The URL can be used to link to this page

Home My WebLink About03-0792IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA- CIVIL ACTION-LAW CREDIT PLUS SOLUTIONS GROUP, Inc. Plaintiff CHANDRA L. FARNER, Defendant : COMPLAINT NO. O B '-~ ~ ~ '~"~,"~ CIVIL ACTION-LAW JURY TRIAL DEMANDED Filed on Behalf of Plaintiff, Credit Plus Solutions Group, Inc. Mary S. Dietz, Esq. Attorney for Plaintiff PA I.D. #68257 Credit Plus Solutions Group, Inc. 2491 Paxton Street P.O. Box 67533 Harrisburg, PA 17106 (717) 236-8031 ext. 2024 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA- CIVIL ACTION-LAW CREDIT PLUS SOLUTIONS GROUP, INC., Plaintiff CHANDRA FARNER, Defendant COMPLAINT No. CIVIL ACTION-LAW JURY TRIAL DEMANDED NOTICE TO: CHANDRA FARNER, Defendant You have been sued in court. If you wish to defend against the claim 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 claim 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: CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717} 249-3166 OR 800-990-9108 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW CREDIT PLUS SOLUTIONS GROUP, INC., Plaintiff CHANDRA L. FARNER, Defendant COMPLAINT No. CIVIL ACTION-LAW JURY TRIAL DEMANDED CIVIL COMPLAINT AND NOW COMES Plaintiff, Credit Plus Solutions Group, Inc., by and through its attorney, Mary S. Dietz, Esq., files this Complaint against Defendant, Chandra L. Farner, and avers as follows: Plaintiff, Credit Plus Solutions Group, Inc., is a Pennsylvania corporation, with its principal place of business located at 2491 Paxton Street, P.O. Box 67533, Harrisburg, Pennsylvania 17106-7533, located in Dauphin County, Pennsylvania. Upon information and belief, Defendant, Chandra L. Farner is an individual with a principal place of residence located at 105 West Pine Street, Mt. Holly Springs, PA 17065 located in Cumberland County, Pennsylvania. o Plaintiff, Credit Plus Solutions Group, Inc. is in the business of collections. Its Collection Division collects outstanding debts. o Defendant, Chandra Farner, had a credit card account with Chase Manhattan Bank USA ("Chase"), account number 5260316230002390 pursuant to the terms of the cardholder agreement between Chase and Defendant. o o o o 10. 11. 12. 13. Defendant has failed to make payments according to the terms of the cardholder agreement and owes an outstanding balance of $2979.04 on her credit card account. Defendant's failure to make the required payments is a material breach of the cardholder agreement. On or about August 2002, Plaintiff, Credit Plus Solutions Group, purchased Defendant's credit card account %5260316230002390 with Chase. As of approximately, August 2002, Plaintiff, Credit Plus Solutions Group is 'the owner of Defendant's Chase credit card account number %526031623002390. At the time of the sale 'to Plaintiff, Credit Plus Solutions Group, the amount due on the account #526031623002390 pursuant to the terms of the cardholder agreement between Chase and Defendant, Chandra L. Farner was $2979.04. Due to Plaintiff's purchase of account no. 5260316230002390, Defendant Chandra L. Farner, owes Plaintiff, Credit Plus Solutions Group the amount of $2979.04 the outstanding balance of her credit card account. Despite repeated demands by Plaintiff for payment, Defendant has failed and refused to pay the outstanding balance owed on her credit card account. Defendant's failure to remit to Plaintiff the amount owed of $2979.04 is a ma'terial breach of the cardholder agreement. Defendant's breach, as aforesaid, has caused Plaintiff damages in the amount of $2979.04. WHEREFORE, Plaintiff, Credit Plus Solutions Group, Inc., requests judgment to be entered against Defendant, Chandra Farner, for the principal amount of $2979.04, plus court costs. Respectfully submitted, Mar~ S. Dietz, Esq. Attorney for Plaintiff, Credit Plus Solutions Group Attorney ID#68257 Credit Plus Collection Services, Legal Department P.O. Box 67533 2491 Paxton Street Harrisburg, PA 17106-7533 {717) 236-8031 ext. 2024 VERIFICATION I, Robert R. Wozniewicz, CEO/President, Credit Plus Solutions Group Inc., verify that I am CEO/President of Credit Plus Solutions Group, Inc., and am authorized to make this verification on behalf of Plaintiff, CREDIT PLUS SOLUTIONS GROUP, INC. The foregoing Civil Complaint is true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. 4904 relating to unsworn falsification to authorities. Robert R. Wozni~icz,C~President Credit Plus Solutions ~Ffroup, Inc. SHERIFF'S RETURN - REGULAR CASE NO: 2003-00792 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CREDIT PLUS SOLUTIONS GROUP IN VS FARNER CHANDRA L GERALD WORTHINGTON , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon FARNER CHANDRA L the DEFENDANT at 105 WEST PINE STREET , at 1920:00 HOURS, on the 26th day of February , 2003 MT HOLLY SPRINGS, PA 17065 by handing to CHANDRA L FARNER 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 Service Affidavit Surcharge 18 00 4 14 00 10 00 00 32 14 Sworn and Subscribed to before me this /0 ~-~ day of ~ ~l~ A.D. ~ ~ ProthOnotar~-~ · So Answers: R. Thomas Kline 02/27/2003 CREDIT PLUS Deputy S~Tri f f IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA- CIVIL ACTION-LAW CREDIT PLUS SOLUTIONS GROUP, INC., Plaintiff CHANDRA L. FARNER, Defendant COMPLAINT No. 03-792 Civil CIVIL ACTION-LAW JURY TRIAL DEMANDED CERTIFICATION OF MAILING TEN-DAY NOTICE TO THE PROTHONOTARY: Plaintiff, Credit Plus Solutions Group, Inc. mailed by regular mail on March 20, 2003, a Ten Day Notice of Default to the Defendant, Chandra L. Farner, at her last known address and service address of 105 West Pine Street, Mt. Holly Springs, PA 17065. z, Esq. Attorney for Plaintiff Legal Department, Credit Plus Solutions Group, Inc. 2491 Paxton Street P.O. Box 67533 Harrisburg, PA 17106 (717) 236-8031 ext. 2024 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA-CIVIL ACTION-LAW CREDIT PLUS SOLUTIONS GROUP, INC., : Plaintiff : : V. : : CHANDRA L. FARNER, : Defendant : COMPLAINT No. 03-792 Civil Civil Action-Law Jury Trial Demanded TO: CHANDRA L. FARNER DATE OF NOTICE: March 20, 2003 IMPORTANT NOTICE 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 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 OR 800-990-9108 _ Mary S .~. e~t~ c Attorney for Plaintiff 2491 Paxton Street Harrisburg, PA 17111 (717) 236--8061 ext. 2024 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNT~7[ PENNSYLVANIA- CIVIL ACTION-LAW CREDIT PLUS SOLUTIONS GROUP, INC., Plaintiff Vo CHANDRA L. FARNER, Defendant : COMPLAINT No. 03-792 Civil CIVIL ACTION-LAW JURY TRIAL DEMANDED CERTIFICATION OF MAILING TEN-DAY NOTICE TO THE PROTHONOTARY: Plaintiff, Credit Plus Solutions Group, Inc. mailed by regular mail on March 20, 2003, a Ten Day Notice of Default to the Defendant, Chandra L. Farner, at her last known address and service address of 105 West Pine Street, Mt. Holly Springs, PA 17065. Attorney for Plaintiff Legal Department, Credit Plus Solutions Group, Inc. 2491 Paxton Street P.O. Box 67533 Harrisburg, PA 17106 (717) 236-8031 ext. 2024 Plaintiff's Exhikit "A" Pg 1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA-CIVIL ACTION-LAW Vo CHANDRA L. FARNER, Defendant CREDIT PLUS SOLUTIONS GROUP, INC., : Plaintiff : : : : : : COMPLAINT No. 03-792 Civil Civil Action-Law Jury Trial Demanded TO: CHANDRA L. FARNER DATE OF NOTICE: March 20, 2003 IMPORTANT NOTICE 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 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 OR Mary S '.~~et z,' ~sq.~~ Attorney for Plaintiff 2491 Paxton Street Harrisburg, PA 17111 (717) 236-8061 ext. 2024 Plaintiff's Exhibit "A" Pg. 2 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA- CIVIL ACTION-LAW CREDIT PLUS SOLUTIONS GROUP INC., Plaintiff CHANDRA FARNER, Defendant COMPLAINT NO. 03-792 Civil CIVIL ACTION-LAW JURY TRIAL DEMANDED PRAECIPE FOR ENTRY OF JUDGMENT OF DEFAULT TO THE PROTHONOTARY: Please enter judgment of default in favor of Plaintiff, Credit Plus Solutions Group, Inc. and against Defendant, CHANDRA FARNER, for Defendant's failure to plead to the complaint in this action within the required time. The complaint contains a notice to defend within 20 days from the date of service thereof. Defendant was served with the complaint on FEBRUARY 26, 2002 and defendant's Answer was due to be filed on MARCH 18, 2003. Attached as Exhibit "A" is a copy of Plaintiff's written Notice of Intention to File Praecipe for Entry of Default Judgment, which I certify was mailed by regular mail to the Defendant at her last known address of 5105 West Pine Street, Mt. Holly Springs, PA 17065, on March 20, 2003 which is at least 10 days prior to the filing of this Praecipe. Please assess damages as set forth below: Principal Amount: $2979.04 Interest Amount: $ Court Costs: $ 96.64 Total Amount: $3075.68 Damages should be' assessed at $3075.68, being the amount demanded in the complaint plus court costs. y ;.~Oietz, Esqu r~ Attorney for Plaintiff OFFICE OF THE PROTHONOTARY, COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA CREDIT PLUS SOLUTIONS GROUP, INC., : Plaintiff : CHANDRA L. FARNER, : Defendant : COMPLAINT NO. 03-792 CIVIL CIVIL ACTION-LAW JURY TRIAL DEMANDED NOTICE TO: CHANDRA FARNER, Defendant 105 WEST PINE STREET MT. HOLLY SPRINGS, PA 17065 Pursuant to Pa. R.C.P. 236, you, Chandra Farner, Defendant, are hereby notified that a JUDGMENT BY DEFAULT has been entered against you in the above proceeding in the amount of $3,075.68. Prothonotary IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA-CIVIL ACTION-LAW CREDIT PLUS SOLUTIONS GROUP INC., Plaintiff CHANDRA L. FARNER, Defendants COMPLAINT NO. 03-792 Civil CIVIL ACTION-LAW AFFIDAVIT OF NON-MILITARY SERVICE Robert R. Wozniewicz, President/CEO, being duly sworn according to law, deposes and says that he is an officer of plaintiff; that he is authorized to make this affidavit on behalf of plaintiff; that the above-named defendant resides at 105 West Pine Street, Mt. Holly Springs, PA 17065, and to the best of his knowledge that the defendant is not in the Military Service of the United States, nor any State or Territory thereof or its allies as defined in the Soldiers' and Sailors' Civil Relief Act of 1940 and the amendments thereto. Date: Robert ~./ Wo'z~iewi~, Pres~i~ent/CEO Credit Plus Solutions Gr~,~Inc. SWORN to and Subscribed Before me this ~ day of _~,~/~2//~'~ , 2003. ~tary Public ~