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Home My WebLink About98-06733 .~ I 0 (J '^ 7 j - .;::.r, o .-z. c ~. 'i -:r. ~ ~ 19 i '3 10 I I irn 1(") Ie- 1...5 I . I i i I ()O cr D Z. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HUNTINGTON NATIONAL BANK CASE NO: 9~- {p 7:33 Plaintiff. v. CANDACE M. COOK COMPLAINT IN CIVIL ACTION Defendant FILED ON BEHALF OF Plainliff COUNSEL OF RECORD OF THIS PARTY: ~).~-L Lori A. Gibson, Esquire Pa.1.0.#68013 WELTMAN, WEINBERG & REIS CO., L.P.A. 2601 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR #01450053 Ii::. , C.QMPLAINT 1. Plaintiff is iI corporation with offices at 41 S. High Stree!. Columbus, Ohio 43215 2. Defendant is an adult individual residing at 5202 Simpson Road, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3, On or about June 13, 1996, Defendant duly executed a Note (hereinafter the "Contract") in favor Roby Chevy aids Inc., the Seller, a true and correct copy of said Contract and Security Agreement is attached hereto, marked as Exhibit "1" and made a part hereof. 4. Pursuant to said Contract, Defendant took possession of the vehicle more particularly identified as a 1992 Geo Tracker. 5. Pursuant to the terms and conditions provided by the Contract, the Contract was assigned from Roby Chevy aids Inc. to Plaintiff. 6. Defendant defaulted under the terms of the parties' agreement by failing to make payment to Plaintiff as promised, thereby rendering the entire balance of the Contract immediately due and payable. 7. By the terms of the parties' agreement, more specifically the "acceleration clause" therein, Defendant's default made the entire balance of the loan immediately due and payable. .. .l I, WHEREFORE, Plaintiff demands JudfJment in its favor and against Defendant, Candance M. Cook, individually, in the amount of 55.727.47 with appropriate additional attorneys' fees and continuing interest thereon at the rate of 10.75% per annum plus costs. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED SHALL BE USED FOR THAT PURPOSE. ; " ERG & REIS CO., L.P.A. .~ Lori A. on, Pa.1.0.#68013 Attorney for Plaintiff WELTMAN, WEINBERG & REIS CO., L.P.A. 2601 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR #01450053 ... ~ Ii; . \ I' I ,. \ ~,~. <t", , ) ~ . , . . ! ! I ,. >., ~~ - ,--.J "f../'-'- Y Uv -.\) -'\ -... ~ e:; ~, )'J '-N ,--," lS'--. C-' !f '0 --j .. ~ r, ~:\"~ . \ <...,).- ''C - I c> p, I \ t 8. 1998, Plnintiff nvers lhnt n balance of $5,700,40 is due from Defondnnt ns of August 28, 12. Plaintiff avers thnt the written agreement between lhe parties provides that Plaintiff is entitled to interest at the rate of 10.75% por annum. 13. Plaintiff avers that interest from August 29, 1998 to October 1, 1998 calculated at the aforesaid rate amounts to $57.07. 14. Plaintiff avers that the Contract between the parties provides that Defendant will pay Plaintiff's reasonable attorneys' fees in the event of collection. 15. Plaintiff avers that such attorneys' fees amount to $70.00 to date and that said fees continue to accrue. 16, Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed and/or refused to pay the principal balance, attorneys' fees, interest or any part thereof to Plaintiff. WHEREFORE, Plaintiff demands Judgment in its favor and against Defendant, Candance M, Cook, individually, in the amount of $5,727.47 with appropriate additional attorneys' fees and continuing interest thereon at the rate of 10.75% per annum 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. Lori A. Gibson, Pa.I.D.#68013 Attorney for Plaintiff WELTMAN, WEINBERG & REIS CO., L.P.A, 2601 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR #01450053 VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA,C.S. I 4904 relating to unsworn falsification to authorities, that he/she is ~ s (' (!D v k {!f2a-l:1- fj,J,"~:5JOR- of iLrJf,'A)O.JO,J (N~lJi ,Plaintiff (Title)"'"J (CarlJpany) herein, that he/she is duly authorized to make this Verification, and that the facts set forth in the foregoing Complaint are true and correct to the best of his/her knowledge, information and belief. ~CLL (Signature) t ( '- ....:./1. (j'''' VL [ f ~~ , c::g , ~ [jViJ . , -, '. l' .. ) .. t :I I ~ i~ ~ " :/ \,"1 iJI',',' ~; :~:' 1'1" l,:i j""'. i Ii , :~j\ ,\'0-,; " ) """-(' ,"/.:1. ~;v , . ji _ ~: h " vs. Civil Action No, 98-6733 CIVIL IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY. PENNSYLVANIA CIVIL DIVISION HUNTINGTON NATIONAL BANK Plaintiff CANDACE M. COOK Defendant PRAECIPE TO SETTLE. DISCONTINUE AND END WITHOUT PREJUDICE TO REFILE TO THE PROTHONOTARY OF CUMBERLAND COUNTY; SIR; Settle, Discontinue and End the above-captioned matter upon the records of the Court without ~ prejudice to refile and mark the costs paid. J WELTMAN, WEINBERG & REIS CO., L.P.A. ..:;~ NOlari.,J Seal I~im M. Jones, Not.1ry PUbnc Plllsl;urGh, AI1i.~nheny County My Commission Exp':.cc June 12, 2000 Member, Penneylvania Itssuci:!tion oJ Not.1ries By: Attorne . for Plaintiff 2601 Koppers Buildin 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#01450053 ,; Hi <'-;' -'S ? SWORN TO AND SUBSCRIBED before me this 2 ~rc\ day Of~, 1999 \d6.1 n J If ll.JDlf\jl) NOTARY PUBLIC