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HomeMy WebLinkAbout06-6336IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. TAMMY Y SHIELDS Defendant No: oc. - COMPLAINT IN CIVIL ACTION 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 05467247 C A Pit SGM I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff VS. Civil Action No TAMMY Y SHIELDS 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 t 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: TAMMY Y SHIELDS 27 CLEVERSBURG RD SHIPPENSBURG, PA 17257 3. Defendant applied for and received a credit card bearing the account number 5178052219956519 . 4. Defendant made use of said credit card and has a current balance due of $1852.50 , 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 11111 and made a part hereof. I 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 , TAMMY Y SHIELDS , INDIVIDUALLY , in the amount of $1852.50 with continuing interest thereon at the rate of 25.900s per annum from October 07, 2006 plus costs. Jam C. Warmbrodt,42524 EL MAN, WEINBERG & REIS CO., L.P.A. 43 Se enth Avenue, Suite 2718 P' tsb rgh, PA 15219 ( 12) 434-7955 AX: 412-338-7130 54 247 C A Pit SGM This law firm is a debt collector atit,6mpting to collect this debt for our client and any information obtained will be used for that purpose. r'1 Surf up to 5x fasterith FREE Ammieraloc for the firsf 12 mmnMst-a 1-888-587-9669 Mention Offer Code: COIN Visit www.peoplepc.com/goicoin oo; UNLIMITED INTERNET ACCESS PeoplePC Online offers the features you would expect from higher-priced Internet Service Providers, including: 19 Virus Protection powered by SymanieCT" =LDS:2S? Pop-Up BlockerTM Spam Controls 4l Smarter Smart Dialer Technology ® More Email Addresses ® Internet Call Waiting Capital QWe Account Sutnmary Previous Balance $960.07 Pavments, Credits and .Adiustments $.00 Transactions $64.00 Finance charges $21,99 New Balance $1,046.06 Minimum Amount Due $1,046.06 Payment Due Date December CE, 2003 Total Credit Line $400 Total Available CT-11 $.00 Credit Line for Cash $400 Available Credit for Cash $,W At your service T. call C--tome, Adation -1rt= repon a lost or stolen card: 1-800-903-3637 For free online account service and special oucomer offm. log on to ?x capimlonernn. Send pa m,emm to: Send mquiric to Atm: Remittance Ping Capita] One S- Capital One S_,_ P.O. B. 85147 P.O. Box 85015 Richmond, VA 23276 Richmond. VA 23285-50r, Rl_kTINLIM MASTERCARD ACCOUNT OCT 02 - NOV 01, 200? 5:78-0522-]995-65]9 Page I of 1 Payments, Credits and Adjustment, This is our third and final notice than your account is seripa511 past due. Payment must be received within 72 hours tc avoid action by ow cobection department Transactions 1 02 OCT OVERLIMIT FEE $29.OC m NON PAST DIIE FEE 95. )C As a valued Capital One customer, you are eligible to receive a free 1'car-End Summan that recaps vow 2003 charges. Please call 1-877-412-3311 before December 12, 2003, to reserve vow copy. All orders will be processed between lanuar , 15 and February- 29, 2004. When you send us a check, you authorize us to make a one-time electronic fund transfer debit from your bank account. The transfer will be for the amount of the check. You agree that if a third pant submits a check for your account, that individual. is vow agent and was provided with these disdoswm if we cannot process the transfer. You authorize it, to make a charge against vote bank account using a paper draft. You were assessed a pas due fee of $35.00 on 11/01'2005 because vow minimum payment was not received by the due date of 11./01/2005. To avoid this fee in the fume, we recommend that pots allow at lease 7 busineas days for your payment to reach Capital One. EXHIBIT ? „ Finance Charges Pie- su reverse side for important informat ion ^m Bdaerr rae, Pm,.Z. Ca.rupoxamF FI_ ?NCE ` ?peudm rt. lPli ? ? GE PLTRCFL SES $916.20 .0709696 ZAK $20 15 CASH $83.46 .07096% . 2i.90A $1.84 ?LNNUAI. PERCENTAGE RATE applied this period 25.90% PLEASE RETLiRX PORTION' BEL0"4 l\ 7TH PAYMENT. Capp lore 0000000 0 5178052219956519 01 1046060100001046065 New Balance $1,046.06 Minimum Amount Due $1,046.06 Pavmew Due Date December 01, 200: To tai enclosed $ Account Number: 5175-0522-1995-6519 Capital One Bank P: 0. Box 85147 LL.L.IL,.16.IJ.1 Richmond, VA 23276 I,II..I{...Il.,.lIM111.,il..dl..,ll...I Pease unit, your a-un! number or. vow peoplepa, online A better way to Internet, Pieces. mint a,dre,,, and, - L mm,ges &i- u , rip. , ?_j inj out Z_t 490306525600688464 Mk::T ID NUhIIEP : ZIO l' Y SHIELDS 27 C-LEVERSKM3 RD MEM S51PPMSBURv PA 17257-9410 L,.Ill...l..1,LL6L.J{.L..L.L..IIIL,...IJ6,.LL1.1 tfiecc w mono ordn made pavabir te, Capaa,, One Banc and mai! ir, the encio-a erveiowe r PQOUI c?nc- online 27 CLEw?auaG apt better way to Intemet. SHIPPENSBURGPA 7257-9411; U"N"'LIMITED INTERNET ACCESS 1-888-587-9669 • e Mention Offer Code: COIN 'Jsit www.peopiepc.com/go/coin PeoplePC Is soles' responsible for this afer, and is not afraiated Mtn Capital One. Capital One does not provide, encome, c- guarantee. an- Is not affiluxed with.. any product or service snows .ere. Am,' irathernants mentioned herein are solel} owned Dy the respechve entity. AP rights reserved. By responding to firs offer. you may oe communicating Information auott yoursef tc the company tna. provides mile product - for example, thai yoL am a Capita One custtmer. r"Vi Onme: Firs. 2 months are billec a, S49, per month'. S.A, per month thereafter Offer, available to hen dial-up suoscif ers at least I E years of age attic may not be redeemed with any other offer. Offer subject to change at any time. Phone technical supcor. available for V 15 w minute TAcealermor is mm, for 12 montne Offer good `.or rmhad time After the firs 1` morons. the Accelerate' service w11 aucomlatl alit' rever to the s'andad PeopleK Online service. Offer subject to orange at anytime. With PecphtK Online A.ceierattfC, color Web page tax, anc grapnl:s will load taster wrier compamic m standard dia?-up interne; service. A-to! reds}` may vary; Peopm"P' Online Accelerates m ant, compatible with PeoplasIC Oriira- Internal senace anc' specifier Wmdomie Droorsem Peo I,PC Online Acewalec is no! compatible witr Wmdo"a• 9E with IE 5.5 so:,. Service not avarame in all areas. Accom Ifeea. taxes, arc other fees and restrictions may appy. Temomine tole charges may apoh, even dunno trial oenogs. You are responsible Tor determmmg whether a car to one of curaccess numbers will result in usepnone toi. charge,. Access may Delimiter. espeaally quill times of peak usage. Gia-up numbers may be changed a PecpaPCe drscretron...gnidTUDUS use SUDIBM to recut oroc educes. Al use is sut7ject to PeopePC Opinions SIaMCm, Agreement and Acceptable Use Pblicc. 56K is the maximum speed of service: actual spleen may vary . e ME, PeoplePC Inc Ai RignD Reservoc eebdepC Online anc its loops are trademarks o' Peocill in the J.5 . and ottw- coumnm C 21705 3apnal Ohs Services. Inc. ;aortal One is a tederalmy rapstani service math.. Al! rignts reservec. 1 How To Avoid A France Charge. periodic of, To obtain the average daily ales- for Ise voui account it IT has already been cosec. Fur example, t a. Grace Period. You wile have a m um grace period o1 bilbng pendd covered by this natament, we .its the it you authorized a purchase from a merchant and we 25 days wham finance charge or, new purcnaees, rew begimrg balance o each segment each clay; add any rew olive the transaction tram the merchant alter your balance trans}.., n w specie Purchases and new other rsections eacs segment. and martmCt any payments ouiY. has been closed, your accourn will be maperoi charges it you pay your local 'New Balance', in Comanxx with The Important Notice In, payments below, cracks. (It the code N appears on the tram of this amen sex! to 'Ralance Rate Applied To.' we Also the amount of the charge will ce added to you' account, and WL will he responsible for paymem. If more is a - and in time for it to be credited by your nor stem subtract any unpntd finance carge Included in the hotancr. emomm p are toi Your ac aunt. Ore tee will continue closing date. There is no grace period on cash Advames of each aagmem.; This gives us the daily balance of each to be charged to the ablest Permitted by law until the rid speclai transfers. In sodium, the.. DO grace boned segment Then, we add un all the daily balances for each. m balance has been paid in full as named above. on any iransetxion it you do not pay the total 'New segment for the billing period one chi ide by the total ? Using Your Aa-.Ywr care or accwm canto- be balance.' number of days m the billing period This gives us the used in comemeon -In any mfornei gambling h. Aapuag Fk-. Charge. Transactions which are not average dally balance of each segment. t onstadtons. _ subject to a grace period are assessed finance charge 1) 3. Aaattl Peroentaga Ratas IAPRI. from the date of the «ensattion or 21 from the date the a. The term Annual Percemape Fate- may, appear as BILLING RIGHTS SUMMARY ransaction is processed to your Account or 3? from the 'APR' on me from of the memment (In Case Of Erms Or Questions About Your Bill, - first calendar day of the currant billing prom Additionally. b. It the code P (Primal. L (3-mo. LIBOR;, C (Certificate of If You thins your bill is wrong, or i' you need more if You did rot pay the 'New, Balance' from me previous Deposit). or S tBankcam Prime) appears on me }root m intorrievon on a larmanion or bill wme to us on a hillrng penotl in full, finipm charges continue to accrue In li is melement tab In the periodic ramml, the periodic separate sisal ..on as pnssiGe at the midess for a Your unpaid balance urnil the unpaid tam' is paid in fol. ales and corresponding ANNUAL PERCENTAGE RATES i inuiries sllown m the bont of this statement. We must This means that you may still owe finance charges, even it may vary }maned, and may increase or decrease based hear from You ro later that, 00 days after we sent, you the you Pay the smite New Balance indicated on the front of on the stated inifces, as found in The Wall Street first bill on which the error or problem, appearod. You can - =0 ur statement, by the next statement closing dare, but did J.vh i, plus me margin paYtoi disclosed to you. call our Customer Relations, number, bid darg an will nor - do sc tot the previous mdmh. Unpaid finance charges These changes will be oft-ye on the first day of your preserve your ngms. In your tenet, give us the idlowyrg are oddes to the applicable segment of Your A-mant. billing penotl covered by your periodic statement erring infonna oli your name one account number, the ddlfar = c. Min as. Fanerree Charlie. For each billing penotl that 'n the momhs January, April Jay and October. -um of me suspected error. a description of the error your account I. "a. to s finance carpe, a minmum c. 11 the code C (Prime). F (1-mo. LIBOR) or C f3-n- and an explanation if possible, of why You believe there is total FINANCE CHARGE of SO 50 will be imposed. If the LIBOR Repriced MontNyr appears on the ham of your an error; or it you reed more inlonnation. a Description of total finance charge resuhmg from the application of Your statement neo to the penonkc lets) In. periodic rates the item you are unsum about. Yw do nor how to pay any Periods. rate(s) is lest: than 90.50 we Will oubtan that, and corresponding ANNUAL PERCENTAGE RATES may amount in question while - art investigating it, but you amount. ham the 90.50 minimum and the difference will be Itsry monthly and may increase of decrease Oasatl on the are still oDligalee to pay the pans of your bill That ere not = billed to me purchase segment of your accwm. st.red mcb.es, as feed in The WaL' Street Journal, dos in quits tim. While we investigate your question, canon Td. Tamporary Roduetion at Franca Charge. We rec. w the the margin. previously dsdosed to you. These changes Town you as cal we' or Take any action to loll-:the ngh to not assess any or ail finance charges to! any given pilling penotl. will be efl-w on the first day of Your billing period each month. im unt you ques[im. 2. Average Daily Balance Ilnnkdiq New Are>tiaeesl. 4. Aaaea - of Lrte, DyarlbnR aed Retuned Pavmera Foes. I,- Special Rule For Credit Card Purchases a France charge is calculated by muhlpying the dally balance o1 each segment of your account (e.g., "an Your account will be assessed no mole than two of the foes limed here that ocwr during any billing penotl Under The advance, purchase, special t.nvsfer. and special butch ise) terms of your cumonnei agreement, we reeerye the fi If you haws a problem with the quality of property or by the co eaponding daily periodic rate(s) that has been waive or not to assess an, tees without prix notification To t n serrices That you purchased win a crerkt card and you '. prewously discloser, to u. At the end of each day during You without waiving our right to assess the same or sunder he- rbed in good faith to correct the problem wim the i the billing penot we apol, the dairy Pepper, rate for each fees at a later time. mercam, You may hove der right n o pay the r ihng = segment of Your account to to daily balance of each 5. TRanewap Yo1r Aceatnt. If a membership tee amount due on the property or serve es. You have this aegmenl. Then at the end of the billing period. we add up appears on the from of this malamerd, you have 30 Protection oToy when the purchase once was more than the results of these daily al-Imi es to arrive m your days from the done rots ..,am- was marled to you to 950.00 and the purchase was made in ywr home state or periodic finance charge far each eepnes. We add up the ve or to v 'tl Va a c such I ce the t c-chead to r M withn 10C miles of your mailing address. (11 we own or r ich each 8egmmt to arrive 8! the tonal blade o it you Can your account. p linth ths i Poppe r od. you may operate that merchant, or it mailed ytxl The ...It a finance charge tar ywt achrount. 10 gat the dally balance continue I. t0 Uee "I account without having TO pay the M adverdPemBfht fp! the property or aeaCea 811 purchases Property for each segment of your account we take the beginning memberffiup tee. cancel vom account, You must m covered regardless of amount or location of purchase .i balance for each segment and add any new t.reactims ratify us by calling Our Customer Relations Dep r, m or... remember I. sign ell correspondome and any penookc finance charge calcoomit m the PaIDUS ' and pay Your -New Balance- in full lc.I.fknc the oey s balance for that, segment. We then subvam any membership tee) prior to the and of The thlny-day period. t DO- Aar apply 1. consume. iron-credit card accounts I. yments or credits soared as of that day that are slimmed 6. If You Come Your Acentrs. You can request to dose to tat segment This gives us the separate daily balance account by calling our Customer Relations I Does nor apply TO hssino- non-r ol, card accounts for each segm aent of your account,. However, it you paid the Dope dmem You must destroy your cre it card(s) and New balance shown on your previous statement in full (or accrunt access checks cancel all preatdhonred billing, Capitol Cane supper- fntomiatron privacy prntemion' see out 11 Your new balance was rem or a credh. amount), new and cease using your accwm. If you do ref cancel we bsim at italore com cap y erections which post to your purchase or epeeist preauthonzed bilking arrangements, we will consider . . tetle. C Peal One W a ratly registered service ark of Cabinet purcaee aegmertts are rim added ro to daily balances. We l l il tl l n receipt of a range your etnhonzanon to reopen your ? H nanc al GOmOrallOn. 41. rights rase ved a 20(% Llh ca a y a ame D} adding all the daily ' aver»ge am I b l h account. Add orally, your accomt wlli viol br closetl Capital One a ances t [ et and divedmg the sum by the -.be, of 4 the days in The cunent billing cycle . To calculate Your imal until you ansamioprhs y vwli have al ts oozed, _ finance charges. any past frame charge, muhipv Your average daily balance by the due fees, oYedim, lees rcmmed payment fees, a h C ?. daily penoric rate and by the rumps, of days in the billing advance tees and any ether tees assessed to your penotl. Due to rounding on a dairy oasts, tare may be a -,. You is remmmitbe for these amounts wnethel slignt v ante between this calculation ant the amount of they appear on your account at the time yet request to finance carpe actually assessed. rose the account of they are inoarned subsequent in _ t. 11 the code Z or N appears m the hoot of this statement you, rawest to close the account. This may result in .. n next to 'Balance Rate Applied To,' multiply the charges appearing on your accwm .tier mO have O7 LGLBAK .1191 1111, belaDCa of loch, s egle m 11, Your requested the account TO be dosed Or the reop.nmol of 306fi7M Important Notice: your payment will be crackled to your account . as of the date wereive it, provided You send me bottom Donlon of this statement and your check in the enclosed rent«ence envelope, and your payment is received it, our processing cemer by 3 p.m C Payments addressed to our }fimme, or Georgia processing c ust be received o a business day by 300 p.m. ET. P.M.- addressed to our Washington processing comer must be received on a bustreas clay by 3:00 p.- PT. Please allow at leas: five (51 business days tot pomal delivery. Payments received by us at any oche, location or in another form may rbr be Crackled the same day we mce- them. Our pumness days are Monday through Saturday, exciuchm holidays. Please tlo non use stables, paper clips, etc. when preparing Your payment. VERIFICATION The undersigned does hereby verify subject to the penalties of 18 IPA. C.S. 4904 relating to unsworn falsifications to authorities, that he/she is C'' p ?(,s)n n? (NAME) plaintiff herein, that T? (TITLE) ? (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 of his/her knowledge, information and belief. (SIGNATURE) WWR# { 6'-7 ' `? c v .77 SHER--FF'S RETURN - REGULAR CASE NO: 2006-06336 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CAPITAL ONE BANK VS SHIELDS TAMMY Y ROBERT BITNER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon SHIELDS TAMMY Y the DEFENDANT , at 1940:00 HOURS, on the 22nd day of November , 2006 at 27 CLEVERSBURG ROAD SHIPPENSBURG, PA 17257 by handing to JERRY SHIELDS, HUSBAND a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: So Answers: Docketing 18.00 Service 47.52 Affidavit .00 Surcharge 10.00 R. Thomas Kline .00 75.52,/ 11/27/2006 -? WELTMAN WEINBERG REIS ;/ ,-,. 1.,210& /d 4 Sworn and Subscibed to By: before me this day eputy Sheri f of A. D. SHERIFF'S RETURN - GARNISHEE CASE NO: 2005-06336 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND MCCLURE-JOHNSTON COMPANY ET AL VS RINEER RUSS CONTRACTING INC And now WILLIAM CLINE ,Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0016:15 Hours, on the 2nd day of November-, 2006, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT , RINEER RUSSEL A JR hands, possession, or control of the within named Garnishee COMMERCE BANK 1130 CARLISLE ROAD CAMP HILL, PA 17011 Cumberland County, Pennsylvania, by handing to , in the JASON THOMAS (ASST MANAGER) , personally three copies of interogatories together with 3 true and attested copies of the within WRIT OF EXECUTION and made the contents there of known to His . Sheriff's Costs: So an Docketing .00 000 Service .00 Affidavit .00 R. Thomas Kline Surcharge .00 Sheriff of Cumberland County .00 00Z ++ 1.2-IN164, 12/04/2006 Sworn and Subscribed to before me- this day of By 44 1 e5: 1 Deputy Sheriff A.D AV iw , IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE 13ANK Plaintiff VS. TAMMY Y SHIELDS Defendant Civil Action No. 06-6336 PRAECIPE FOR JUDGMENT 12Y CONSENT TO THE PROTHONOTARY: Kindly enter Judgment against Defendant, TAMMY Y SHIELDS , in the amount of $1,852.50 plus costs, based upon the consent of the parties. CONSENTED TO: WELTMAN, WEINBE,RtG & REIS CO., L.P.A., Gv ? 1 By, Attorney for Plaintiff TAMMY Y SHIELDS, o ? By: Defendant WWR#05467247 IN TIE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BAND. Plaintiff VS. Civil Action No. 06,6336 TAMMY Y SHIELDS Defendant STIPULATION OF THE PARTIES FOR PAYMENT AND FOR THE ENTRY OF JUDGMENT BY CONSENT TO THE PROTHONOTARY: Kindly enter Judgment in favor of Plaintiff and against the Defendant, TAMMY Y SHIELDS , above-named, in the amount of $1,852.50 pursuant to the Stipulation of the Parties for Payment and for the Entry of Judgment by Consent, as follows: Defendant admits indebtedness to Plaintiff in the amount of $1,852.50 with continuing interest thereon at a rate of 6.0% per annum plus costs from OCTOBER 7, 2006. 2. To secure the repayment of said indebtedness, Defendant agrees that Judgment by Consent will be entered in favor of the Plaintiff and against the Defendant, TAMMY Y SHIELDS , in the amount of $1,852.50 plus continuing interest thereon at the rate of 6.0% per annum from OCTOBER 7, 2006 and costs. 3. Plaintiff agrees not to execute on its Judgment so long as Defendant causes to be delivered to Plaintiff the following payments in full by 12:00 NOON on the following dates: (a) $85.00 due by JANUARY 12, 2007; (b) $85.00 due on the 12TH day of each consecutive month thereafter until the Judgment amount plus accrued interest and costs are paid in full. 4, All payments are to be made payable to the order of" CAPITAL ONE 13ANX " All payments due under this agreement are to be received at the offices of Weltman, Weinberg & Reis, Co,, L.P.A., 2718 Koppers Building, 436 Seventh Avenue, Pittsburgh, PA 15219. 5, In the event of default, each payment received shall be first attributed to costs, interest and then to prinpipal, 7. Time is of the esssnee of this agreement and should the Defendant fail to have in the hands of Plaintiff or Plaintiff's counsel any payment in full within five ($) calendar days of the stated due date, then Plaintiff shall be immediately free to issue Execution as well as pursue all other remedies, in law or in equity, to collect the full balance of the Judgment entered hereunder plus appropriate :additional interest and costs, 8. No act or omission of the Plaintiff, nor of anyone alleged to be acting on its behalf, shall constitute a waiver, estoppel, or any other excuse for non-performance of any duty undertaken by the Defendant in this Stipulation which the parties agree is final and complete. 9, Intending to be legally bound, the parties set their hands and seals this -day of 2Q ? , Wl'I.'rMAN,'AI?fElNBURG elk REIS CQ,, L,P,A. t 9 illlam T, Mok;Aan} F ?atce PA I.D. 447437 WELT-MAN, WEINBERO & REIS CO,, L.P.A. 2718 Koppers wilding 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WW R No, 05467247 By Z ? d -a w d 1 ..tom C? "f. 129 cl) 't J ^? .t t . :-C Jr N t IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE, BANK Plaintiff vs, Civil Action. No, 06.6336 TAMMY Y SHIELDS Defendant NOTICE OF IVDGMFNT OR ORDER TO; ( ) Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the following Order r Judgment was entered against you on ?k _ R. 3 t 2.6o7 (xx) Assurnpsit Judgment in the amount of $1,852.50 plus costs. ( ) Trespass Judgment in the amount of $ plus costs. ( ) If not satisfied within sixty (60) days, your motor vehicle operator's license and/or registration will be suspended by the Department of Transportation, Bureau of Traffic Safety, Harrisburg, PA. (xx) Entry of Judgment of ( ) Court Order ( ) Non-Pros ( ) Confession ( ) Default ( ) Verdict ( ) Arbitration ( ) Award (XX) By Consent Prothonotary TAMMY Y SHIELDS 27 CLEVERSBURG RD SHIPPENSBURG,PA 17257 By: PRO ONOT a --. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. TAMMY Y SHIELDS Defendant No. 06-6336 PRAECIPE FOR SATISFACTION OF JUDGMENT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C Warmbrodt, Esquire PA. I. D.#42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#05467247 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. Civil Action No. 06-6336 TAMMY Y SHIELDS Defendant PRAECIPE FOR SATISFACTION OF JUDGMENT At the request of the undersigned attorneys for the Plaintiff, you are directed to satisfy the above-captioned Judgment. WELTMAN, WEINBERG & REIS CO., L.P.A. Sworn to and subscribed before me this day of Novembev'08 By: James C a mbrodt, Esquire PA. I.D. 25 4 WELTM N, EINBERG & REIS CO., L.P.A. 1400 K pp rs Building 436 S e th Avenue Pittsb r , PA 15219 (412) 4-7955 WWR #05467247 Jennifer M. Borowski, Notary Public CUp Of Pittsburgh, Allegheny County 00 O 37- 0© .fl