:~~r: ~~~~ed~r~ ~~yviOUS ~n~~ .:o~e;rio~~~r;c~ ~ ~~ ~he~~~~~~ period. payments or erec:its posted as of that day that are allocated 6. If You CIo.. VOU' AcCOU"lt. You can request to dose ~~rt:::'ch -=erit To~Sv:.~~ ~J:,a.::r,~II~':~~ the r;:.~~t:~ ~~ ~;~~re~r:::~O:(S) and New Balance shown on your previous statement in full (or account access checkl, cancel all preauthorlzed billing, if your new balance was zero or a credit amot.rn:), new and cease usi,:,\! your account. If you do not cancel transactions which post to your purchase or special preauthorized billing arrangements, we will consider purchase segments ate not added to the daily balances. We receipt of a charge your authorization to reopen your calcutate the a\lerage dally balance by adclng all the dally account. Additionally, your acCOUTt will not be closed balances together an::! dividing lhe sun by the number of until you pay all amomts you owe us induding: any the days in the current billing cycle. To calclAate your total transactions you have authorized, finance charges, past ~n;:~~~cr:.~t':~~~ =:.t:: ::~~;~~n:, bJ.I~~ ::a::e:,~~~~ta~ol~~uf= == ~~:WC:-sh period. Due to rounding on a daily basis, there may be a aCCOU'lt. You are responsible for these amOlSlts whether sli\11l variance between this calculation and the amoum of they appear on your account at the time you request to finance charge actually assessed. dose the aCCOllU or they are incurred 9l.tJsequent to b. If the code Z or N appears on the front of this statement your request to close the account. This may result in ~ra~ -::~b~a~': :;'t.~ :~~ ~,~~r ~~thl" ~~ed~~~~oub:cc= ~~~~~~::- of o o " , 0::;1 ~~~ C')....: N~N your accolnt if it has already been closed. For exampte, if you authorized a purchase from a merchant and we receive the transaction from the merchant after your account hes been c1oeec1, your accOlA"rt \/IIi1l be reopened, the amooot of the charge will be added to your account, and you \/VIII be responsible for payment. If there is a membership fee for your account, the lee will contirne to be charged, to the extent permitted by law, until the account balance hIlS been paid in full as defined above. 7. Using V... Aocount.Your card or account cannot be used in connection 't'IItth any internet gambling transactions. BILLING RIGHTS SUMMARV (In Case Of f:rrors Or Questions Abolrt Your Bill) If you think your bill is wrong, or if you need more information on a transaction or bill, write to us on a separate sheet as soon as possible at the address for inquiries shown on the front of this statement. We must hear from you no IlIter than 60 dlIys atter we sent you the first bill on which the error or problem appeared. You can call our Cuatomer Relations number, but doing 80 \/IIi1l not preserve your riltlts. In your letter, give us the following Information: your name and acCOlJ'lt number, the dollar amount of the SU8peCtecl error. a description of the error and an explanation, if possible, of why you believe there is an error; or if you need more information, a description of the item you are unsure about. You do not hII~ to Poly any amOlXlt in question ....mle we are investigating It, but you are stili obligated to Poly the pans of your bill that are not in question. WhUe we investigate your question, we carnJt report you as delinquem or take any action to collect the amount you question. t,t Special Rule For Credit Card Purchases If you have II problem with the q.J8lity of property or services that you purchased Mth a credrt card and you have tried in good faith to correct the problem 'Nith the merchant, you may have the rign not to pay the remaining IImOUlt due on the property or services. You have this protection only when the purchase price was more than ~60.00 and the purchase was made in your home state or Vllithin tOO miles of your mailing address. (If we own or operate the merchant, or If we mailed you the advertisement for the property or services, all purchases are covered regardless of amount or location of purchase.) Please remember to sign all correspondence. t Dossoot apply to consumer non-cnKHt card accounts * Does nof apply fo business non-credlt clJ(fj accounts Capital One suppons information privacy protection: see our website at www.capitalone.com. Capital One is a federally registered service mark of Capital One, Rnancial Corporation. All rigns reserved. C 2003 Capital One 01lGLBAK Inrpot'UnI: M:Jtioe: Payments you mail to us will be credited to your 8CCOlJ'lt as of the business day we receive it, provided (1' you send the bottom portion of this statement and your check. in the enclosed remittance envelope and (2) your payment is received in our processing c:erner by 3 p.m. ET (12 noon PT). Please allow at least five (5) buslress days for postal delivery. Payments received by us at any other location or in any other form may not be credited as of the day we receive them. Our business days are Monday through Saturday, excluding holidays. ~ce~ dofo~heUS:m~e:f :;:eJ:~s'n:~.8=far:ri~~y:rt~:c~~~ S:~:the ~~S~$ :~r~sb'::'~ o:~~n;; ~~:= ~~~: ~~r:~eru~~~rize us to make a charge against your bank account using the check, II paper dratt or other item. VERIFICATION CAPITAL ONE BANK, F.S.B. vs WILSON, PEGGY The undersigned does hereby verify subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities, that he/she is, HENDERSON W MCKENZIE II, Authorized Agent, of CAPITAL ONE BANK, F.S.B., Plaintiff Herein, that he/she is duly authorized to make this Declaration, and that the facts set forth in the foregoing Complaint in Civil Action are true and correct to the best of hislher knowledge, information and belief. ,4 . , jlHiI/tA'k ;114f;4.;? HENDERSON W MCKENZIE II j;~~ uUDLEY~R NaIIIy PuIIIe, ---c...tr. ..... My Conlrnmlon ...... ......., tt,.. ' 5178051793383231 A049 WELTMAN, WEINBERG & RBIS CO., L.P.A. C) ~~, s;: n .~ ( .;: -".'.j G') ""~l r,) =2 (....) ~..r.J \.0 .-< ""- "''-...> gu ~ ,-. ] -') - '"") l/\ <-0 v-" ...l:, ~ 't-' u,) ~ ~ v, ~ ., ,utU! ~" ..,_.__) .\'~;') .....'< ",~, ,.~ \,,,,,,_1 l''''f'11!'- ....,. I "........:: SHERIFF'S RETURN - REGULAR CASE NO: 2006-06034 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CAPITAL ONE FSB VS WILSON PEGGY GERALD WORTHINGTON , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon WILSON PEGGY the DEFENDANT , at 1940:00 HOURS, on the 1st day of November, 2006 at 202 W MAIN STREET MECHANICSBURG, PA 17055 by handing to PEGGY WILSON a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. 18.00 5.28 .00 10.00 .00 33.28/ J1/11/0~ ~ Sworn and Subscibed to Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: .~~~<~~ R. Thomas Kline 11/02/2006 WELTMAN WEINBERG REIS day BY'A~~)~ ' Deputy She ff before me this' of A.D. \ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL DIVISION CAPIT AL ONE BANK, Plaintiff No. : 06-6034 CIVIL TERM YS. PRAECIPE FOR DEFAULT JUDGMENT PEGGY WILSON 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, PA 15219 (412) 434-7955 WWR#05358629 Judgment Amount $ 1226.21 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. : 06-6034 CIVIL TERM PEGGY WILSON Defendant PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter Judgment against the Defendant, PEGGY WILSON above named, in the default of an Answer, in the amount of$1226.21 computed as follows: Amount claimed in Complaint $1075.83 Interest from AUGUST 22, 2006 TO MARCH 8, 2007 at the legal interest rate of25.90% per annum $150.38 TOTAL $1226.21 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 LD.#47437 Weltman, Weinberg & Reis Co., L.P.A. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, P A 15219 (412) 434-7955 WWR#05358629 Plaintiff's 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: 202 W MAIN ST MECHANICSBURG,PA 17055 '\ IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA CIVIL DIVISION CAPITAL ONE BANK, Plaintiff vs. Civil Action No. : 06-6034 CIVIL TERM PEGGY WILSON Defendant NOTICE OF JUDGMENT OR ORDER TO: () Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the folIowing Order or Judgment was entered against you on (Yl.'.:ln~ ~ ~O( ~t.>7 (xx) Assumpsit Judgment in the amount of$1226.21 plus costs. () Trespass Judgment in the amount of$_ 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 A ward Prothonotary ByJ~ PROtHONOT A . PBT'4- PEGGY WILSON 202 W MAIN ST MECHANICSBURG,PA 17055 Plaintiff's 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 F.S.B. Plaintiff Case # d&-&03L{ C:Iv;L Tf';/"\ PEGGY WILSON Defendant(s) IMP RTANT NOTICE TO: PEGGY WILSON 202 W MAIN ST MECHANICSBURG,PA 1 055 Date of Notice: WWR#: 05358629 9.- J ~1-(S1 ! 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 I ;PAPER TO YOUR LiWYER A THER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS IF YOU CANNOT AFF HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFO TION ABOUT HIRING A LAWYER. 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: ~~ 7X~ tCro~ PATRICK THOMAS WOODMAN PA I.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: : 06-6034 CIVIL TERM Plaintiff NON-MILITARY AFFIDAVIT vs. PEGGY WILSON 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 III accordance with the Servicemembers' Civil Relief Act (SCRA), 50 US.C. App. ~ 521. Affiant further states that based upon investigation it is the affiant's belief that the Defendant, PEGGY WILSON 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, PEGGY WILSON is not in the military service. Further Affiant sayeth naught. tJh~ AFFIANT ND SUBSCRIBED in my presence this ~ day . .lO~1 . COMMONWEALT..t\ OF PENNSYLVANIA Notarial Sf'S' . Wen'~ I L Gault, N':,lary Public City Of Plfsburgh, r.'.H!,}neny County I My Comm:"sion Explle3 ,July 15, 2010 , J b pe;;~ylvania Associaliv(1 of Notanes Mam ar, 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. ~equest for Military Status Page 1 of2 Department of Defense Manpower Data Center . Military Status Report Pursuant to the Servicemembers Civil Relief Act MAR-08-200709:28:27 < Last Name FirstlMiddle Begin Date I Active Duty Status I Service/Agency WILSON PEGGY 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. ~~. ~-~ 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 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: htt-p://www.defenselink.mil/faq/pisIPC09SLD R.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 3/8/2007 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:BYWTGQHTOAA https://www.dmdc.osd.mil/scraJowaJscra.prc_Select 3/8/2007 'C'*- ~ ~ ~ ~ ~ ~' ("'. ~ ~ ~ ~ ~ () ~ ~ lrt ~~ -1 r-.) 0 g -1'1 ---J --4 :;T:. :;.: -n ~ \11 e t.,) -=?1'c? o {.~i-.\ ~'} ~ ~:~~:';~?\ <.;:? ~ ".0 :< (.~ o