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Home My WebLink About03-1355IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CREDIGY RECEIVABLES, INC. SUCCESSOR IN INTEREST TO FIRST SELECT, INC. Plaintiff VS. CHARLES S. LOVENDUSKY 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#02648047 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CREDIGY RECEIVABLES, INC. SUCCESSOR IN INTEREST TO FIRST SELECT, INC. Plaintiff VS. CHARLES S. LOVENDUSKY Defendant Civil Action No. COMPLAINT IN CIVIL ACTION 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 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. CHARLES S. LOVENDUSKY Defendant Civil Action No. (~ 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, Charles S. Lovendusky, and, in support thereof, Plaintiff avers as follows: 1. The Plaintiff, Credigy Receivables, Inc., successor in interest to First Select, Inc., is a corporation with its principal place of business located at Two Sun Court, Suite 450, Norcross, GA 30092. 2. Plaintiff is the owner of this account, which is the subject matter of this action. 17025. Defendant is an adult individual residing at 6893 Wertzville Road, Enola, PA 4. Defendant requested the account and made use of said account and has currently a balance due and owing to Plaintiff, as of August 27, 2002, in the amount of $3,714.10. 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, Charles S. Lovendusky individually, in the amount of $3,714.10 with finance charges thereon at the rate of 6% per annum from August 27, 2002, 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. W I I..-LIAf¢i~. MOL(~Z.~N,~UIRE PA I.D.¢/47437 Weltman, Weinberg & Reis Co., L.P.A. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#: 02648047 \~RIFICATION The undersigned does hereby verify subject to th.e penalties of 1. 8 PA.C.S. ~4904 relatin.g to unswom falsifications to authorkies, that he/she is ~k~J 0c ri 6~ C~t ~6~/3 , J(Nam.e) v'q ~,/e~ -l~r~c' , plaintiff herein, that A~ ~4.5~c~c~1 of Cc~t~D ~c~, _. (Title) ~' (Company) he/she is duly authorized to make fl~/.s Verification, mad that the facts set forth in the foregoing Compla/nt in Complaint m-e true mhd correct to the best oft~s/h.er lmowledge, infonnation and belief. SHERIFF'S RETURN CASE NO: 2003-01355 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CREDIGY RECEIVABLES INC VS LOVENDUSKY CHARLES S REGULAR BRIAN BARRICK , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon LOVENDUSKY CHARLES S the DEFENDANT at 6893 WERTZVILLE ROAD ENOLA, PA 17025 , at 1436:00 HOURS, on the 31st day of March , 2003 by handing to FRANCES LOVENDUSKY, MOTHER 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 7 59 00 10 00 00 35 59 Sworn and Subscribed to before me this 7o ~ day of ~L~7 ~ A.D. othonotary ' ' So Answers: R. Thomas Kline 04/01/2003 ~ A WELTMAN WEINBER!~EIS ~ /! By: D/e~[i f~ 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CREDIGY RECEIVABLES, INC. SUCCESSOR IN INTEREST TO FIRST SELECT, 1NC. Plaintiff VS. CHARLES S. LOVENDUSKY Defendant No. 03-1355 CWIL TERM PRAECIPE TO SETTLE, DISCONTINUE & END FILED ON BEHALF OF Plaintiff COUNSEL OF P, ECORD OF THIS PARTY: William T. Molczan, Esquire PA. I.D.g47437 WELTMAN, WiEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Aw:nue Pittsburgh, PA 15219 (412) 434-7955 WWR#02648047 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. 03-1355 CIVIL TERM CHARLES S. LOVENDUSKY Defendant PRAECIPE TO SETTLE DISCONTINUE AND END TO THE PROTHONOTARY OF COUNTY: Please kindly Settle Discontinue and End the above captioned matter upon the records of the Court and mark the cost paid. WELTMAN, WEINBERG & REIS CO., L.P.A. William 1~ l{/lolczan, ~squire ~/ PA. I.D.#47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Bailding 436 Seventh Aw:nue Pittsburgh, PA ].5219 (412) 434-7955 WWR#02648047