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Home My WebLink About03-1353IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CREDIGY RECEIVABLES, INC. SUCCESSOR IN INTEREST TO FIRST SELECT, INC. Plaintiff VS. VANESSA L. HORNE Defendant COMPLAINT IN CIVIL ACTION FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: WILLIAM T. MOLCZAN, ESQUIRE PA I.D.#47437 Weltman, Weinberg & Reis Co., L.P.A. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#02689904 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CREDIGY RECEIVABLES, INC. SUCCESSOR IN INTEREST TO FIRST SELECT, INC. Plaintiff VS. VANESSA L. HORNE Defendant Civil Action No. COMPLAINT IN CIVIL ACTION AND NOTICE TO DEFENn 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 LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CREDIGY RECEIVABLES, INC. SUCCESSOR IN INTEREST TO FIRST SELECT, INC. Plaintiff vs. Civil Action No. VANESSA L. HORNE Defendant COMPLAINT AND NOW COMES, Plaintiff, Credigy Receivables, Inc., successor in interest to First Select, Inc., by and through its counsel, WELTMAN, WEINBERG & REIS, CO., LPA., and hereby files this Complaint against Defendant, Vanessa L. Horne, and, in support thereof, Plaintiff avers as follows: 1. The Plaintiff, First Select, Inc., is a corporation with its principal place of business located at 4460 Rosewood Drive, Pleasanton, CA 94588. 2. Plaintiff is the owner of this account, which is the subject matter of this action. 3. Defendant is an adult individual residing at 547 Good Hope Road, Mechanicsburg, PA 17050. 4. Defendant requested the account and made use of said account and has currently a balance due and owing to Plaintiff, as of February 26,2003, in the amount of $3,594.82. 5. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed and/or refused to pay the balance. WHEREFORE, Plaintiff demands Judgment in its favor and against Defendant, Vanessa L. Horne individually, Jn the amount of $3,594.82 with finance charges thereon at the rate of 6% per annum from February 26,2003, plus costs. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED SHALL BE USED FOR THAT PURPOSE. WELTMAN, WEINBERG & REIS, CO., L.P.A. Weltman, Weinberg & Reis Co., L.P.A. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#: 02689904 \rERIFICATION The undersig].ed does hereby verify subject to the penalties of 18 PA.C.S. 44904 relating to ~swo~m f~sifications to authorities, ~at he/she is ~ (N~e) ~ . ~C~C~ of CC~ ~c~' 1~(~2 ~; pl~ntiffh.erein, that (Title) 3 he/she is duly autho~ed to make tl~.s Vmification, and fl~at the hcts set fo~h in the foregoing Complain.t in ~mplaint are ~e m~.d cm~ect to rite best of iris/her h~owledge, i~onn.afion and beliefi SHERIFF'S RETURN - REGULAR CASE NO: 2003-01353 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CREDIGY RECEIVABLES INC VS HORNE VANESSA L DAWN KELL , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon HORNE VANESSA L the DEFENDANT , at 547 GOOD HOPE ROAD at 2025:00 HOURS, on the 1st day of April , 2003 MECHANICSBURG, PA 17050 by handing to VANESSA L HORNE a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18 00 8 28 00 10 00 00 36 28 Sworn and Subscribed to before me this 2~ day of ~ ~.,'$ ,;~6~ A.D. ! t~rott{oh0tary So Answers: R. Thomas Kline 04/02/2003 WELTMAN WEINBERG REIS Deputy Sheriff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CREDIGY RECEIVABLES, INC., SUCCESSOR IN INTEREST TO FIRST SELECT, INC. Plaintiff VS. VANESSA L. HORNE No.03-1353 CIVIL TERM STIPULATION OF THE PARTIES FOR PAYMENT AND FOR THE ENTRY OF JUDGMENT BY CONSENT Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: WILLIAM T. MOLCZAN, ESQUIRE PA I.D.#47437 GERIANNE HANNIBAL, ESQUIRE PA I.D. #66622 Weltman, Weinberg & Reis Co., L.P.A. 2718 Koppers Building Pittsburgh, PA 15219 (412) 434-7955 WWR#02689904 THIS LAW FIRM IS ATTEMPTING TO COLLECT THIS DEBT FOR ITS CLIENT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CREDIGY RECEIVABLES, INC., SUCCESSOR IN INTEREST TO FIRST SELECT, INC. Plaintiff VS. VANESSA L. HORNE Defendant Civil Action No. 03-1353 CIVIL TERM STIPULATION OF THE PARTIES FOR PAYMENT AND FOR THE ENTRY OF JUDGMENT BY CONSENT AND NOW, comes the Plaintiff, by counsel, and the Defendant to Stipulate to Settlement and the Entry of Judgment by Consent, as follows: 1. Defendant admits indebtedness to Plaintiff in the amount of $3,594.82 with continuing attorneys' fees and interest thereon at a rate of 6% per annum plus costs from February 26, 2003. 2. To secure the repayment of said indebtedness, Defendant agrees that Judgment by Consent will be entered in favor of the Plaintiff and against the Defendant, Vanessa L. Horne, in the amount of $3,594.82 plus continuing interest thereon at the rate of 6% per annum from February 26, 2003 and costs. 3. Plaintiff agrees not to Execute on its Judgment so long as Defendant causes to be delivered to Plaintiff the following payments in full by 12:00 NOON on the following dates: (a) $152.00 due by April 30, 2003; (b) no less than $152.00 per month due on the 30th day of each consecutive month thereafter until the Judgment amount plus accrued interest and costs are paid in full. 4. All payments are to be made payable to the order of "Credigy Receivables, Inc." 5. All payments due under this agreement, is to be received at the offices of Weltman, Weinberg & Reis, Co., L.P.A., 2718 Koppers Building, 436 Seventh Avenue, Pittsburgh, PA 15219. 6. In the event of default, each payment received shall be first attributed to costs, interest and then to principal. 7. Time is of the essence of this agreement and should the Defendant fail to have in the hands of Plaintiff or Plaintiff's counsel any payment in full within five (5) calendar days of the stated due date, then Plaintiff shall be immediately free to issue Execution as well as pursue all other remedies, in law or in equity, to collect the full balance of the Judgment entered hereunder plus appropriate additional interest and costs. 8. No act or omission of the Plaintiff, nor of anyone alleged to be acting on its behalf, shall constitute a waiver, estoppel, or any other excuse for non-performance of any duty undertaken by the Defendant in this Stipulation which the parties agree is final and complete. 9. Intending to be legally bound, the parties set their hands and seals this 20 C,..~ THIS LAW FIRM IS ATTEMPTING TO COLLECT THIS DEBT FOR ITS CLIENT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. WELTMAN, W~IN! WILL~I~M~, MdL~z PA I.D.#47437 !RG & REIS C ;AN, ESQUIRE GERIANNE HANNIBAL, ESQum PA I.D. #66622 Weltman, Weinberg & Reis Co., LP.A. 2718 Koppers Building Pittsburgh, PA 15219 (412) 434-7955 )., L.P.A. VANESSA L. HORNE WWR#02689904 By: ~[ ~"¢~_~_~.~_L Defendant -- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CREDIGY RECEIVABLES, INC., SUCCESSOR 1N INTEREST TO FIRST SELECT, INC., Plaintiff No. 03-1353 CIVIL VS. VANESSA L. HORNE, Defendant CERTIFICATE PREREQUISITE TO SERVICE. OF A SUBPOENA PURSUANT TO RULfi 4009.22_ As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22, Plaintiff certifies that: (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. William T. Molczj~ Esquire Attorney for Plaintiff Pa. LO. # 4.7437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR #02689904 IN THE cOURT OF coMMON PLEAS cUMBERLAND coUNTY, PENNSYLVANIA CIVIL ACTION cKEDIGY KECEWABLES, INC., SUCCESSOR IN INTEREST TO FIRST SELECT, INC., Plaintiff, VS. vANESSA L. HoRNE, Defendant. ) ) ) ) ) ) ) ) ) ) ) ) NO.: 0:3 - 1353 CWIL TERM ~T TO sERVE A SUBPOENA TO pI_tODUCE DocUMENTS AND~ THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 Plaintiff intends to serve a subpoenas identical to the one attached to this notice. You have twenty days from this date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If no objection is made, the subpoena may be served. Date ~ ~f_~O-t~/ Will.iam T. Molcza~ Esquire Attorney For Plaintiff coMMON~ALTH OF PENNSIrLVANIA coUNTY OF CIJMBBRLAND CREDIGY RECEIVABLES?_ INC., SuccESSOR IN IblIMREST TO FIRST SELECT, INC., : : File No 03-1353 CIVIL TER~J VS. VANESSA L. HoRNE, : SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: American Hond~nan~-e- -- (Name of Person or Entity) within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: 1)_ a co_9.py_~f Vanessa L. H_orne's (S$~ 1~3-72-~Ll~5-~~G°°~ Hollo Rd, Mechanicsbur_qy_~ PA~ 17050) cre____dit_app_lication to _Kg_~r c_ompan__~i; 2~_a copy of__the checks Vanessa Home _uses t__po pay her a__~_BDD~i~t &~3)~ly o~a~r clo~i~nt id~nt~n5 ha~__~nk accounts. at 2718 Kopper bldg., 4.36 Seventh Ave. ,_ Pitt~sbut' h3~b~A 15219 ~ - ~ -- - (Address) You may deliver or mail legible copies of the documents or produce things requested by.th/s subpoena, together with the certificate of compliance, to the party making t~is request at the address hsted above. You have the right to seek m advance the reasonable cost ofprepanng the copies or producing the things sought. If you fail to produce the documents or things required by t~fis subpoena witkin twenty (20) days after its service, the party serving tiffs subpoena maY seek a court orde:r compelling you to comply with it. THIS sUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: N~ME: Weltm~_n~_Wei_nberg, & Re_is _Co., L.P.A. by williamT. Molczan ADDRBS s:~per s_bld 'gz~--- 436 Seventh Ave., Pittsburgh~ - PA 13219 ....... ~ SUPoRNEyFoR.Plai~tiff ~l Re. celvables ATT .- -- Date:~