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Home My WebLink About07-0582t 1 era ~~~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL DIVISION Plaintiff vs. ROBIN BARNHART Defendant r~ °r' ~~~ COMPLAINT IN CIVIL ACTION FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt,42S24 WELTMAN, WETNBERG & REIS CO., L.P.A. 436 Seventh Avenue, Suite 2718 Pittsburgh, PA 15219 (412) 434-7955 FAX: 412-338-7130 c~S531747 C E Pit BNT ~ ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CACH, LLC Plaintiff .~A vs . ~~~~ ROBIN BARNHART Defendant Civil Action No ®~• S FZ ~'~ ~~ 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. '~ "`''''~ r',_";, 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 } ~~~ n M. ,:~ COMPLAINT 1. Plaintiff, CACH, LLC is a corporation with offices at 370 17TH ST.,SUITE 5000 DENVER CO 80202 . 2. Defendant is adult individual(s) residing at the address listed below: ROBIN BARNHART 1483 GOODYEAR RD GARDNERS, PA 17324 3. Defendant applied for and received a credit card bearing the ~...,~,•,, account number 4357875420086049 4. Defendant made use of said credit card and has a current balance due of $1828.81 as of December 27, 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 tie rate of 6.000 per annum on the unpaid balance from December 27, 2006 A copy of Plaintiff's STATEMENT is attached hereto, marked as Exhibit "1" and ~~p' 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 ROBIN BARNHART INDIVIDUALLY in the amount of .$1828.81 with continuing interest thereon at the rate of 6.000% per >, annum from December 27, 2006 plus costs. r~ James C. ar laro t,425. WELTMAN, EI ERG & RETS CO., L.P.A. 436 Seve th venue, Suite 2718 Pittsbur h, A 15219 (412) 4 4-7 S5 FAX: 41 -3 8-7130 055317 E Pit BNT This law firm is a debt collector attempti~ to collect this debt for our client and any information obtained wi 1 be used for that purpose. ~. - ~,,, , `~` z ~~ ppiaggss a ~r 3 $t~t@1116nTia aeoourrt ntanber: 4357!764 2p00 904li filar DsY,oe Paymara Darr DaN Pawl Due Amaarl IiArimu,r Paynst St,7>ib.07 11/07/06 5218.0~~0ppyy $1.064A7 Nalraya+r ~a.m•4~P+M,ban~WWiCard 81rvbM. Arrn,a+t Enebaed ~~wae amen a 4357875420066049DOS05907DOy79807~000D04 aw erx z eaaoe o HOBIP! L BARNHART 1169 G1000YEAR RD pARDNEA3 PA 173TA~bB06 Ir, rlll„rl,rll,,,l,l,ir,llrrl rl,I„II„r,l l,rl r.l.,rll, l,t„I CAFIDMEh6~ BERYICE 1(AUANOTON DE tYBBO.6169 r:5^00 L60 28 . 97854 2D08601.96r sMbnunt DaM: ow14b5-lalaab cusTOrl[R S!'RVIDe CHASE O Mri,eanl P~aymml Due. Ss,06a07 ~°~~ 1-Bb6146.7306 TDD 1.600.06620!0 OuMk. us. ~ aoMot ,.3oz-6o1~b2oo VISA ACCOUNT SUMMARY AooauatN,aa6w:47iT~7649DOS6M1 AACOIINT~ Il.1f Pieirl0w 9aMnce S1,eb2.e7 ToMi CradM LYu 51,aoo fin, DE f a660•b286 ~ purofraos, Cash. Da611c +574.00 Fkrsnw Chargaa +511.20 AvaYhN Cretla Cash Aaeaee LM9 51.000 PAYMpIT IIDOIIEb6 ~~f Avaf+bM 1orGah Sb P.D. Box 1b16b IWr.6alana yyiMr*gbn, DE 19e6661b0 VIbrY~ AT: TRANSA .C~I~Ns Amount 7rana Crdt DabK DaM Reference Number Mwchanl Nuns a Tranaadlo,l Oeaodp/on 1 3600 09x14 OVEIiIPubIT iEE FINANCE CHAgOEs Daiy Perforfa Rab CorrasPendrp Average Daily Balance Frranos Charge Due Trane,rdon FKIrWCE Gay ~ ~ ~n aye ApR To Perlodo RaM Fee CNAllOfln Puafraaee V .07674% 26.749L 11.744.13 0 54130 j0 00 50.00 yyJ 00 51/20 >~.00 Cash adoanon V .07674X 26.7196 9D.0 . . 51120 ToLi flnaroe ohayw ffuaatlw Aaexal ParaanlagA Rar(APRr A.749: PMaw ar ra.arr elde tar balarae ocMip~atlon a,dind, grace perbd, and o6w lrrporMnt Momlatkn The Carroepaafrq APR N 6a raM al NMreM you pay rrfwr yo,r carry a balance on u'Y haralao6an oaMDery. The Ellecfue APR nprwnM your tofd 6rrr,ce durpaa • YiaafeYlp traanasc0on Mac euofr as cash adwnu ud baMnoe V+rraAel Mee • errpraeeed as a pa,venOge. CHASE Q I,,.III.I,.I,.I.I..I.r II..,I,I,,,.Il.lrl...ll„1,1„r li„16.1 ~~~ E~e/~IIBIT t, ! .,..,.~ This Statement is a Facsimile -Not sn ixipinal Xooooom r'is~sxsnt aao N z u aano•rs rw/a+ awe uauna,w aenoooooroooe,wo, . . VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA C.S. 4904 relating to unsworn falsifications to authorities that he is Jeffrey Weyand, Authorized Agent of CACH, LLC, plaintiff herein, that he 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 knowledge, information and belief. JAN 0 5 2001 Date 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. e~!~~ Jeffre eyand WWR# 5531747 n ~ ~~ 1u p 0 G ~~ r_. ~__ ,.~ , N K',~ c,a c~ c~ c..~ u~ -.~ ~~ -n :. n. +; _ ; ~_~~ SHERIFF'S RETURN - REGULAR CASE NO: 2007-00582 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CACH LLC VS BARNHART ROBIN TIMOTHY REITZ Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon BARNHART ROBIN the DEFENDANT at 1205:00 HOURS, on the 7th day of February 2007 at 1483 GOODYEAR ROAD GARDNERS, PA 17324 ROBIN BARNHART by handing to a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff ' s Costs Docketing 18.00 Service g.6g Affidavit .00 Surcharge 10.00 .00 / 37.68 ~~~~-~o~ Sworn and Subscibed to before me this day of , So Answers: R. Thomas Kline 02/07/2007 WELTMAN WEINBERG REIS ~.. By : .._-- De uty Sheri f A.D. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CACH, LLC Plaintiff vs. ROBIN BARNHART Defendant No. 07-582 CIVIL TERM PRAECIPE FOR DEFAULT JUDGMENT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt PA I.D. 42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 Seventh Avenue, Suite 2718 Pittsburgh, PA 15219 (412) 434-7955 FAX: 412-338-71305 WWR#05531747 Judgment Amount $ 1,$54.66 THIS LAW FIRM IS ATTEMPTING TO COLLECT THIS DEBT FOR ITS CLIENT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. • r IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CACH, LLC Plaintiff vs. Civil Action No. 07-582 CIVIL TERM ROBIN BARNHART Defendant TO THE PROTHONOTARY: PRAECIPE FOR DEFAULT JUDGMENT Kindly enter Judgment against the Defendant, ROBIN BARNHART above named, in the default of an Answer, in the amount of $1,854.66 computed as follows: Amount claimed in Complaint $1,828.81 Interest from December 27, 2006 to March 23, 2007 at the interest rate of 6.00% per annum $25.85 TOTAL $1,854.66 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. James C. W rm rodt PA LTJ. 4 52 WELT AN WEINBEKG & REIS CO., L.P.A. 436 Sev nth enue, Suite 2718 Pittsb rgh, A 15219 (412) 34- 955 FA :41 -338-71305 W R#0 531747 Plaintiff s address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Buildi , 436 7~' Avenue, Pittsburgh, PA 15219 And that the last known address of the Defendant is: 1483 GOODYEAR RD ., GARDNERS,PA 17324 . IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CACH, LLC Plaintiff vs. Civil Action No. 07-582 CIVIL TERM ROBIN BARNHART Defendant NOTICE OF JUDGMENT OR ORDER TO: ( )Plaintiff (xx) Defendant ( )Garnishee You are hereby notified that the following Order or Jud ment was entered against you on ~ ~ .Z,OD? (xx) Assumpsit Judgment in the amount of $1,854.66 plus costs. ( ) Trespass Judgment in the amount of $ plus costs. ( ) [f 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. PROT ONOTAR ROBIN BARN-HART 1483 GOODYEAR RD GARDNERS,PA 17324 Plaintiff's address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7`" Avenue, Pittsburgh, PA 152].9 1-888-434-0085 L' IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CACH, LLC Plaintiff ROBIN BARNHART Defendant(s) IMPORTANT NOTICE TO: ROBIN BARNHART 1483 GOODYEAR RD GARDNERS,PA 17324 ~~,,~~11 Date of Notice : ~~~~~'~ ~~ o~y(/7 WWR#: 05531747 Case # ' `~ ~ Vl ~~-Q~YI/-~ 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 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 CAN 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 .~-- BY: Q~ctl~ ~~iC~VH-~ (~~r PATRICK THOMAS WOODMAN PA I.D. #34507 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 KOPPERS BLDG, 436 7TH AVE. PITTSBURGH, PA 15219 s IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CACH, LLC Plaintiff vs. ROBIN BARNHART Case no: 07-582 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, ROBIN BARNHART 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, ROBIN BARNHART is not in the military service. Further Affiant sayeth naught. SWORN TO D S SC BED in my presence this (~ay of ~'~ COMMONWEALTH OF PENNSYLVANIA NotadBd Seal N A RY PUB Wayne A Jones, Notary Public My~Cortimissior'- E~ires June ~ X10 Member, Pennsylvania Assooiatlon of Notaries This law firm is a debt collector attempti g to collect this debt for our client and any information obtained will be used for that purpose. Request for Military Status Page 1 of 2 r ~, Department of Defense Manpower Data Center Military Status Report Pursuant to the Servicemembers Civil Relief Act MAR-22-2007 07:53:41 ++C Last Name First/Middle Begin Date Active Duty Status Service/Agency BARNHART ROBIN 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. ~ ~-~- 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. #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 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._defenselnk.mil/faa/~s/PC09SLDRhtml 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 3/22/2007 F W !~~` 7~ h~ ! ~'+ n ~~ N yC ~'t '~4.. 1 "~w. 0 c~- ---~~' ~ ~ ~µ .:_ tz-t - r -n ~ ;-~ _ t~~^ ~ =~ ~ ; r~~ C `Z SHAPIRO LAW OFFICE,P.C. BY: Kenneth S. Shapiro,Esq. '+" Identification No. 26850 N 13 AUG 2 3 PH 2: G 4 P.O. Box 20 712 Darby Road CUMPiERLAND CrJINTY Havertown,PA 19083-0210 PENNSYLVANIA 610-668-0707 CACH, LLC In The Court Of Common Pleas of Cumberland County, PA Plaintiff VS Robin L. Barnhart Defendant CIVIL ACTION NO. 07-582 CIVIL TERM PRAECIPE TO SATISFY JUDGMENT TO THE PROTHONOTARY: Kindly mark the judgment in this case satisfied upon payment of your costs. Respectfully submitted By: � S. iro, E Attorne for Plaint' �, 71�o� ,e#-- acw