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Home My WebLink About07-0300 It ... IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CITIFINANCIAL INCORPORATED, a corporation CIVIL DIVISION Plaintiff{s), No. 2007- ~~l) du~l/~ v. BRIAN K. HENRY, an individual Defendant{s), COMPLAINT Code No. Filed on Behalf of: PLAINTIFF ATTORNEY OF RECORD FOR THIS PARTY Louis B. Swartz PA. 10 # 00242 SWARTZ, LOVEJOY & ASSOCIATES 16th FLOOR LAW AND FINANCE BUILDING PITTSBURGH, PENNSYLVANIA 15219 (412) 288-0300 @75475 NOTE: THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE -.J 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 ATIORNEY 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 TIllS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO THE TELEPHONE OR THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, P A 17013 1-800-990-9108 717-249-3166 @75475 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CITIFINANCIAL INCORPORATED, a corporation No. 2007- -.Job CLL)~L I~ Plaintiff(s), v. BRIAN K. HENRY, an individual Defendant(s), COMPLAINT 1. Plaintiff(s) is CITIFINANCIAL INCORPORATED, a corporation. Plaintiff's address is 6010 FAIRVIEW RD, CHARLOTTE, NC 28210. 2. Defendant(s) is BRIAN K. HENRY, an individual. Defendant's address is 46 MOUNTAIN VIEW TER, NEWVILLE PA 17241. 3. Plaintiff, at Defendant's special instance and request, opened for the Defendant a credit account which Defendant thereafter used and there is a balance due and unpaid, despite demand, in the amount of $7,935.33 plus interest from July 26, 2005. Louis B. Swartz Attorney for PLA SWARTZ, LOVEJOY & ASSOCIATES 16th FLOOR LAW AND FINANCE BUILDING PITTSBURGH, PENNSYLVANIA 15219 ant(s) in and costs. WHEREFORE, Plaintiff demands Judgment against De the amount of $7,935.33 Plus legal interest (412) 288-0300 .. @75475 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CITIFINANCIAL INCORPORATED, a corporation Plaintiff(s), No. 200 v. BRIAN K. HENRY, an individual Defendant(s), VERIFICATION The undersigned, So"""'~~o~e.~~'-"r ,avers that he/she is the ~.;) of Plaintiff, is authorized to make this verification on behalf of Plaintiff, the statements of fact contained in the attached Complaint are true and correct to the best of his/her information, knowledge and belief, and are made subject to the penalties of 18 Pa. Cons. Stat. Ann. Section 4904 relating to unsworn falsification to authorities. VERIFCOM.PLE 7 - 7 -0' ~11 J'~ Date -;::) p ~ t t ~ ~ W tI1 t D (") f'-,,) c <= 0 = j -- -.J 11 "'- ...0 r! ri"'~ fii <- -f 1;) ~";.., : ::;r.. I.." ~ --.. ",".- Z nl;= ~~~-. r . -Cl rr: C() :uy -<' -.l ~;: C) ~ "-1 e) ..j-:" " ;:,~:Ii " -Y" ~~"~: .~:--; C") Om L~ ,--I ~ ,..._.J .r:- 1> -< ::0 1...0 -< SHERIFF'S RETURN - REGULAR CASE NO: 2007-00300 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITIFINANCIAL INCORPORATED VS HENRY BRIAN K 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 HENRY BRIAN K the DEFENDANT , at 1940:00 HOURS, on the 29th day of January , 2007 at 46 MOUNTAIN VIEW TERRACE NEWVILLE, PA 17241 by handing to BRIAN HENRY 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 8.80 Affidavit .00 Surcharge 10.00 R. Thomas Kline .00 ~ ')./''1/0 J v' 36.80 01/30/2007 LOUIS SWARTZ Sworn and Subscibed to before me this day of A.D. - . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CITIFINANCIAL INCORPORATED, a corporation NOTE: I CIVIL DIVISION I I I Plaintiff(s), I I No. 2007-300 I I I I I I Defendant (s) , I I I PRAECIPE FOR DEFAULT JUDGMENT I I I Code No. I I Filed on Behalf of: I I PLAINTIFF I I I I ATTORNEY OF RECORD FOR THIS PARTY I I Louis B. Swartz I I PA. ID # 00242 I I I SWARTZ, LOVEJOY & ASSOCIATES 116th FLOOR LAW AND FINANCE BUILDING I PITTSBURGH, PENNSYLVANIA 15219 I I 1(412) 288-0300 %75475 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE v. BRIAN K. HENRY, an individual .... %75475 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CITIFINANCIAL INCORPORATED, a corporation Plaintiff(s), No. 2007-300 v. BRIAN K. HENRY, an individual Defendant(s), PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Enter judgment against Defendant(s) and in favor of Plaintiff in Default of an Answer or a Notice of Intention to Appear as follows: AMOUNT CLAIMED IN COMPLAINT PLUS INTEREST FROM 07-26-2005 TO: 03-19-2007 $ 7,935.33 $ 783.97 $ 8,719.30 TOTAL I certify that I mailed a notice of default to the defendant(s) in the form attached hereto on the pate stated thereon which was more that ten (10) days befor praecipe. Louis B. Swartz / Attorney for PL~ NTIFF SWARTZ, LOVEJOY & ASSOCIATES 16th FLOOR LAW AND FINANCE BUILDING PITTSBURGH, PENNSYLVANIA 15219 (412) 288-0300 . ;75475 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CITIFINANCIAL INCORPORATED, a corporation Plaintiff(s), No. 2007-300 v. BRIAN K. HENRY, an individual Defendant(s), DEFAULT NOTICE TO THE DEFENDANT: BRIAN K. HENRY, an individual 46 MOUNTAIN VIEW TER NEWVILLE PA 17241 IMPORTANT NOTICE OMYOU 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 (10) 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 OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.OP 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. Date ~ PENNSYLVANIA LAWYER REFERRAL SERVICE 100 SOUTH STREET, P.O. BOX 186 HARRISBURG, PA 17108 1-800-692-7375 8-Louls B. SwartZ Louis B. Swartz Attorney for PLAINTIFF SWARTZ, LOVEJOY & ASSOCIATES 16th FLOOR LAW AND FINANCE BUILDING PITTSBURGH, PENNSYLVANIA 15219 (412) 288-0300 NOTE: THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE defnote/defnotex .. '" ....--. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BRIAN K. HENRY, an individual I CIVIL DIVISION I I I Plaintiff(s), I I No. 2007-300 I I I I I I Defendant(s), I I I AFFIDAVIT OF NON-MILITARY I SERVICE I I Code No. I I Filed on Behalf of: I I PLAINTIFF I I I I ATTORNEY OF RECORD FOR THIS PARTY I I Louis B. Swartz I I PA. ID # 00242 I I I SWARTZ, LOVEJOY & ASSOCIATES 116th FLOOR LAW AND FINANCE BUILDING I PITTSBURGH, PENNSYLVANIA 15219 I I I (412) 288-0300 %75475 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE v. CITIFINANCIAL INCORPORATED, a corporation NOTE: . _. %75475 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CITIFINANCIAL INCORPORATED, a corporation Plaintiff(s), No. 2007-300 v. BRIAN K. HENRY, an individual Defendant(s), AFFIDAVIT OF NON-MILITARY SERVICE I, LOUIS B. SWARTZ, do depose and say that the above-named defendant(s) Brian K. Henry are not currently in the naval or military services of the United States, either directly or indirectly. These statements are made subject to the penalties of 18 Pa. Cons. Stat. Ann. Section 4904 relating to unsworn falsification to authorities. ~ .(c;a., ~ -p - 7' ..t ~ 1\=- ~ . C> - C> r-> ~ 0 c:::> ~ - w -J ~ ':3 ~-r"I -c ~ ;,.~. ; Y" -u r'n~ C> ...0 ~ -,;;0 -o..A ~ ..0 \ ~~rs - (".) ~ - ~ ~ ~,i;.\< '.;~f~~~ ~ ~ :r:: ~ ~ c q: ~ _./~ ~ bJ :2 (...., (.)\ '.;..c. ..... ~ ~ ~