The URL can be used to link to this page

Home My WebLink About06-6642 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff No, ()I. - [,J.'-I~ (!1u~L I~ vs. COMPLAINT IN CIVIL ACTION SUEELLEN E WISE 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 05467685 C A Pit DKB IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. Civil Action No SUE ELLEN E WISE 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: SUEELLEN E WISE 423 WREN CT MECHANICSBURG, PA 17050 3. Defendant applied for and received a credit card bearing the account number 5291151808445520 . 4. Defendant made use of said credit card and has a current balance due of $1914.74 , as of November 02, 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 November 02, 2006 . A copy of Plaintiff's STATMENT 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 , SUEELLEN E WISE , INDIVIDUALLY , in the amount of $1914.74 with continuing interest thereon at the rate of 25.900% per annum from November 02, 2006 plus This law firm is a debt collector our client and any information ob -- Warmbrodt, 42524 , WEINBERG & REIS CO., L.P.A. eventh Avenue, Suite 2718 P. t sburgh, PA 15219 4 2) 434-7955 F : 412-338-7130 467685 C A Pit DKB to collect this debt for be used for that purpose. Your account is delinquent. We want to help! ...nn\\' "'ia\l.ef'Vu- \ (,ii' "'iQt\al CapitalOne. Accounr Summan' , Previo", Balance Pavmenrs, Credits and Adiustments T r~nsactiorn; . Finance Charges $938,88 $,00 $64,00 $20, B2 New Balance Minimum Amount Dut Payment Due Date $1,023.70 $1,023,70 August 27, 2003 $200 $,00 $200 $,00 Total Credll Line Total A \'ailable Credit Credit Lin' for Cash A vailabJ, Credit for Cash At your service TO' call Customer Relations or to repln a lort or stolen card: 1-800-903-3637 For free: online account ~crvicc and special ru.stomer offen. log on to: www.capitalone.com Send paymenu to': Ann: Remittance Proctl$sing ClLpiul Ont Service P.O. Box 8514'7 Richmond.. VA 23276 Send inquiriCl5 to: Capital One Scrvic= P,O, BOJ{ 85015 Richmond. Ii A 23285.5015 011; '-':r To protect your credit with us, you need to make a payment. m~r We can help-but only if you call us. '-':i' When you call, you can make a free check-by. phone payment. Return your account to good standing. It's up to you to take the first step. Call us! 1-800-479-7231 014-1102 COW !l1ASTERCARD ACCOUNT 529H51~-0844' 5520 JU" 2~. JUL 27, 2003 Page 1 of] T ransacrions Pa\'IDents, Credits and Adju..rments 1 2 28JU" 27 JUL 27 JUL OVERLIMIT FEE CAPITAL ONE MONTHLY MEMBER FEE PAST DUE FEE $29.00 6,0(1 29.OC You were assessed a past duc' fee of S29.0C! on 07/27/2003 because your minimum payment was not received bnhe due dar, of Oi /26/2003 , To avoid this fee in the furure, we recommend that \'Ou allow at le"a.~ i business days for YOU! payment to reach Capital One. - rmance ChaIges oor PleaJe .ue rt:V(rS(' .ritbf~ important i~rormati.on $19.14 S1.68 PURCHASES CASH BtJma(( Tmt P~ioa'i:: 'f1>iidtc- ratl S89.,14 ,07096% S78,95 ,07096% Comspon.Jmr ApE< 25,_ 25,9(\<l(, ~AP:8f 2;,90% en M o '" M o !!!!!!!!!!! - - - A. "lNUAL PERCENTAGE RATE applied rhis period CapltalOne' " PLEASE RETUR>\ PORTIOK BELOW WITH PAYMENT. " 0000000 0 5291151808445520 27 1023700100001023701 PieaJ{ .tw'int tNZiJ.'mt __us and/or 1-m4;l chanEt.\ OdOfJ' u,{ml blUE or Dim; mt.. New Balance Minimum Amount Due Payment Due Date $1,023,iO $1,023.70 August 27, 2003 Total enclO5ed Account Number: 5291-151 S-Oll44- 5520 -, Capital One Bank F, O. Box 8514 i 1,1,,1,,1,1,,11,1,1,,1 Richmond, VA 23276 1"1,1"11".1.11".1,11"11",11",11,,,11,,,11,,,11,.,11.,.1 5!r~t Apt#! CIty Statl ZI~ MC'nlf Phon~ Alte~!li.tt Dtn~t E.maiJ Addre~~ #9020849560633478# MAIL I~ NUMBER SUEELLEN E WISE 202 S BALTIMORE ST DILLSBURG FA 17019-1009 1".111",111"""111,1,.",1111",11",1,1"11,,,,,1,111",1 r PieaJE writ" your acc()Unf number 011 yow check (Jr monry ortkr made payable to Capita] Ont Bank anti mail in the enclosed m'VefOJ>€. - - - == - !!!!!!! cr> 2002 Capital One Services, Inc, Capital One is a federally registered service mark, All rights reserved. - = !!!!!!! !!!!!!! !!!!!!! = - - - = - = !!!!!!! !!!!!!! - - - - - - = !!!!!!! - - = !!!!!!! - - - - - c c (0 o co c " ~ N I 1, Haw TIO Awid A F~. D1.-ge. penodic une. To obtain the average ciailv ba~anct: tal the i t 8. ~~:~~Ofir:'~~~:g:,~m~, ~~~~~ ~~, :~~~ri~I~;~ ~'~h~;:::~~ ~:yt,8:~dt~ny new I balance transfers, new speCfa! purchases and new other transactions to each segment, aoo subtract an..,. payments ! ~~:~~~,lJir:~~;~~n~':;;~~~pe8.~~lnts below :~~=~I r~~~o ~8~~~~ :;ii~ ~~~ ~t~fS(, and in time tOl It to be credited by your next snltemenl subtract an..,. IXlpaid financt: charge included in the balance closing date. There is no grace period on cash advances of each segment.) This gives us the dailv balance of each and special transfers. In addition, there is no grace period segment. Then, we, add UJ? al! the d8~ly balances tor each on any transaction if you do not pay the total -New segment tor the billlllg penod and tivtde bv the lotal b818~.. number 01 davs in the billing period. This Wve5 us the b, ADCr'Uftg Fin.-,ce Ch.ge. Transactions which Ble noT a....ersge dailV balance of sach segment SltJject to a grace period are 8ssesRd fmance d18rge 1) 3. AmuaI P.centllge R.es IAP'U. from the dete of the transaction 01 2) trom the date the e, The term "Annual Percentage Rare. may appear as transaction is processed 10 vour Accoun1 or 3) from the . APR" on the hent 01 this statement first calendar day 01 the current billing period. Additionally, b. If the code P (Primal. L (3-mo. Ll80Rl. C lCenificate of i1 you dId not pav the .New Balance. from the previous Deposit), or S (Bankcard Prime) appears on the from oj billing period in full. finance CharQ8s continue to accrue to this staTement next TO the periodiC r8Ie(sl, the periodic your unpaid balance lJUil the unpaId balance ill paid in full rates and corresponding ANNUAL PERCENTAGE RATES This means that vou ma~' still owe finance charges, even if mB~. vary Quanerlv and mav increase or decrease based you pay the entire New Balance indicated on the from of on the stated indices, 85 found in The WolI Street youl statement by the next. 8tatemern clOSing date, bUl did Journal, plus the margm previouslv disclosed to you. not do so tor the preVIous month. Unpaid finance charges These CNIr\Qes will be effective on the first day of yClUT lire lidded to the applicable segmen1 of your Account billing period covered by youl peliodic Sla1.ernem ending t c. Minimum FinInCe a-..ve. For each billing period that in the months January, ApriL July and Octobel. your account is tUljec'l 10 .& finance charge, a minimum c If the code 0 (Prime). F f1-mo. L1BORl 01 G (3-mo. total RN.b.NCE CHARGE of $0.50 will be imposed_ If the U80R Repllced Monthly) appears on the front 01 your total finance charge resutting horn the application of your statemant neXl to the pariade rste(s). the- pertodic rlltes periodic rate(slls less than $0.50, we will tIlbtfaCl that and corresponding ANNUAL PERCENTAGE RATES may amount from the SO.50 minimum and the difference will be vary monthlv and may increase or decrease based on the biUed to the purchase segment of your account. stated indices, as tOISId in The WIJI1 St~ttt Journal, plu~ td. T........-v Reduction in F~ Qw-ge. We reserve the the margin previouslv disclose<! to you. The:3e changes ~f'ns:open;rod~ssess any or all finance charges tor any grven ~~ ~~t~~ive 00 the first d8~' of your billing period 2. Awr.,. Daity Baa.nc. IInducting Mew Purchasesl. 4 As.....-.l of L_., OYwtirnil ... R~ P.yment Fees.. a. Anance Char98 is calculated by multiplying the dallv Your accotSlT will be assessed tKl more than twO 01 the lees bal.nce of each segment of your accoum le.o.. cash listed here thal occur during anv billing period. Under the advance, purchase, special tr.nster. and special pUJchase) tenns of your customer agreement, we reserve the right to by the corresponding daily periodic ratels) tha! has been waive or not to assess any 1ees without prior notific8tian to previOUSllv dtsClosed to vou. At the end of each day during vou WithoUt waiving our nl11t to assess the same or similar the billing period. WE apply the dailv periodic rate tor each l~ '1 8 l.ter time segmenT of your account to the daily balance of each 5tR~ Yc:u AoCOU1t. If" membership tee seg-nenl, Then at the end of the billing period, we add ~ appears on the frOnt 01 this Sl.tement, you tlllYe 30 the restit5 of these daily celCUlations to arrive at your days from the date this :!latement was mailed to you to periodic finance charge tor each segment. We add up the avoid p'ying the 1ee or to hive 8UCh fee credited to vou rewtts from each segment to .rrive a1 the total periodic il you cancel your account. During this period, you may finance ctuuge lot your aCCOlflt. To get the dall\,' balance continue to use your account withOlfi having to pay the for eactl segment of yOUl account, we take the beginning membership fee. To cancel VOUI acCOUnt. you mUSl balance tor each seQIllelll and add .ny new transactions notify us bV calling our CustomeE Reiatioru; Depanment and any penodic finance charge calculated on the previous and P"V your ~New Balance. in illl texcludmg the da~ s bJ,lance for that segment We then subtract an~ membership tee) priOE to the end 01 the thlny-clay period payments or credns pOSTed as 01 that da~' tha1 are allocated 6. If You ceo.. yOU'" ACOCU'lt, You can request 10 dose to th81 segmem.. This gives \IS the separate dally balance your accout't1 by calling our Cumomer Retations fo' each ~enl 01 yoU! account. Howevel, if you paid the Depanmem. You must destroy yClUr credit c.ardtsl and New Balance shown 00 your previOl./S stalemem in full Cor account access checks, cancel all pteaUfhorized billing. it your new balance was zero 01 8 credit amournL new and cea~ usi~ your account. If you do not cancel uansactlQN; \/IIhich post to yoU! purchase or special pr8authonzed billing arrangements, we will consldel purchase segments are not added to the daily balances. We receipt of a charge your alJthorization to reopen yoU! calculate the average ~i!)' .balance bv lidding all the oail',! acCOUn1. AddifionallV. your account w1~1 no1 be closed balances together and div'diflQ the sum bv the number oj until you pay all amounts you owe us Including: an,"' the days in the currem bimng cvcle. J 0 e&lculate Vour lotal uansaCTiorn; you have authoriled, finance charges, pas; finance c::harge, muttiply your average dail,"' balance by the due fees, ovcrlimh iees leturned paymen1 tees, cash dailV penodc rate and by the number of days in the billin,", advaoce fees and anv other fees assesged to your period. Due to rounding on a dally basis, there mav be a account. You are responsible for these amounts Whether sU~ variance between this calculation and the amoum of they appeal orl your account 81 the time \IOU requeSl to ~~OC:~fa~~:~:~s:~~~ from of this statement ~:re r~o~e t~ aa~~o~r!?~S~~lti~' next to -Balance Rate Applied To: we multiplv the charges appearing on YOUl accoum after YOU haW' aver.ae dailv balanCE' 01 each Moment bv vour monthlv reauested the account to be closed or the reooenino 01 24035M your accourn if i! has alread... been dosed. For exampte, if you authoriled a purchase horn a melch.ant and we receive the transaCTion from the merchllnt attet your accoum has been closed, your accounl will be reopened, the amounl 01 the charge will be added to your account. and \IOU will tHl resp()n9ible 10r pa.,.,-nent. It there is a membership leE fOl your account, the lee will continue to be charged, to the exrem permmed bv law, until the account balance has been paid in full a~ defined above. 7 usno yOU'" Acoount.Your card or account cannot be used in connection WIth any imemet gamblmg transaCTions BILLING RIGHTS SUMMARY fin Case Of ~rrors Or Questions AbolJt YOUf Bill} 11 you think your bill is wrong, or if YClJ need more information on II transaction or bill. write to US on 6 separaTe sheet as $000 8S possible a1 the address fOr inquiries shown on the hmt of thill sultemem. We must heal from you no iater than 60 days after we sem you the first bill on wl"ich the error or problem appeared You can call our Customer Relations number, but doing SO .....11 not preserve your rights. In your lener, give US the following information: your name and account number, the dollar amoum 01 the suspected errot, a description 01 the errOl ancl an explanation, if possible, of why you bebeve there is an error; or i1 you need more inlormation, a descnption of the item you are unsure about You do not have to pay anV amount in question wtile we are invelRigatltlQ it, but you lire still oblig.ted to paV the pans of \fOUr bill thar .lIte nOT in Question. wtile we investigate YOUI QUestion, v.oe cannot repon VOU as delinquen1 or take anv lICTion to collect the amOlXlt you QUestIon :t-. t Special Rule I=or Credit Card Purchases 11 vou have a problem with the qualitv of propeny or services that you purch'lIed with a credit cald and you hive tried ~n good faith to correct the problem with the mercham, you may have the nght nol to pay the remaining amount due on the prapen" or services. You have this protection onIV \I'ihert the purchase price was more than $50.00 and the purchase was made 111 vour home State or within 100 mile,; of YOUt mailing .addteSll CI1 we own or operate the mercham, or If VIle mailea you the advenisemen1 for the propsny 01 senRces, all purchases are covered regardleu of amoun1 or locetion of purchase.) Plea9C remember to sign .~ correspondence t Does no; apply to conSUm#Jf non-credit card accounts t Doe.~ I10T apply 10 business non-credir card acCOunTS Capital One suppons intonnation privacy prOlectian: see our web9ite al www.capftalone.coOl Capital One is (I tecler.llv registered setVlce mark 01 Capital One Rnancial Corporation, Ail rights reserved. C 2003 Capital One 01LGlBAK Important Notice: Your payment will be credited to your account as of the date we receIve It, provided you send the bottom portion of this statement and your check in the enck>sed remittance envelope, and your payment is received in our processing center by 3 p.m. Payments addressed to our Virginia or Georgia processing center must be received on 8 business day by 3:00 p.m. ET. Payments addressed to our Washington processing center must be received on a business day by 3:00 p.m. PT. P~ease sHow at lesst fIve (5) business days for postal delivery. Payments received by us at any other location or in another form may not be credrted the same day we receive them. Our business days are Monday through Saturday. excluding holidays. Please do not use staples, paper clips, etc, wnen preparing your payment. -... -. \(J a:: --1 a.. <C Q,) (I) ct1 ..c ~ .,; :::) .c . -s~ Q.. ,~ g ~ (%.1 c~=a - j~~ 0 0 +-01 .2 ~! ~ 2 u 0 ~ :::1 0 - "0 ~. ~ -- ~ e j ~ ~ it ..; C ::= 1!.s' - ~ CLl ~g~ TIJ >-:s 0 1 . ~ 0 ~ .S III <0 ~e~ .c.. Q ii. ~ +J w~'% .~ ..... d'" ~ . @l =' Ja !l "'0 o~ o:t~ \.- V) ~ ~]~ . ~ i~ (..) ~ ~ r--.&"';: E "- tlJZ == ~ l!~'li r ~ 1>-- =~ g.., ~ en 'C i ~~~ , r:a =B " ~ .M .", -':":-:L::: = I ~~ (j) llI.i i ~.L "0 - . ~~.~I ~ .. 1 0 .- C!' . g C'l 1! > ~ 1? .- L ~r.I) .... ~ 0 '... (I'.l "0 CO > e Oa c.. l" 0 <( 0\ , 0 0 ~ 8 E 0 0 ~ '.lll N a.... I c .. 3: 0\ t ~o J.j ~ Q) m V'} 0 5..i~ c: 0 .~ ~ r- iS~ ..... ... 0 ....... ~i o...!U >-. },f) ~ 0 < ~..o E ~ . E 0... ii UJE t- uJ ..... .., ~ +-' 00 .o..J ~ c: l'1 - bO =~ o > ~ 0\ ~,JS ~ ~i tt:o oc;;f' 0 ~ ;::l OZ rl ........V},.J::. ltI~ # N (J ~ V) i~ ~N== .. ~ 0 ~ ;:j 0 ..- 0 en If) N 0 ...... t' U ""'" ~ 00 ~ UI' > t- tJ\ ~ U') E co ~ rI I ~ (1\ () rr'I ~ ...:t ~ - - ... - - - - - - - - - _. VERIFICA liON The undersigned does hereby verify subject to the penalties of 18 Pa. C.S. s4904 relating to unswom falsification to authorities, that he is an attomey for the Plaintiff herein and makes this Verification based upon the facts as supplied to him by the Plaintiff because the Plaintiff is outside the jurisdiction of the court and the Plaintiffs Verification cannot be obtained within the time allowed for the filing of this pleading; and that the facts and circumstances set forth in this pleading, are true and correct to the best of his knowledge, infonnation and belief. QSLl0 Ie;;, '6, <) ~ """ ~ " D -.0 ~ t -lq ~ . RJ CI) ...... C> ~ :c) ti P:: 4$ -~- ~ , (') ..'~ ~: ~ ~~ -,... :.._:::l.".-~8 ",::) 'I I ~ 1111__ en ~.s; [9..'. V) -ry ::!:J <{? ,': "~~~ ("j c.) :~~ '-n 0-' SJ (,.:: -< SHERIFF'S RETURN - REGULAR CASE NO: 2006-06642 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CAPITAL ONE BANK VS WISE SUEE~LEN E JASON VI O~=lliL Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon WISE SUEELLEN E the DEFENDANT at 1901:00 HOURS, on the 17th day of November, 2006 at 423 WREN COURT MECHANICSBURG, PA 17050 by handing to JACK WISE, BROTHER 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: Docketing Service Affidavit Surchar9'e 18.00 10.56 .00 10.00 .00 38.56 / (~ I;) (J " / D(, Sworn and Subscibed to So Answers: ?'~-<~ R. Thomas Kline 11/20/2006 WELTMAN WEINBERG REIS C7y~ By: before me this day of A.D. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff No. 06-6642 CIVIL TERM YS. PRAECIPE FOR DEFAULT JUDGMENT SUE ELLEN E WISE De1cndant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: WILLIAM T. MOLC/,AN, ESQUIRE P A 1.D.#47437 Weltman, Weinberg & Reis Co., L.P.A. 2718 Koppers Bldg. 436 Seventh A venue Pittsburgh, P A 15219 (412) 434-7955 WWR#05467685 Judgment Amount $ 1999.79 THIS LAW FIRM IS ATTEMPTING TO COLLECT THIS DEBT FOR ITS CLIENT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IN 'niE COURT OF COMMON PLEAS CUMBERLAND COUNlY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK P laintitl" vs, Civil Action No, 06-6642 CIVIL TERM SUEELLEN E WISE Defendant PRAECIPE FOR DEFAULT JUDGMENT 'fa THE PROTHONOrARY: Kindly enter Judgment against the Defendant, SUEELLEN E WISE above named, in the default of an Answer, in the amount of $1999.79 computed as follows: Amount claimed in Complaint $191/1.74 Interest from NOVEMBER 2, 2006 TO JANUARY 4, 2007 at the legal interest rate of25,9% per annum $8:'.05 10'I'AL $1999.79 I hereby certi(y 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. ~L~~~ PA I.D.i!47437 ~ESQ Weltman. Weinberg & Reis Co., L.P.A. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, P A 15219 (412) 434-7955 WWR#05467685 Plaintiffs address is: c/o Weltman. Weinberg & Reis Co" L.P.A, 2718 Koppers Build ing, 436 7'11 Avenue, Pit shurgh, P A 15219 And that the las1 known address of the Defendant is: 423 WREN CT, MECHANICSBU!{G.PA 17050 IN THE COURT OF COMMON PLEAS CUMBERUU~D COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BAlJK plaintiff Case # C~-~~~liC\DI'I'~( (Yl SUBELLEN E WISE Defendant(s) IMPORTANT NOTICE TO: SUEBLLEN E WISE 423 WREN CT MECHANICSBURG,PA 17050 \1 \\l-\\Cb \ ' . Date of Notice: W\1R#: 05467 IS 85 YQU 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 c~n 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 RODT, ESQUIRE' IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL DIVISION CAPITAL ONE BANK Case no: 06-6642 CIVIL TERM Plaintiff NON-MILITARY AFFIDAVIT vs. SUEE;;LLEN E WISE Defendant The undersigned, who first being duly sworn, according to law, deposes and states as follows: That he/she is the duly authorized agent of the Plaintiff in the within matter. Affiant further states that the within Affidavit is made pursuant to and In accordance with the Servicemembers' Civil Relief Act (SCRA). 50 LJ.S.c. App. S 521. Affiant further states that based upon investigation it is the affiant's belief that the Defendant, SUEELLEN E WISE is not in the militaI) 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, SlJEELLEN E WISE is not in the military service. Further Affiant sayeth naught. wdft1~ AFFIANT ~D in my presence this~ay ,1I1 ----- COMMONW JHOFPENNSYLVANIA NotBttaISeal Wayne A. Jones. NoIaIYPublic CltyorPillllburgh.~Colriy My Commission Expires JUI1929, 2010 ilAember. Pennsylvania Association of Not;:lrles This law finn is a debt collector attempting to collect this debt for our client and any information obtained will be used for that purpose, Request for Military Status Page 1 of2 Department of Defense Manpower Data Center JAN-04-200708:45:19 Military Status Report Pursuant to the Servicemembers Civil Relief Act ..,' Last Name First/Middle WISE SUEELLEN 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 information that you provided, the above is the current status of the individual as to all branches of the Military. ~}1r. ~-~ 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 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: http://ww\v.defenselink.mil/faq/pis/PCQ9S LDB.btml WARNING: This certificate was provided based on a name and Social Security number (SSN) provided https://www.dmdc.osd.millscra/owa/scra.prc_Select 1/4/2007 Request for Military Status Page 2 of2 . ' by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report lD:BJTYEYFQLXC https://www.dmdc.osd.mil/scra/owa/sera.pre_Select 1/4/2007 C N ~ -<<.l. ~ ....0 ~ ~ . 0 (") r...:J 0 c:') C = 11 -..I - D ~':'. ~ f; ~ " ~ < <- :P" rn:D -",...... -n~ """'- -u ....... ~ :(;0 ~ ~ p- o (::'1~? ~ ........ -T'" 11 -0 .~;~s (V ........ ~ B -J'..... - ~ ~ 1" c5rn r ~ ,..-\ ]'..,. 1 0 ""n =< --.:t::- . . IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY. PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. Civil Action No. 06-6642 CIVIL TERM SUEELLEN E WISE: Defendant NOTICE OF JUDGMENT OR ORDER TO: () Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the following Order ~r JUdgment, was entered against you on ~d.,u 1Dt ~OO'7 (xx) Assumpsit Judgment in the amount of $1999.79 plus costs. () Trespass Judgment in the amount of$_ plus costs, () If not satisfied with in sixty (60) days, your motor vehicle operator's license and/or registration will be suspended by the Department offransportation, Bureau of Traftic Safety, Harrisburg, PA. (xx) Entry of Judgment of () Court Order () Non-Pros () Confession (xx) Default () Verdict () Arbitration A ward SUEELLEN E WISE 423 WREN CT MECHANICSBURG,PA 17050 Plaintiffs address is: c/o Weltman, Weinberg & Reis Co., L.P.A, 2718 Koppers Building. 436 7th A venue, Pittsburgh, P A 15219 1-888-434-0085 . _ . , 2010 ,~~.~~~ ~.8 r r~ E2• ~7 ~ "` ~tt~ h i; Al IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. SUEELLEN E WISE Defendant(s) No. 06-6642 CIVIL TERM PRAECIPE FOR SATISFACTION OF JUDGMENT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: Lyndsay E Rowland, Esquire PA I.D. # 205520 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#5467685 JAM ~P',dd p~~y ~~ yG 3 ~~~ ti R IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. Civil Action No. 06-6642 CIVIL TERM SUEELLEN E WISE Defendant(s) PRAECIPE FOR SATISFACTION OF JUDGMENT At the request of the undersigned attorneys for the Plaintiff, you are directed to satisfy the above-captioned Judgment. WELTMA,~ WEINBERG & REIS CO., L.P.A. Y~ Lyndsay E owlan sq ire PA LD. # 2 520 WELTMA , WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7999 WWR #5467685 Sworn to and subscribed before me this _~_ day of May,~.0. COMMQNIN~A~.'fiWl ~ F'~NN~YLVANIA Notsne~ apYl F~ublip V~:~~ayttp b1. Jtx~, N91i~~ City of ptlsh~-(~t. pii~phrny County FAy Comma ~~' ~ ~tlq~ of Notatles MemGer, Pennaylvan As