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COMPLAINT IN ASSUMPSIT
1. Plaintiff, Sears, Roebuck & Co., is a corporation
authorized to do business In the Commonwealth of Pennsylvania
with a place of business at the uddress contuined in the
above caption.
2. The Defendant(s), Janice A. Craftl is/are adult
individual(s) residing at the address containmd in the above
caption.
3. On sundry and various occasions, Defendant(s), with
the use of a credit card issued by the Plaintiff pursuant
to a retail sales installment contract, made various purchases
of goods and lor merchandise from the Plaintiff.
4. The present outstanding balance on the account is
$9,027.59; and, although repeated requests and demands have
been made, the Defendant(s has/have and still refused to
pay the same.
5. In accordance with the aforesaid agreement, the
Plaintiff is entitled to recover a reasonable attorney fee
incurred by the Plaintiff in effectuating collection of the
aforesaid balance due Plaintiff. Plaint.lff has incurred
reasonable attorney fees in regard to this matter in the
sum of $1,354.14.