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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
UNIFUND CCR PARTNERS,
CIVIL DIVISION
ARBITRATION DIVISION
No. tf1J- 3(../'1 ('~ T.u-.
Plaintiff,
COMPLAINT IN CIVIL ACTION
Filed on behalf of Unifund CCR
Partners, Plaintiff
vs.
CHARLES LAWYER,
Defendant.
Counsel for Unifund CCR Partners:
Jonathan S. McAnney, Esquire
Pa.I.D.#50041
TUCKER ARENSBERG, P.C.
Firm #287
1500 One PPG Place
Pittsburgh, PA 15222
(412) 566-1212
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
UNIFUND CCR PARTNERS
Plaintiff,
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No.
vs.
CHARLES LAWYER,
Defendant.
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 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.
LAWYER REFERRAL SERVICE
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PENNSYLVANIA 17013
(717) 249-3166
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
UNIFUND CCR PARTNERS
Plaintiff,
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No. tJtJ- 3f.,f<{ f!;;;:J/.t--
vs.
CHARLES LAWYER,
Defendant.
COMPLAINT IN CIVIL ACTION
AND NOW, comes the Plaintiff, UNIFUND CCR PARTNERS, by its counsel,
Tucker Arensberg, P.C. and files this Complaint stating as follows:
1. The Plaintiff is Unifund CCR Partners, a Delaware partnership, with offices
located at 11802 Conrey Road, Suite 200, Cincinnati, Ohio 45249.
2. The Defendant, Charles Lawyer is an individual and a resident of 85
Conrad Road, Carlisle, Pennsylvania 17013.
3. On or about June 1, 1996, the Defendant applied for and was approved to
receive a First Chicago Credit Card (hereinafter "Account"). Such Account was issued at Account
Number 4678035759280.
4. The Defendant utilized such Account and incurred a balance due and
owing.
5. As of May 3, 2000, the Defendant owed $5,758.65 in principal, and
$3,344.02 in interest. The total amount owed is $9,102.67. See the Affidavit of Indebtedness
attached hereto as Exhibit "A" and incorporated by reference as if fully set forth at length herein.
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6. Despite written and oral demands for payment, the Defendant has failed
and refused to pay the amount due and owing.
7. Reasonable attorneys' fees in the amount of 20% of the principal balance
are due and owing.
8. The following amounts are currently due and owing from the Defendant:
Principal and Interest
$ 9,102.67
$ 1.820.53
Reasonable Attorney's Fees (20%)
TOTAL:
$10,923.20
9. The Account has been assigned by First Chicago to the Plaintiff including
all rights to collect the amount due from the Defendant.
WHEREFORE, the Plaintiff, Unifund CCR Partners demands that judgment be
entered in its behalf and against the Defendant, Charles Lawyer, in the sum of $10.923.20 plus
costs and interest.
TUCKER ARENSBERG, P.C.
By
J athan S. McAnney, Esquire
P .I.D.#50041
Counsel for Unifund CCR Partners:
TUCKER ARENSBERG, P.C.
1500 One PPG Place
Pittsburgh, PA 15222
Attorneys for Plaintiff
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AFFIDAVIT OF INDEBTEDNESS
State of Ohio )
County Of Hamilton ) 55.
Amy Utaski, being swom, deposes and says that she is Media Supervisor of Unifund CCR Partners herein called
assignor, which is doing business at 11802 Conrey Road, Cincinnati, Ohio 45249 and that she is authorized to
make the statements and representations herein.
The defendant is not in any branch of the military.
There is due and payable from CHARLES LAWYER, Account Number 4678035759280, the amount of $91 02.67
(principal balance in the amount of $5758.65 plus interest up through 05/03/2000 in the amount of $3344.02). By
the terms of the agreement between the defendant and the original creditor, interest is accruing from the
aforesaid date at the rate of 19.80 percent per annum.
This account was originated with First Chicago. Unifund Corp. purchased this account from AST A Funding
Acquisition III, LLC. Said account has been assigned, trasferred and set over unto, Tucker Arensberg with full
power and authority to do and perform all acts necessary for the collection, settlement, adjustment, compromise
or satisfaction of said claim.
DATED 03M"'200~ W~
IFUND CCR PARTNERS
By: Amv Utaski
Media Supervisor
Title
11802 Conrey Road Cincinnati. OH 45249
Address
Subscribed and sworn to before me this IS day of VU~. 'ZtJ~O
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Client # 215
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EXHIBIT
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VERIFICATION
The undersigned verifies that the statements made in the foregoing
Complaint are true and correct to the best of his knowledge, information and belief and
understands the statements therein made are made subject to the penalties of 18 Pa.C.S.
34904 relating to unsworn falsification to authorities,
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Tr cy Lane
Unifund CCR Partners
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SHERIFF'S RETURN - REGULAR
CASE NO: 2000-03614 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
UNIFUND CCR PARTNERS
VS
LAWYER CHARLES
WILLIAM DIEHL
, Sheriff or Deputy Sheriff of
Cumberland County, Pensyl vania , who being duly sworn according to law,
says, the within COMPLAINT & NOTICE
was served upon
LAWYER CHARLES
the
DEFENDANT
, at 0017:35 HOURS, on the 20th day of June
, 2000
at 85 CONRAD ROAD
CARLISLE, PA 17013
by handing to
CHARLES LAWYER
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
Aff idavi t
Surcharge
18.00
3.72
.00
10.00
.00
31.72
So Answers:
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R. Thomas Kline
06/21/2000
TUCKER ARENSBERG
Sworn and Subscribed to before
By:
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me this 7 ~ day of
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Prothonotary
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
UNIFUND CCR PARTNERS,
CIVIL DIVISION
ARBITRATION DIVISION
Plaintiff,
No. 00-3614
TEN DAY NOTICE
vs.
Filed on behalf of Unifund CCR
Partners, Plaintiff
CHARLES LAWYER,
Defendant.
Counsel for Unifund CCR Partners:
Jonathan S. McAnney, Esquire
Pa. I.D. #50041
TUCKER ARENSBERG, P.C.
Firm #287
1500 One PPG Place
Pittsburgh, PA 15222
(412) 566-1212
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
UNIFUND CCR PARTNERS,
Defendant.
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No. 00-3614
CIVIL DIVISION
ARBITRATION DIVISION
Plaintiff,
vs.
CHARLES LAWYER,
TO: Charles Lawyer
85 Conrad Road
Carlisle, Pennsylvania 17013
DATE OF NOTICE: July 12, 2000
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED
OF YOU IN THIS CASE. 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 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
2 LIBERTY AVENUE
CARLISLE, PENNSYLVANIA 17013
(717) 249-3166
Jonathan S. McAnney, Esquire
Pa. I.D. #50041
TUCKER ARENSBERG, P.C.
1500 One PPG Place
Pittsburgh, PA 15222
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CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the within Ten Day Notice was
served on the following by first class mail, postage pre-paid on July 12, 2000:
Charles Lawyer
85 Conrad Road
Carlisle, Pennsylvania 17013
Jonathan S. McAnney, Esquire
Pa. I.D. #50041
TUCKER ARENSBERG, P.C.
Firm #287
1500 One PPG Place
Pittsburgh, PA 15222
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
UNIFUND CCR PARTNERS,
CIVIL DIVISION
ARBITRATION DIVISION
Plaintiff,
No. 00-3614
PRAECIPE FOR DEFAULT JUDGMENT
vs.
Filed on behalf of Unifund CCR
Partners, Plaintiff
CHARLES LAWYER,
Defendant.
Counsel for Unifund CCR Partners:
Jonathan S. McAnney, Esquire
Pa. 1.0. #50041
TUCKER ARENSBERG, P.C.
Firm #287
1500 One PPG Place
Pittsburgh, PA 15222
(412) 566-1212
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
UNIFUND CCR PARTNERS,
Plaintiff,
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No. 00-3614
vs.
CHARLES LAWYER,
Defendant.
PRAECIPE FOR ENTRY OF DEFAULT JUDGMENT
To Prothonotary:
Please enter Judgment by Default in the above-captioned case for the Plaintiff
and against Defendant, in the amount of $10.923.20 plus costs and interest, for failure to
answer or otherwise respond to the Complaint.
I hereby certify that the attached written Notice of Intention to take a Default
Judgment waS mailed to the Defendant ten days prior to the filing of the Praecipe for Entry of
Default Judgment.
Date:
7 ~ 7. 7 -60
By:
Counsel for Unifund CCR Partners:
Jonathan S. McAnney, Esquire
Pa.I.D.#50041
TUCKER ARENSBERG, P.C.
Firm #287
1500 One PPG Place
Pittsburgh, PA 15222
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
UNIFUND CCR PARTNERS,
vs.
CHARLES LAWYER,
Plaintiff,
CIVIL DIVISION
ARBITRATION DIVISION
No. 00-3614
TEN DAY NOTICE
Filed on behalf of Unifund CCR
Partners, Plaintiff
Defendant.
Counsel for Unifund CCR Partners:
Jonathan S. McAnney, Esquire
Pa. I.D. #50041
TUCKERARENSBERG, P.C.
Firm #287
1500 One PPG Place
Pittsburgh, PA 15222
(412) 566-1212
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
UNIFUND CCR PARTNERS,
Defendant.
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CIVIL DIVISION
ARBITRATION DIVISION
Plaintiff,
No. 00-3614
vs.
CHARLES LAWYER,
TO: Charles Lawyer
85 Conrad Road
Carlisle, Pennsylvania 17013
DATE OF NOTICE: July 12, 2000
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED
OF YOU IN THIS CASE. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF
THIS NOTICE, AJUDGMENT 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
2 LIBERTY AVENUE
CARLISLE, PENNSYLVANIA 17013
(717) 249-3166
Counselor Unifund CCR Partners:
Jonathan S. McAnney, Esquire
Pa.I.D.#50041
TUCKER ARENSBERG, P.C.
1500 One PPG Place
Pittsburgh, PA 15222
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CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the within Ten Day Notice was
served on the following by first class mail, postage pre-paid on July 12, 2000:
Charles Lawyer
85 Conrad Road
Carlisle, Pennsylvania 17013
Jonathan S. McAnney, Esquire
Pa.I.D.#50041
TUCKER ARENSBERG, P.C.
Firm #287
1500 One PPG Place
Pittsburgh, PA 15222
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PRAECIPE FOR WRIT OF EXECUTION
Caption:
Unifund CCR Partners,
) Confessed Judgment
(XX) Other
File No. 00-3614
vs.
Plaintiff,
Amount Due
Interest
$10,923.20
$ 442.80
. Charles Lawyer,
Defendant.
Atty's Comm
Costs
ro THE PROTHONOTARY OF THE SAID COURT:
The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or
account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed
pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 011974 as amended.
Issue writ of execution in the above matter to the Sheriff of Cumber land
for debt, interest and costs, upon the following described property of the defendant(s)
All personal property of Defendant located at:
RS Conrad Road, Carlisle, PA 17013
County,
PRAECIPE FOR ATTACHMENT EXj:CUTION
Issue writ of attachment to the Sheriff of County, for debt, interest and
costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real
estate, supply six copies of the description; supply four copies of lengthy personalty list)
and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s).
o (Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the
defendant(s) described in the attached exhibit.
~ - 21-6/
Date
Signature:
Print Narne:
Address:
s. McAnne
1500 One PPG Place
Pittsburgh, PA 15222
Plaintiff
Attorney for:
Telephone: (412) 594- 5584
Supreme Court ID No.: 50041
(over)
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Notes: If real property, supply six copies of description including improvements and an original and copy of
affidavit of ownership (PaR.C.P. No. 3129).
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If lengthy personalty list, supply four copies of list.
To index writ, file separate praecipe with writ.
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R. Thomas Kline, Sheriff, who being dilly sworn according to law, states this
Writ is returned ABANDONED, no action taken in six months.
Sheriff s Costs:,
Docketing
Poundage
Advertising J
Law Library
Prothonotary
Mileage
Misc.
Surcharge
Levy
Post Pone Sak
Garnishee
18.00
1. 81
10.00
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6.20
20.00
20.00
15.00
92.51
Sworn and Subscribed to before me
this 1..l.!!.. day of C)..Pr
2002 A.D. CJ:r.-,j}-~,~
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Advance Costs:
Sheriff s Costs:
150.00
92.51
57.49
Refunded to Arty on 7/3/02
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So Answers;
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R. Thomas Kline, Sheriff
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO.
COUNTY OF CUMBERLAND)
TO THE SHERIFF OF Cumber] and COUNTY:
To satisfy the debt, interest and costs due Unifund CCR Partners
00-3614 CIVIL 19 TERM
CIVIL ACTION - LAW
from Charles Lawyer, 85 Conrad Road,Carlisle, PA 17013
(1) You are directed to levy upon the property of the defendant(s) and to sell
DEFENDANT(S)
All personal property
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of
GARNISHEE(S) as follows:
and to nomy the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined from paying any
debt to or for the account of the defendant(s) and from delivering any property of the defendant(s) or otherwise disposing
thereof;
(3) If property of the defendant(s) not levied upon an subjectto attachment is found in the possession of anyone other
than a named garnishee, you are directed to nomy him/her that he/she has been added as a garnishee and is enjoined as above
stated.
Atty's Comm
Atty Paid
Plainmf Paid
%
L.L.
Due Prothy
Other Costs
$.50
$1. 00
Amount Due
Interest
$10,923.20
$442.80
Sl03.72
Date: APril '2, 2001
'by:
REQUESTING PARTY:
Name Jonathan S. McAnney, Esq.
Address: 1500 One PPG Place
Pittsburgh, PA 15222
Attorney fori Plaintiff
Telephone: 412-594-5584
Supreme Court 10 No. 50041
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