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Home My WebLink About06-6292 oJ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff No: Ol- - t-~9~ C!.'U~tT~ vs. COMPLAINT IN CIVIL ACTION DENA M SHOVER 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 05467949 C A pit SGM . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. Civil Action No DENA M SHOVER 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 BANK is a corporation with offices at 6851 JERICHO TURNPIKE #190 SYOSSET , NY 11791 . 2. Defendant is adult individual{s} residing at the address listed below: DENA M SHOVER 14 MOUNTAIN VIEW TER NEWVILLE, PA 17241 3. Defendant applied for and received a credit card bearing the account number 5291152088485756 . 4. Defendant made use of said credit card and has a current balance due of $2198.60 , as of October 07, 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 October 07, 2006 . A copy of Plaintiff's STATEMENT is attached hereto, marked as Exhibit "I" 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 , DENA M SHOVER , INDIVIDUALLY , in the amount of $2198.60 with continuing interest thereon at the rate of 25.900% per annum from October 07, 2006 plus Warmbrodt,42524 , WEINBERG & REIS CO., L.P.A. enth Avenue, Suite 2718 Pi sb rgh, PA 15219 (4 2) 434-7955 F 412-338-7130 o 46 949 C A Pit SGM This law firm is a debt collector a our client and any information obtai to collect this debt for be used for that purpose. , '\ 0" , Your account is delinquent. We want to help! .-.) To protect your credit with us, you need to make a payment. .-.::, We can help-but only if you call us. -~i' When you call, you can make a free check-by-phone payment. CapitalQne' Account SUD1IIUlJ"' PreVlOll.<; Balanc~ Payments.. Credits an~ AdiUS'""menrs Tr~ns:ac.tjom: Financ.e Charges fl.ObC.6S S.OO S7C.OC $23.44 ~ew Baianct Minimun, Amoum DUf Pavmen: Due Datf H.154.OS $1.15.:;.OS June 13. 2003 Total Credit Line Totai Available CmJi: Credit Lint f::>r Cas}] A,,'ai.1abl~ Creci! fOT Cast At your ~er\.'ice T (l aill Custon,el'" Rd.atiom or 1(. report s 10$1 or slolen card: 1-800-903-3637 F.)r free online account ~ervi.cr ano special alSTomcr otten. l('g on tc WW',\'.capiralone. cflm Send paymmu to Ann: RemittiUlCt" Fn,cel;sing Capital One Service P.O. Box 8.'14' Richmond.. VA 23276 Send inquirie. to: Capital On(' Service P.O. Bo); 85015 RichmfJJJd. VA 23285.5015 Imporram Account Information DId l"ou Know? Capital One offers more than just credit card productS, \-Vith mort than 47 milliOn accounts., Capital One provides valuable fmanctal solutions-including: auw loans, personal loans.. C::>s.. money market accoum:s and mort-to one ou: of ('vcry thret homes in thf U.S. ~. '" ~ Return your account to good standing. It's up to you to take the first step. Call us! 1-800-479-7231 (114-1102 GOLD MASTERCARD ACCOUi\"T 529J - :S2(1-~~8. 5756 APR 14. MAY E. 2003 Page] of 1 Pavrnems, Credit; and Adjustment; Transactions 14 APR 13 MAY 13M,>,Y O\'ERLIMlT FEE CAPITiu. ONE ~10)\THL Y MEMBER FEE PAST DUE FEE $29.00 6.00 3S.OC' $500 S.Cl(J S5Cl(J $.00 -Capiti One proudly supports the National Youth Anti- Drug Medi..c Campatgn. PARE]\'TS. THE Ai\"Tl.DRlIG. Star Involved. As!: Qtesrions. To get the FREE bookieL "Keeplllf Your Kids Drug- Free, ~ call1-R()(). 7Rf-2~OO or visi.t Ww\...-.~'heAntlDrug.colTi- You were assessed a past due fee of $35 .VC} or~ 05/13:'2003 because your minimum payment was not received byrne due date of 05/13/2003, Tc avoid this fee in the furore, we recommend that vou allow aT. l~ast -; bmoiness days for your paymem to rf'"..<Ic.h CapiTal One. EXHH:~IT It / 1/ . Finance Charges PieQ.j( .fee re'Vc7sr sidefrr. i.mpunanr information PURCHASE}, CASH S?E.CL~L PURCHASES lkJll11UTQJI "f't~'n':h S94:.39 SO.OO 1158.73 ~\~f Pcrio.iic C""7PRiml .07O'Jt'% .0709"* .07096" 2;:.90% 2S.'fO% 25._ S20.n6 S.OO S3.3S A. '\J\uAL PERCE>\TAGE RA. TE applied this period 25.90% CapitalOne' T PLEASE RETUR'\ PORTIO" BELOWV\r;T!-J F'AYME'iT T 0000000 0 5291152088485756 13 1154090065001154098 Pit/jS[ prin.t maiim[ aa4rtS., (1fI.d;(p r-11lai,' chances ",,'uo:.' usint ,i.iw (p huui: ini:. New Balance Minimum Amount Due Payment Due Date S1.154.09 $1.154.09 June 13. 2003 Total enclosed Account Numher: 5291-152o-8S4~.5756 ..., Capita: One Bank P.O. Box 85:'47 Richmond, VA 23276 111"",,11,1111I1,,11 1"1,1"11",1,11",1,11"11,,,11,"11,,,11,"11",11,,,11,"1 E:re~' _t..:J:l St.3t~ 21' nOIT'f?n::m< Ai[(:rn~r~ :>~nn" E..ITa_i: Adcte3~ '" cro '" "" C - !!!!!!!!! - - !!!!!!!!! - - #90134E~1819?9486# MF.I~ IL WJM3ER DENA M SHOVEF. 14 MO~~AIN VIEM~ TER ~~~~ILLE. Ph :724:-902= r 1,,,111,"1,,1,1,1,,111I111,1.,11"",1,1,,1,111,11,1,,11,,,11 Pl~a..li' 'Wri;eyour iUCOtlnt num.h~ em yow chec~ (}'!" monry' orde'l' mark payo.b/~' fl, Co.ptra.'(Jnt- Bani: and mo.!.; in th(' enc/oud I'nveiopf. \ , - - - - - = !!!!!!! - !!!!!!! - - - - !!!!!!! - - - - - - - - - = !!!!!!! - - = !!!!!!! - - - - - G! 2002 Capital One Services. Inc. Capital One is a federally registered service mark. All rights reserved. - - c 1. How 10 Awid A Fn~~ etu.va. t a Gr.ce Period. YOl; wil! hllve Ci minimum grace period 0; n, days wttholl1 fil1llnce chargE' on new purchases, new balance transfers new special purchase!> and new other cnarges i1 YOU pa\.' your lotat -New Balance", ill accoroaOC€ WItt, The Imponan1 NOlice tOl payments below .linG in ume tor it \(I be creditec by vour neXl ststemen! closing dale. TherE: is no grace period (1(1 cast, advance!; and SOeclsi Hoosiers. In addition, there is no grser periOd or, anv transaction i1 you do noT pav tne total -New balancE," b Accruing Fi'\.x:e Ch-ve. Transactions which are 001 subjeCl IU II grace r~riod 81t' assessed finance Charge 1) from the Oate of the t1ansactlor, 0: 2) from the dale the transaction is processed Ie. yOUr Account or 31 trorr, the first calends! dSi-' at the current billing period. Addrtioosllv j' yoLJ dlO not pay the- "New Ba~ance" fron: thE' previous billing periOd in full, finance charges continue 10 accrue 1( \lOur ullP8id ualance until tht' unpaiC balance is paid in ful: This means that "ou ma\i still owe finance char~, even i1 VOl.: pay the entire New Balance Indcated on thto trom 01 you: S1.alemen1 b" the next statement closing date. but did n01 do $(, for the previous month_ Unpaid finance charges are added to the applicable segmem 01 your Accol.lll t c. Mnrnum F.-_" a..ve. For eac~1 billing period that vour accoum i$ subject to ~ finance charge. 8 minimUlT' lmal ~lNANCE CHARm- of $C.50 Vllill be imposed. If the tOlal finance charQf' resuttin~ from the application of your penodlc fatelsi is. les~ than $0 50, we will subtfaC1 that amoum trom the $0.50 minimum and the difference will be billed to the purchase segment of your account t 0 T~ary Reduc:tian i"I Fnw.ce Cha-ge. We reserve the nght to nm assess an" or !Iii finance charges ior any given billing oenod. Av<<age O*"v 8~ ,Including New FUchaesl. a Rnance Charge is calculated by mlJltiplytng the dail~' balanc€ Of each segment of vour account le.g.. cash ad\lan~ purchase, special traos1er. and special purchase', b\, t~ corresponding daily periodic raleis) thal has beAn preViously disClosed 10 you. AT the end 01 each day during The billlOg penod_ we appl\l the daif~ penodic ratl? tOl eaCh segment of vour accoum TO The daily balance 01 each seQlTlen:. Then a1 the end 01 the billing period, we add up the resutts of these daily calculations to arrive a1 your penodic frnance charge tor each segment We add up the results trom eacn segmen1 10 arrive a1 the total oeriodlc finance charoe 10r your aCCOlnI To gel the dailV halancp tor each segmem of your aceoum, we take the tteglrYllng balance tor each sepmem arlC add any new transactions ane any periodic finance charQc calculated on the previous dil',' s balanc€ for tha1 segment We then subtraCt any payments or credns polJted as 01 thaI CUly thal are allocated 1f1 Tha1 segmem This giYE$ us the sepIH8Te dally b8lance tor E:lIch segment ot YOUI account, HOvvevel, if \IOU paid ttle New Balance shOVlIn on your previous :!\tatemem in tull lor if your ne-w balance was zero or b credn amount), new uansactionr vvhlCt, pas; TO YOl.J" purchase or speCial purchase segments are noT added 10 the daily nalances We calculaTf' the average daUv balance bv adding all The dailV balances together and dividillt the sum by the m.mbe~ 01 the days in th€ current billirl{! cycle, To calculale YOUI tOTal finance charge, multiply vou! averaQC daily baiartCE by thfo oaily oeriodic raTe and by the f1\JI11ber of days in the billinl1 penoe_ [AJe TO roundiOQ 00 Ii daily basis., there may bE; a sll~ variance beTween This calctJllITim and the amounT nl finance chalge actually assessed t; If the code Z 01 N appears on the trool of this statement neXlto "Balanc(: Rate Applied 1(1" we multiptv the averaae dailv balance of each seamen< bv \lOur monthlv periodic rate. To obtain the average aail~' balallce tOl th(;- billinQ period covered by this statemem, we taic.e the begirri~ balance ot each segmere each day, add any nev. transactions 1(; each segment, ane subtract any paymems 01 credns. (11 thf. code N appeal'f on the trom of thIS Sllnemenl nexr TO "Balal"lCfe RaTe Applied To: wp also subtrac; any unoald financt' chalge inCluded in Ule bahmCE 01 each s~mem.l This grves Uf' the dairy balance ot each segment, Then, we add up all tne daily balances tor each segment 10r the billing period ane divide bV the tenal number 01 days in the billi~ period ThiF gives us the ave/8Qf' dally balance oi eact"! segrnem .... AlYtual P.crillge Fbltes: IAPR1. a The Tel1l1 "Annual Percentage Rate. mav appear as . APR" on thE' tront 01 this StaTement b If the codE- P (Prime). l l3.mo LlBORI C ICenifica1f, of Depositl, or S fBankcard Pnmej appears on thE' trOnT of thi!; staTement flP-X'l to The periodic: ratelsl, The periodic rB1es and corresponding ANNUAL PERCENT AGE RA H:S may vary ouarteny and ma\ increase 01 decrease based on the stated indices, as founc In The: Wall Street .Jourr.al, plus the mBrgin previously disclosed 10 you These changes will be effeCTive on the fIrst dll" of your billing periOd covered by your periodi-c stlnemem ending in the monlhs January. April, July and OC1ober c It the codE D (PrimeL F (1-mo, UBOR) O! G 13-010. lIBOR Repnced Monthtvi appears on the trom of your Statement nex: 10 the periodic ralets), the periodic rates and corresponding ANNUAL PERCENT AGE RATES mev vary monthly and may increase or decrellse based on tht suned indice6, as found in Tht: Wall STreet .Journal. plus the margin previously disclosed to YOU. These changes Vllill be ettectiv~ on the first dsy of your Oilling period ell ch month 4 Assenment of lata. Overlimit .-.c:I Retuned PaV"*'lt Fau YoU! BCCOI.lf11 will be assessed no mou. Than twO of the fees liSTed hefe tha1 OCCUr during Bny billing period. Undel the terms of your customer agreement, we reserve th~ right Ie waive or nOl to assess any fees without prior notification to you W1tholJt wa""ng OUI riphl to assess the- samE' or SImilar lees a1 a later time 5, ! Renewi'1rg YOI.I' AcOCU1l. 11 a membershi~ lee appealS on the 110m of this StaTement, \IOU have 30 da ~ from the date this snnemenl was mailed to YOlJ \(I avoid paying the fee 01 tn have such tee credited to '0100 il vou cancel your aCCOlJl1. During this penod, VOU ma\ cominue 10 use VOlll accoum withoU1 haYlll(110 pay the membership 1ee To cancel your account. you muSt rlotity us bv calling our Customel RelatIOns Depanmem BOO pay your .New Balance' in tU! lexcludinp the mambelship feei priOl to the end of The thiny"da" period. 6, If YDU Close You- AcCOl.ft.. You can r~ques-r 1(1 dos~ vow HCr.:OunT b\' CflUlng OUf CUSTomer Relations Department. You must cleS1.ro\i VOUI cr~dil cardlsl and account access chec~, cancel all preauthonzed billing and CCfJse usinv your account. If voo do nOI cancel preauthorized billmg arrangemenls, we will conSIder leceipt of " chargE vour authoriUlion to reopen VOUl account. Addnlonallv, your account will not be Closed unlil you plIV all amoums Vou owe us induding:: an\ Transactions you haVE authorized, finance charges, DBSl due 1ee:; oyerfimi1 fees. retumed pavmem fees, cast1 advance tees Bnd an\' other fees assessed 10 your 8CCOunt, You are responsiblp 101 thes;e amOlJ1t!; wlether they appeal on vour account 81 The TimE you reQUt'!.S1 f( eiose the aCCOl.flI 01 they are incuned subseQuent 10 vour reQuel'll to dosc the account. Tnis maV resUlT ir, charges aopearing 00 \lour IICCounl atter you have reouest&d the accourr: to be closed 01 the reooenino 01 vour accoUfll if i; hlI~ aiready been closed, F-or exampie if YOl> authorized a purchase trom fJ mercham and we leceive t~ transaction from thr mercham after your account haf; beer, closed vour accolln~ Vv'ill be reopened tilt- amoum 01 the charge wiE l\e added 10 VOU! account, and YOU \Nil: hE responsiblE: tOl pllymem It there is a membership fe~ tOI you: aCCOUnl, the le~ will continue t(J be :::harged, to the ex'l"ent penmined bv la\'\, unti' the account balance has been pale in 1u11 as definer:: aboVE 7 Ucng Ycu- AcDOWlt. Your calO or account cannOl b€ used In connection with an" Internet gambling transactions. BilLING RIGHTS SUMMARY tin Case Of Errors Or Questions About You' Bill) If \IOU think vour I)jll IS wrong, or if 'Iou need morE in1ormatl0T1 on <l transaction or bill. write IIj us on B separatp. sheet Elf; soon as pos9lble aT Thf' aooress 10r i~/ies shown on the trom 01 this statement We must hear from vou no later 1han 60 days after we 5en~ YOU the first bill on Yllhich the error or problem appeared. You can call our Customer Rel91ioflS numbel. but doing so \/\/il! not preserye your rights. In your lener, give us the follOwing information: your name and account number, ttle ooUar BmOUnt ot the suspected error, e description of the error and an explanation. jj possiblE' of why ~u belielle there is an error; or if I{OU need more inlormaTion a des:::liption 01 thee item 'IOU are unsure about. '(00 do n01 haVE' to pay any amounl in QUeSTion While we Bre investigating It, bUI you are still obligaled to pay the parts 01 VOU! bill thaI <ire nm in Question. While ~ IOveslIgat€ vour QUeS1!(.>f!, WE- calYlO1 report you as delinquen: or take anv action 10 collecc the amount YOU Question t ,t Special RulE:' !=or Credit CalC Purchases If YOU have II problem wit!"", thE: qualirv of propeny or seMces that yOU purchased VllJth B credil Ccud and you he lie tried in good taith 10 correct the problem wi1:h the merchant, you mBv have the right nOl to ~\' tht: remaininl) I amount due or, the propenv Of services_ YOl> have this protection onl" \/\lhoo the purchase price was more than $00.00 and thE> puTchase was made In 'lOW home S1.ate 0; wiThin 100 mites of VOU! mailing address. Ilf \Nt' 01Nn or operate the merchant, or 11 we mailed you the advertisemem for the propt!ny (Ir services all purchases art- covered regardiess of amoum or location 01 purchase.j Please remember 10 SIgn all correspondence t Does nol applv to consumer n(m-crtJdl1 card 8ccounts : Does nor apply to {)usmess non-cIeri:' care HCcounts Capital One l'Iuppons intonnaliorl priv8C\' proleCTion: se~ ow website a! \IIfW\l\c.capilaione.~om Caoital One is ,8 tederallv regrSTered servi~ mark of Cllpital Or-te Fmancial Corporation, All rights rcscrved c: 2003 Capital One 01lGlBAK Important Notice: Your payment will be credited to your account as of the date we recerve It, provided you send the bottom portion or thiS statement and vou~ check in the enclosed remittance envelope, and your payment is received in our processing center by 3 p.m. Payments addressed to our Virginia or Georgia procElssing center must be received on a bUSiness day by 3:00 p.m. fT. Payments addressed to our Washington processing center must be received on B bUSIness dey by 3:00 p.m. PT. Please allow at ieest Tlve (5) bUSiness days tor postal delivery. Payments reCelvec by us a1 any other location or in another form may not be credited the same day we receive them. Our business days are Monday through Saturday. excluding holidays. Please de not use staples. paper clips, etc. when oreparing you~ oaymen't.. .., c co '" 48961 S , VERI FICA TION f5(jUl~ - . (TITLE) The undersigned does hereby verify subject to the penalties of 18 P A. C.S. 4904 relating )/, GnO lc::~_J( <2r) nel- 'f (NAME) / of C,f; {I" / Jl-~- npr" it:.. , plaintiff herein, that (COMPANY) to unsworn falsifications to authorities, that he/she is 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 of hislher knowledge, information and belief. c){(~~ 'ill~ (SIGNATURE) WWR#u'~;"-/0 71 C/ I "" ,~") (0) o c:::~ ;';fl. ' /\ C;; ?_''''.-4 _ J CJ -r.: -n ,- C-) i'l'C: -l iJ...,: ~ \: G) ~ ~ t ~ ~ ~ t ~ ~ ~ --- "t ~ ~ ~ _'T.~ r:} .- - SHERIFF'S RETURN - REGULAR CASE NO: 2006-06292 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CAPITAL ONE BANK VS SHOVER DENA M WILLIAM CLINE , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon SHOVER DENA M the DEFENDANT , at 1530:00 HOURS, on the 6th day of November, 2006 at 14 MOUNTAIN VIEW TER NEWVILLE, PA 17241 by handing to DENA SHOVER a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. So Answers: 1~:~~ ;?""~ ~ .00 f~ 10.00 R. Thomas Kline .00 37.68~/ 11/07/2006 f :1/0"'/0& WELTMAN WEINBERG REIS By: AJf~IV ~~ day L Deputy Sheriff Sheriff's Costs: Docketing Service Affidavit Surcharge ~ Sworn and Subscibed to before me this of A.D. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK, Plaintiff No. 06-6292 VS. PRAECIPE FOR DEFAULT JUDGMENT DENA M SHOVER Defendant FILED ON BEHALF OF PlaintitT 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 A venue Pittsburgh, P A ! 52] 9 (412) 434-7955 WWR#05467949 Judgment Amount $ 2,3] 5.60 THIS LAW FIRM IS ATTEMPTING TO COLLECT THIS DEBT FOR ITS CLIENT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT ]>URPOSE. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK, Plaintiff vs. Civil Action No, 06-6292 DENA M SHOVER Defendant f.!iAE,CIPE FORDEFAVLT JUDGMENT TO THE PROTHONOTARY: Kindly enter Judgment against the Defendant, DENA M SHOVER above named, in the default of an Answer, in the amount of $2,315.60 computed as follows; Amount claimed in Complaint $2,198.60 Interest from OCTOBER 7, 2006 TO DECEMBER 21, 2006 at the legal interest rate of25.9% per annum $117.00 $2,3] 5.60 TOTAL I hereby certify that appropriate Notices of Default, as attached have been mailed in accordance with P A R.C.P. 237.1 on the dates indicated on the Notices. WELTMAN, WEINBERG &; REIS CO., L.P,A. Plaintiff's address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 27] 8 Koppers Building, 436 7lh Avenue, Pittsburgh, PA 15219 And that the last known address of the Defendant is: 14 MOUNTAIN VIEW TER NEWV1LLE,PA 17241 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CArlT AL ONE BANK, Rlaintiff vs. Civil Action No, 06.6292 DBNA M SHOVER Defendant NOTICE OF JUDGMENT OR ORDER TO: () Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the following ~~d: 1~:14-!O~e7d against you (xx) Assumpsit Judgment in the amount of$2,3 I 5,60 plus COSts. () Trespass Judgment in the amount of $___ plus costs. () (fnot 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 BY_~AA~')J2, PROTHONOTARY (911r,:gEPIJTY)-. DENA M SHOVER 14 MOUNTAIN VIEW TER NEWVILLE,PA 17241 Plaintiff's address is: c/o Weltman, Weinberg & Rcis Co., L,P.A., 2718 Koppers Building, 436 til A venue, Pittsburgh, PA 15219 1-888-434-0085 . IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK, Case no; 06c6292 Plaintiff NON-MILITARY AFFIDAVIT vs. DENA M SHOVER 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 Il1 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, DENA 1\1 SHOVER 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, DENA 1\1 SHOVER is not in the military service. Further Affiant sayeth naught. AF,fd{k~ 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. .-, S. :VORj)J--TO AND SUBSCRIBED in my presence this --0.;:-) . . day '-. of a~-''''/J~'-Z'''''UI' ~ -g;--'--r- ~- :rtIOF NSYLVANIA" ---~ -- ~~.. "uaLle WaIo18A_NoIIlIyNll~ , CIty Of PIIfsbuqj1, Allegheny County f My Commission Expires June 29. 2010 lIAember. Pe""~IIII/"ni" '\!;!':nd..tinn "f Nntarlef Request for Military Status Page 1 of 2 Department or Defense Manpower Data Center DEC~2l ,,2006 08 :24 :05 Military Status R\::port Pursuant to the Servicemembers Civil Relief Act ~; Last Name First/Middle SHOVER DENA M Begin Date Active Duty Status Service/Agency 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 infonnation that you provided, the above is the current status of the individual as to all branches of'the Military. ~ Y1t. ~-~ Mary M. Snavely"Dixon, Director [)(lpartrnent of Defense ~ Manpower Data, Center 1600 Wilson Blvd., Suite 400 Arlington, V A 22209,,2$93 The Defense Manpower Dat~t Center (DMDC) is an organization of the Department of Defenile that maintElins 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] (SeRA) (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 individll<ll is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of tho 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 uctive~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, itnproved accuracy of DOB, a middle name), you can submit your request again at this Web site and we will provide !l new certif1cate for that query. This response reflects current active duty status only. For historical information, please contact th(.: Military Service SeRA points-of-contact See: http://'Nww.def~n~~Jinl<,miJ/t~~vpi'fj/Pc.Q9SJ,, I2R,btJu! WARNING: This certit1cate was provided based on a name and Social Security number (SSN) provided httl)~:/ h.www.drndc.osd.milllicl:aJowaJiwra.pl.c~S\.lll.lct 12/21/2. 006 Request for Military Status Page 2 of2 . by the requester. Providing an erroneolls name or SSN will calise an erroneous certit1cate to be provided. Report ID:BfIKCZJZLOJl.1H https;//www.dmdc.osd.millscra/owalscra.prc_Select 12/21/2006 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff Case # Q&:? -~V12- DENA M SHOVER Defendant{s) IMPORTANT NOTICE TO: DENA M SHOVER 14 MOUNTAIN VIEW TER NEWVILLE,PA 17241 Date of Notice: WWR#: 05467949 /V/5~/'~(P , 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 ~ BRODT, ESQUIRE 42524 WEINBERG & REIS CO., L.P.A. PERS BLDG, 436 7TH AVE. RGH, PA 15219 ~ ..tQ.. t jJ ~ --.a ~ . r-"> C> (i c:> ~ c: S 0 <. <-- :=?--n "'-:)-0"", r11 F" ~ ~ ~ -;;;::. :?8 - - ~ - ',,;):~) ~ ~ -0 -~~~) l """- ~ ';,>.() V'\ - ()\ (1 ~ ~ c.,' ....-\ ~ -;;. 0 ~ ~ --.. \.D ~ ~ . .....------