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Home My WebLink About06-6969IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff VS. ANGELA M KREBS Defendant No : n(,. - Fv?to 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 05398386 C N Pit VOC IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. ANGELA M KREBS Defendant Civil Action No 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 100 EAST SHORE DR GLEN ALLEN , VA 23059 2. Defendant is adult individual(s) residing at the address listed below: ANGELA M KREBS 13 HIGHLAND DR CAMP HILL, PA 17011 3. Defendant applied for and received a credit card bearing the account number 4388641719172657 . 4. Defendant made use of said credit card and has a current balance due of $1424.90 , as of November 04, 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 26.740° per annum on the unpaid balance from November 04, 2006 . A copy of Plaintiff's STATEMENT OF ACCO UNT is attached hereto, marked as Exhibit 111" 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 , ANGELA M KREBS , INDIVIDUALLY , in the amount of $1424.90 with continuing interest thereon at the rate of 26.740% per annum from November 04, 2006 plus costs. h:4 Warmbrodt,42524 WEINBERG & REIS CO., L.P.A. th Avenue, Suite 2718 h, PA 15219 -7955 338-7130 C N Pit VOC This law firm is a debt collector at ting to collect this debt for our client and any information obtaied will be used for that purpose. r KYFF 1C r^.'• Keepii our mantes rt • Know your credit limit and the amount of credit available for your use. • Maintain a good credit history ...it affects more areas of your life than just your ability to get a credit card. • Use a budget to help you see what you can afford to buy now and to help you save for the future. • Understand that the cost of credit includes fees as well as interest. • Request a copy of your credit report from a credit reporting bureau regularly. KYFF-1001 Capesal!f IW GOLD VISA ACCOUNT APR 20. MAY 19, 2005 ?1I? ? 4388-6417-1917-2657 Page I of I payments, credits and Adjustments Account Summery Previous Balance $916.39 Payments, Credits and Adjustments $.00 Transactions 00 $59 Transactions $88.00 40 520 . I 19 MAY CAPITAL ONE MEMBER FEE 29 00 Finance Charges . 2 19 MAY PAST DUE FEE New Balance $1,024.79 You were assesseda past due fee of$29.00 on 05/19/2005 becauseyour minimum payment wasno Minimum Amount Due $1,024.79 receivedby the due date 01 705/1912005. To avoid this fee in the future, we recommend that you Payment Due Date June 18, 2005 allow at least 7 businessdays for your payment to reach Capital One. Total Credit Line i $500 S.00 in 2657, 6333, you Due to the past-due status on one or more of your Capital One a=1111(s) ending Yo accordance with your Customer Agreement(s). d i d t Total AvailableCred h f C $500 n e charging privilegeson these accounts have been suspen rivilegason these accounts will be restored char in di as or Credit Line Cash di f $.00 g p g ng, As soon as these accounts are back in good stan ou can call 1-800.955-7070. If yodve already mation i f d or t AvailableCre , y or n ue within 7.10 days. For up-to-date payment- made your payment(s), pleasedisregard this message.Thank You At your service To callCustomeRelationorto reporialostorstolercard: 1-800-903-3637 Sendpaymentso: Sendnquineso: Atm:Remmanctrocessing CapitalDneflank CapitalDneServices P.O.Borf790216 St.LouisMO63179-0216 P.O.Box%5015 RidmondyA23285-5015 EXHIBIT L ;- Plemeseereversaideforimpontantinformation Finance Charges FINANCE Balen®te Periodic Corresponding HARGE C applietb rate APR S PURCHASES $928.15 .07326"A 26.74% $2040 00 .07326% 26.74% 5 . CASH ANNUAL PERCENTAGE RATE applied this period 26.74% PLEASE RETURN PORTION BELOW WITH PAYMENT CAPI WO• 0000000 0 4388641719172657 19 1024790025001024793 PleasprintaddresdlengdelotrsinVuorbiwink New Balance $1.024.79 Minimum Amount Due _ $1.024.79 Street Apt# Payment Due Date ]ume 18, 2005 City State 23P Total a dosed S -Imr Phone AltemalNiolle Account Number: 4388.6417-1917-2657 ?-p #9014030353079298# MAIL ID NUMBER r ANGELA M KREBS Capital One Bank 13 HIGHLAND DR P.O. Box 790216 IIIltllltlllllllltllll m CAMP HILL PA 17011-7519 St. Louis, MO 63179-0216 c IIIIIIIIII111IIIIIIII I I I II I I I I I I I I I I I I I I I I I I I I I I I I I I III III. I II 1- IIIIIIIIIIIII11111IIIIIIIIIIrlllllllllllllllllllllllllllll'III Pleas nteyouraammtlumWonyourchedmmoneyordertnadepayabidocapital Onellankand mail in theencloselklvelope. 8 8 wP .P. MN VERIFICATION CAPITAL ONE BANK vs KREBS, ANGELA M The undersigned does hereby verify subject to the penalties of 18 Pa.C.S. Section 4904 relating to unworn falsification to authorities, that he/she is, MAISHA DAVIS, Authorized Agent, of CAPITAL ONE BANK, 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 his/her knowledge, information and belief. MAISHA DAVIS MYRA PRINDLE Notary Public Gwinnett County Georgia My Commission Expires July 31 st 2009 4388641719172657 A049 WELTMAN, WEINBERG & REIS CO., L.P.A. <fl Cil r!:rt c? J ?'T (r. PI-i cZl C7 f'+'1 (-TI CA n y ?.W G `T7 T ffi1 v! f i .D IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. ANGELA M KREBS Defendant No. 06-6969 CIVIL TERM MOTION FOR ALTERNATE SERVICE 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 Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR 405398386 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff No. 06-6969 CIVIL TERM vs. ANGELA M KREBS Defendant PLAINTIFF'S MOTION FOR ALTERNATE SERVICE AND NOW, comes Plaintiff, by counsel, Weltman, Weinberg & Reis Co., L.P.A. and requests this Honorable Court to enter an Order allowing the Plaintiff to make service upon Defendant, ANGELA M KREBS, by certified U.S. Mail and Certificate of Mailing, addressed to 13 Highland Dr, Camp Hill,Pa 17011, averring in support thereof the following: 1. On or about DECEMBER 5, 2006, Plaintiff filed a Complaint in Civil Action against Defendant to recover the unpaid balance due Plaintiff from Defendant in the amount of $1424.90. 2. When the Sheriff of CUMBERLAND County, Pennsylvania, attempted to make service of Plaintiff's Complaint on Defendant, the Sheriff was unable to do so, as evidenced by the Sheriff's return, a true and correct copy of which is attached hereto, marked Exhibit "1", and made a part hereof. 3. Upon receipt of the Sheriffs return of no service, Plaintiff conducted an investigation with the United States Postal Service to confirm the physical address of the Defendant. W WR #05398386 4. Pursuant to Plaintiff's request for information, the United States Postal Service confirmed Defendant's physical address of 13 Highland Dr, Camp Hill,Pa 17011, a true and correct copy of Plaintiff's Postal Request is attached hereto, marked as Exhibit "2", and made a part hereof. 5. Plaintiff conducted an online white pages search and was unable to confirm a current address for Defendant of 13 Highland Dr, Camp Hill,Pa 17011. 6. Plaintiff contacted the CUMBERLAND County Tax Assessment office, a representative from which could not confirm the Defendant's current physical address as 13 Highland Dr, Camp Hill,Pa 17011. 7. Based upon the foregoing, Plaintiff believes and therefore avers that Defendant is attempting to avoid service of process in the above-captioned matter and Plaintiff therefore seeks an Order of Court, pursuant to Pennsylvania Rule of Civil Procedure 430, granting Plaintiff leave to serve its Complaint on Defendant by alternative means. WWR #05398386 WHEREFORE, Plaintiff requests this Honorable Court to enter an Order pursuant to PA.R.C.P. 430(a), authorizing the Plaintiff to serve Defendant by Certified U.S. Mail and Certificate of Mailing sent to an address (13 Highland Dr, Camp Hill,Pa 17011) at which Defendant is presently receiving mail according to information obtained from the Post Office, or by allowing service by a competent adult. William T. Molczan, E wire PA I.D. 447437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR #05398386 SHERIFF'S RETURN - NOT FOUND CASE NO: 2006-06969 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CAPITAL ONE BANK VS KREBS ANGELA M R. Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT KREBS ANGELA M but was unable to locate Her in his bailiwick. He therefore returns the it /TrtTT T TTTT r TT/'%MT f" "T the within named DEFENDANT 13 HIGHLAND DRIVE KREBS ANGELA M NOT FOUND , as to CAMP HILL, PA 17011 DEFENDANT DOES NOT LIVE AT GIVEN ADDRESS. NO FORWARDING ADDRESS ON FILE AT POST OFFICE. Sheriff's Costs: Docketing 18.00 Service 26.40 Not Found 5.00 Surcharge 10.00 .00 59.40 So answers • R. Thomas Kline Sheriff of Cumberland County WELTMAN WEINBERG REIS 01/05/2007 Sworn and Subscribed to before me this day of A. D. (3 b3,77 n&tg W ELTMAN, W EINBERG & REIS CO., L.P.A. WILLIAM T. MOLCZAN Attorney at Law 412.434.7955 Fax 412.434.7959 wmoiczan@weltman.com ATTORNEYS AT LAW 2718 Koppers Building 436 Seventh Avenue Pittsburgh, Pennsylvania 15219 412.434.7955 www.weltman.com OF INNOVATION GROWTH + RESULTS January 25. 2007 Postmaster CAMP IAILL,PA 17011 Request for Change of Address or Boxholder Information Needed for Service of Legal Process Please furnish the new address or the name and street address (if a boxholder) for the following: Name: ANGELA M KREBS Address: 13 HIGHLAND DR CAMP IIILL,PA 17011 BURLINGTON, NJ 609.914.0437 CHICAGO, IL 847.940.9812 CINCINNATI, OH 513.723.2200 CLEVELAND,OH 216.685.1000 COLUMBUS, OH 614.228.7272 DETROIT, MI 248.362.6100 PHILADELPHIA, PA 215.599.1500 NOTE: The name and last known address are required for change of address information. The name, if known, and post office box address are required for boxholder information. The following information is provided in accordance with 39 CFR 265.6(d)(6)(ii). There is no tee for providing boxholder infornation. The lee for providing change of address information is waived in accordance with 39 CFR 265.6(d)(1) and (2) and corresponding Administrative Support Manual 352.44a and b. 1 . Capacity of requester: William T. Molczan, Esquire, Attorney for Plaintiff, CAPITAL ONE BANK 2. Statute or regulation that empowers me to serve process : N/A 3. The names of all known parties to the litigation: CAPITAL ONE BANK vs. ANGELA M KREBS 4. The Court in which the case has been or will be heard: Court of Common Pleas of CUMBERLAND 5. The docket or other identifying number if one has been issued: 06-6969 CIVIL TERM The capacity in which this individual is to be served: Defendant WARNING THE SUBMISSION OF FALSE INFORMATION TO OBTAIN AND USE CHANGE OF ADDRESS INFORMATION OR BOXHOLDER INFORMATION FOR ANY PURPOSE OTHER THAN THE SERVICE OF LEGAL PROCESS IN CONNECTION WITH ACTUAL OR PROSPECTIVE LITIGATION COULD RESULT IN CRIMINAL: PENALTIES INCLUDING A FINE OF UP TO $10.000 OR IMPRISONMENT OF (2) TO AVOID PAYMENT OF THE FEE FOR CHANGE OF ADDRESS INFORMATION OF NOT MORE THAN 5 YEARS, OR BOTH (TITLE.: 18 U.S.C. SECTION 1001). I certit}' that the above information is true and that the address information is needed and will be used solely for service of legal process in connection with actual or prospective litigation. ` Kim erl y L. We WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 FOR POST OFFICE U S (LY / R BOXI iOLDER' S POSTMARK Not known at address given. , -Moved, left no forward address. No such address. No change of address on file Good as Addressed f ?,?? ---------- ---_ _--?_-._ Xx PLEASE INDICATE PHYSICAL ADDRESS NEW ADDRESS or NAME and S'T'REET ADDRESS W W R#05398386 CERTIFICATE OF SERVICE The undersigned certifies that a true and correct copy of the within Motion for Alternate Service was served on the day of A-pt , 2007, by first class, U.S. Mail, postage-prepaid, addressed as follows: ANGELA M KREBS 13 Highland Dr Camp Hill,Pa 17011 Attorney fo Plaintiff WWR #05398386 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK NO. 06-6969 CIVIL TERM Plaintiff vs. ANGELA M KREBS Defendant AFFIDAVIT PURSUANT TO PA R.C.P. 430 (a) BEFORE ME, a Notary Public, in and for the foregoing County and Commonwealth, personally appeared William T. Molczan, Esquire, of Weltman, Weinberg & Reis, Co., L.P.A., attorneys for Plaintiff, and deposes and says that the following accurately reflects efforts made to ascertain the exact whereabouts of Defendant named in the above-captioned matter. a. Plaintiff requested current address information from the United States Postal Service, which request for information confirmed the current address for Defendant as being 13 Highland Dr, Camp Hil1,Pa 17011. A true and correct copy of the Postal Service Return is marked Exhibit "2" attached hereto and made a part hereof. WWR #05398386 Finally, Affiant deposes and says that after the foregoing investigation, the exact whereabouts of the Defendant, ANGELA M KREBS, is 13 Highland Dr, Camp Hill,Pa 17011. WELTMAN, WEINBERG & REIS, CO., L.P.A. WilliaVm( T. Molczan, E ire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 Sworn to and subscribed before me this day f March, 07 No ry COMMONWEALTH OF PENNSYLVANIA Notarial Seal Wayne A. Jones, Notary Public FM?% Of Pittsburgh, Allegheny County ommissi??n E?ires June 29, 2010 Member, Pennsylvama Association of Notaries WWR #05398386 SHERIFF'S RETURN - NOT FOUND CASE NO: 2006-06969 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CAPITAL ONE BANK VS KREBS ANGELA M R. Thomas Kline Sheriff or Deputy Sherif J who being duly sworn according to law, says, that he made a dilig It search and inquiry for the within named DEFENDANT i KREBS ANGELA M but was unable to locate Her in his bailiwick. He therefore urns the COMPLAINT & NOTICE , ' NO r , FOUND as to the within named DEFENDANT KREBS ANGELA M 13 HIGHLAND DRIVE CAMP HILL, PA 17011 DEFENDANT DOES NOT LIVE AT GIVEN ADDRESS. NO FORWARDING ADDRESS ON FILE AT POST OFFICE. Sheriff's Costs: So answers- -- Docketing 18.00 Service 26.40 Not Found 5.00 R. Thomas Kline Surcharge 10.00 Sheriff of Cumberland C .00 ? 59.40 WELTMAN WEINBERG REIS 01/05/2007 Sworn and Subscribed to before me this day of , A.D. 1?aty IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff VS. ANGELA M KREBS Defendant Case No. 06-6969 CIVIL TERM AMENDMENT TO MOTION FOR ALTERNATE SERVICE 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 Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 wwr#05398386 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff Case No. 06-6969 CIVIL TERM VS. ANGELA M KREBS Defendant AMENDMENT TO MOTION FOR ALTERNATE SERVICE AND NOW COMES, Plaintiff, by and through its attorneys, Weltman, Weinberg & Reis Co., L.P.A., to amend the Motion for Alternate Service. 1. On or about APRIL 9, 2007, Plaintiff sent a Motion for Alternate Service to the Cumberland County Prothonotary. 2. Due to a clerical error, the Motion for Alternate Service did not comply with Cumberland County Local Rule 208.3(a). . 3. The following paragraphs need to be added to the Motion for Alternate Service to comply with Cumberland County Local Rule 208.3(a). 4. No judge has previously ruled upon any other issue in this matter or any other related matter in Cumberland County. 5. Because the Defendant in the above matter is represented pro-se, concurrence cannot be obtained. 1 ] 1,4 Wil is . Molczan, quire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 CERTIFICATE OF SERVICE The undersigned hereby certifies that a true and correct copy of the within pleading was served on the following on this day of a. , 200-, by first class, U.S. Mail, postage pre-paid: Angela M Krebs 13 Highland Dr Camp Hill,Pa 17011 WELTMAN, WEINBERG & REIS CO., L.P.A. By: William T. M czan, Esquire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 1521.9 (412) 434-7955 ` ,.. C.? J ?? ?--.1 .,..z,. ' ' ' ?.--- ?? _ ?i 'TJ ? . ?.,p. / t. , ?..,? 4? (?t ' ' .? CAPITAL ONE BANK, Plaintiff V. ANGELA M. KREBS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 06-6969 CIVIL TERM IN RE: MOTION FOR ALTERNATIVE SERVICE BEFORE OLER, J. ORDER OF COURT AND NOW, this 24 h day of May, 2007, upon consideration of Plaintiff Capital One Bank's Motion for Alternative Service and of the attached supporting affidavit, the motion is granted, to the extent that service of the complaint in this matter may be made on Defendant Angela M. Krebs by (a) regular and certified mail to her last known address at 13 Highland Dr., Camp Hill, PA 17011, said service to be complete upon mailing, and (b) by publication once in the Cumberland County Law Journal and in a newspaper of general circulation in Cumberland County. William T. Molczan, Esq. eltman, Weinberg & Reis Co., L.P.A. 2718 Koppers Building , 436 Seventh Avenue Pittsburgh, PA 15219 Attorney for Plaintiff :rc BY THE COURT, 9":€1111 Q'a :*`` 'Gz ji ]Hi 20 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. ANGELA M KREBS Defendant No. 06-6969 CIVIL TERM PRAECIPE TO REINSTATE COMPLAINT 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 (421) 434-7955 FAX: 412-338-7130 W W R#5398386 1 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. Civil Action No. 06-6969 CIVIL TERM ANGELA M KREBS Defendant PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. WELTMAN, WEINBERG & REIS CO., L.P.A. By: James C. arm rodt, 42524 WELTMA , W INBERG & REIS CO., L.P.A. 436 Seve th A nue, Suite 2718 Pittsbur , PA 5219 (421) 4 4-79 F .412-338-7130 a Cb BLS t ^.l t`]- 14 G? Q ("- 4J G" C"'? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. ANGELA M KREBS Defendant No. 06-6969 CIVIL TERM PRAECIPE TO REINSTATE COMPLAINT 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. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#05398386 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. Civil Action No. 06-6969 CIVIL TERM ANGELA M KREBS Defendant PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint. in the above captioned matter. WELTMAN, WEINBERG & REIS CO., L.P.A. By. /!ice James C. ai brodt, Esquire PA I.D. # 25 WELT AN, EINBERG & REIS CO., L.P.A. 2718 pper Building 436 venth Avenue Pitt urgh, A 15219 (41 ) 43 955 5398386 46 - Ln rT ? L cs A G7 C`5 s CA) q -c 0*- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. ANGELA M KREBS Defendant No. 06-6969 CIVIL TERM AFFIDAVIT OF SERVICE OF COMPLAINT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt, Esquire PA. I.D.442524 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#05398386 4 1r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff No. 06-6969 CIVIL TERM vs. ANGELA M KREBS Defendant AFFIDAVIT OF SERVICE OF COMPLAINT BEFORE ME, the undersigned authority, personally appeared James C. Wannbrodt, Esquire, who according to law deposes and says that a copy of the Complaint in Civil Action has been served on the Defendant, ANGELA M KREBS. 1. On or about MAY 24, 2007, Plaintiff received a signed Order of Court permitting service, on the Defendant, to be complete and valid upon mailing to the complaint by first class mail, certificate of mailing and by certified mail, return receipt requested. Said Order of Court is attached as Exhibit "I". 2. On or about OCTOBER 17, 2007, Plaintiff mailed the complaint to 13 HIGHLAND DR CAMP HILL PA 17011. Said certificate of mailing and certified mail receipts are attached as Exhibit "2". WELTMAN, WEINBERG & REIS, CO., L.P.A. James armbrodt, Esquire PA I. # 524 WEL M , WEINBERG & REIS CO., L.P.A. 271 Kop ers Building 43 Sev th Avenue P' tsbu h, PA 15219 412) 34-7955 Sworn to and before me this 1 c 10%. CAPITAL ONE BANK, Plaintiff V. ANGELA M. KREBS, Defendant TR y hand IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 06-6969 CIVIL TERM IN RE: MOTION FOR ALTERNATIVE SERVICE BEFORE OLER, J. ORDER OF COURT AND NOW, this 24th day of May, 2007, upon consideration of Plaintiff Capital One Bank's Motion for Alternative Service and of the attached supporting affidavit, the motion is granted, to the extent that service of the complaint in this matter may be made on Defendant Angela M. Krebs by (a) regular and certified mail to her last known address at 13 Highland Dr., Camp Hill, PA 17011, said service to be complete upon mailing, and (b) by publication once in the Cumberland County Law Journal and in a newspaper of general circulation in Cumberland County. BY THE COURT, W' liam T. Molczan, Esq. eltman, Weinberg & Reis Co., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 Attorney for Plaintiff :rc ester of ,.. EXHIBIT In ...... .. 0-1 4ho i . EXHIBIT U.S. POSTAL SERVICE CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT PROVIDE FOR INSURANCE-POSTMASTER Received From: ss ?,?.???rg at I Trj W 19p11 d L • CAL i 'R Y z CNV- ? e bU Dens; m ?• y?? l- One piece of ordinary mail addressed to: D PS Form 3317, January 2001 Postal CERTIFIED MAI L RE CEIPT M No insurance Coverage Provided) (Comestic Mail Only, N Lr) `r' l F F 4 r - co $ - Cl Postage M C3 Certified Fee w ai C3 C] Return Receipt Fee uired) ement Re r d E 1 '.\ ? O q n o s ( k Restricted Delivery Fee (Endorsement Required) t 'yi>$ C y " C:3 fd ., ,, ('Ll I 3 Y ., fu Total Postage & Fees s ? 5 C3 -Sent TO ? A /? ? !1 L? - 51------------------- C3 -u`fraeL M or PO _ .,.. - . - 1 --• - Y" _ 1 - ------ - - City, State, ZtP+4 ?1 - --------------------- --- r ... r f 'i", f rZ C-r7 -?d k IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK, Plaintiff vs. ANGELA M KREBS Defendant No. 06-6969 CIVIL TERM PRAECIPE FOR DEFAULT JUDGMENT 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#05398386 Judgment Amount $ 1,825.75 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. 06-6969 CIVIL TERM ANGELA M KREBS Defendant TO THE PROTHONOTARY: PRAECIPE FOR DEFAULT JUDGMENT Kindly enter Judgment against the Defendant, ANGELA M KREBS above named, in the default of an Answer, in the amount of $1,825.75 computed as follows: Amount claimed in Complaint $1,424.90 Interest from NOVEMBER 4, 2006 TO NOVEMBER 23, 2007 at the legal interest rate of 26.74% per annum $400.85 TOTAL $1,825.75 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: -Y- WILLIAM T. MOLC N, ESQUIRE PA I.D.#47437 Weltman, Weinberg & Reis Co., L.P.A. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 W WR#05398386 Plaintiff's address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7`h Avenue, Pittsburgh, PA 15219 And that the last known address of the Defendant is: 13 HIGHLAND DR CAMP HILL, PA 17011 IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK, Plaintiff vs. ANGELA M KREBS Case no: 06-6969 CIVIL TERM NON-MILITARY AFFIDAVIT 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 U.S.C. App. § 521. Affiant further states that based upon investigation it is the affiant's belief that the Defendant, ANGELA M KREBS 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, ANGELA M KREBS is not in the military service. Further Affiant sayeth naught. AFFIANT SWORN TO AND SUBSCRIBED in my presence this L1-day of /JUU Z? COMMONWEALTH pE"ILVAN& ND*WftEeea NOT RY PU IC ;y?,yly,? tr*K?x .?. 1&2 =•`' _' ,air ?1pt?tftEb 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. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. ANGELA M KREBS Defendant TO: ANGELA M KREBS 1465 BOWERS BRIDGE RD MANCHESTER, PA 17345 Civil Action No. 06-6969 CIVIL TERM IMPORTANT NOTICE Date of Notice: 0z 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 NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-31660 WE4MAN', INBERG & REIS CO., L.P.A. By: William T. Molcza PA I. D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR #03367344 Request for Military Status Department of Defense Manpower Data Center 40 Military Status Report Pursuant to the Servicemembers Civil Relief Act Page 1 of 2 NOV-26-2007 08:05:07 Last Name First/Middle __ Begin Date Active Duty Status - Service/Agency [ KREBS angela 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. IA. lt(ot 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. §§ 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 of DOB, 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://www.defenselink.mil/faq/pis/PC09SLDR.httnl WARNING: This certificate was provided based on a name and Social Security number (SSN) provided https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 11/26/2007 Request for Military Status Page 2 of 2 by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID: QJTWIZIVFD https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 11/26/2007 C ; r.a O ,. ?:r ? YT ? ? ? . ? Q! ? ?? ? r.'y? O yp ._ ,, a _ - ? ? ---? r.? ti,?, . (?1 vs y ? ? ? ? a - C,J .i ? ? `? _ Q1 ..C IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK, Plaintiff vs. Civil Action No. 06-6969 CIVIL TERM ANGELA M KREBS Defendant NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the following Order or Judgment was entered against you on 1 11 /Op (xx) Assumpsit Judgment in the amount of $1,825.75 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 (xx) Default ( ) Verdict ( ) Arbitration Award Prothonotary By: ` PRO ONOTARY (OR DEP k- ANGELA M KREBS 13 HIGHLAND DR CAMP HILL, PA 17011 Plaintiff's address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7 h Avenue, Pittsburgh, PA 15219 1-888-434-0085