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HomeMy WebLinkAbout07-1393.,, ~.* 4 ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CITIFINANCIAL INCORPORATED, I CIVIL DIVISION a corporation I I I Plaintiff(s), I I No. 2007 - v . I ~~ ~I c~ t, l., i PAMELA J. PAINTER, I an individual I I I Defendant(s), I I I I COMPLAINT 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 ISWARTZ, LOVEJOY & ASSOCIATES 116th FLOOR LAW AND FINANCE BUILDING (PITTSBURGH, PENNSYLVANIA 15219 I I 1(412) 288-0300 ;75883 NOTE: THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE {~ .1 "' /~ ;75883 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CITIFINANCIAL INCORPORATED, a corporation Plaintiff(s), No. 2006 v. PAMELA J. PAINTER, an individual Defendant(s), NOTICE TO DEFEND AND CLAIM RIGHTS 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 days (20) 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 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, GO TO OR TELEPHONE THE 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. PENNSYLVANIA LAWYER REFERRAL SERVICE 100 South Street P.O. BOX 186 Harrisburg, PA 17108 1-800-692-7375 NOTDEFPA.PLE 9. a ~ • . K ;75883 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CITIFINANCIAL INCORPORATED, a corporation Plaintiff(s), v. PAMELA J. PAINTER, an individual Defendant(s), COMPLAINT 1. Plaintiff(s) is CITIFINANCIAL INCORPORATED, a corporation. Plaintiff's address is ATTN: PAYMENT PROCESSING, FORT MILL, SC 29715. 2. Defendant(s) is PAMELA J. PAINTER, an individual. Defendant's address is 108 FAIRFIELD ST, NEWVILLE, PA 17241-1202. 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 $7,904.03 plus interest from November 28, 2005. WHEREFORE, Plaintiff demands Judgment against Def~e~hd~nt(s) in the amount of $7,904.03 Plus legal interest If and costs. Louis B. Swartz Attorney for PLAI T FF SWARTZ, LOVEJOY & A SOCIATES 16th FLOOR LAW AND FINANCE BUILDING PITTSBURGH, PENNSYLVANIA 15219 (412) 288-0300 R .if • '~ @75883 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CITIFINANCIAL INCORPORATED, a corporation Plaintiff(s), No. 200 v. PAMELA J. PAINTER, an individual Defendant(s), VERIFICATION The undersig that he/she is the avers ~intiff, 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. Date ~~~ ~~ VERIFCOM.PLE ti..a G ~~ _~ _ -~ t .^~.1 ~ ;-;-* ~ ~ '1 `.~ t_- .. ~ ~ ~ 4 ~ !~ a ~ R~ ~ ~ -f- ~_ SHERIFF'S RETURN - NOT FOUND CASE NO: 2007-01393 P ` COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CITIFINANCIAL INCORPORATED VS PAINTER PAMELA J 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 PAINTER PAMELA J but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT & NOTICE NOT FOUND as to the within named DEFENDANT PAINTER PAMELA J 108 FAIRFIELD STREET NEWVILLE, PA 17241 DEFENDANT HAS A FORWARDING ADDRESS OF PO BOX 53 HOLIDAYSBURG, PA 16648 Sheriff ' s Costs : So answers • -~''~ ,.•;~.~-- D o c k e t i ng 18.0 0 ..---~~ '~~ .--''~ Service 16.32 Affidavit 5.00 R. T ~ s"~ Kline Surcharge 10.,0g0p/_J~ Sheriff of Cumberland County ~ 0-,,' 49.32 SWARTZ LOVEJOY & ASSOCIATES ~~Ip~ 03/21/2007 Sworn and Subscribed to before me this day of , A.D. t ti IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CITIFINANCIAL INCORPORATED, I CIVIL DIVISION a corporation I I I Plaintiff(s), I ~~ ~ 1 I No. 2007 - ~7 I PAMELA J. PAINTER, an individual I I I Defendant(s), I I I I COMPLAINT I • r :>~~'~~~ ~ ~ ~.~ r 6 i~~ ~~a~ i~~ ~~ ~ ~ ~ ~ - I Code No . t~Oi~RECT COPY OP THE ORIGINAL 1 I I Filed on Behalf of: I I PLAINTIFF ~fF''q ,~~~~ P"~*- a R" ,AI~RG Illr'C ('r a,, f' e' I I I ATTORNEY OF RECORD FOR THIS PARTY I I Louis B. Swartz 1'R1JE COpY SRO R~COR~ I PA. ID # 00242 T~tlmOtly /~~r~}~~Nr.~>~~, A hr~ unto Est m/yy~~~~" ISWARTZ, LOVEJOY & ASSOCIATES 6th FLOOR LAW AND FINANCE BUILDING (PITTSBURGH, PENNSYLVANIA 15219 ~+•+ I ((412) 288-0300 ;75883 NOTE: THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE • t ;75883 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CITIFINANCIAL INCORPORATED, a corporation Plaintiff(s), No. 2006 v. PAMELA J. PAINTER, an individual Defendant(s), NOTICE TO DEFEND AND CLAIM RIGHTS 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 days (20) 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 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, GO TO OR TELEPHONE THE 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. PENNSYLVANIA LAWYER REFERRAL SERVICE 100 South Street P.O. Box 186 Harrisburg, PA 17108 1-800-692-7375 NOTDEFPA.PLE ;75883 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CITIFINANCIAL INCORPORATED, a corporation Plaintiff(s), No. 2007 v. PAMELA J. PAINTER, an individual Defendant(s), COMPLAINT 1. Plaintiff(s) is CITIFINANCIAL INCORPORATED, a corporation. Plaintiff's address is ATTN: PAYMENT PROCESSING, FORT MILL, SC 29715. 2. Defendant(s) is PAMELA J. PAINTER, an individual. Defendant's address is 108 FAIRFIELD ST, NEWVILLE, PA 17241-1202. 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 $7,904.03 plus interest from November 28, 2005. WHEREFORE, Plaintiff demands Judgment against Defendant(s) in the amount of $7,904.03 Plus legal interest and costs. Louis B. Swartz Attorney for PLAINTIFF SWARTZ, LOVEJOY & ASSOCIATES 16th FLOOR LAW AND FINANCE BUILDING PITTSBURGH, PENNSYLVANIA 15219 (412) 288-0300 A ~, @75883 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CITIFINANCIAL INCORPORATED, a corporation Plaintiff(s), v. PAMELA J. PAINTER, an individual No. 200 Defendant(s), ~ VERIFICATION The undersig avers that he/she is the .intiff, 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. Date ~~~ ~~ VERIFCOM.PLE ~~ ~~_ r ,'~~ ~d ' '..,