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Home My WebLink About98-06811 l., ~ cr., !~ i i?i I i ; Vi I'QJ I !:: , -r .. & ~ r-g, '-;!:' "'. 'C -' ~ ~ (- - J -' 0() --5 , 00 0- -- .. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION UNIFUND CCR PARTNERS, Defendants. ) ) ) ) ) ) ) ) ) ) No, Plaintiff. vs, ROBERT W. SHAFFER. JR., and WARREN T. SHAFFER. 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 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 FINE OUT WHERE YOU CAN GET LEGAL HELP. COURT ADMINISTRATOR 4TH FLOOR, CUMBERLAND COUNTY COURTHOUSE CARLISLE. PA 17013 4, On or about October 30. 1991. the Defendants applied for and were approved to receive a Consumer Installment loan (hereinafter "loan") totaling $6.622.12 from the First Bank of Trust Company a PNC Bank, Such loan was issued at Account Number 631060847. 5. Said loan was to be paid by the Defendants to PNC at the rate of $171.46 per month for 48 months beginning on December 5, 1991. 6. Beginning in or about April 1992 and continuing thereafter the Defendants began to be in default on the loan by failing to make the monthly payments to PNC. 7. As of the present, the Defendants owe $2.859.84 in principal. and $1.226.38 in interest. The total amount owed is $4.086.22. 8. Despite written and oral demands for payment. Defendants have failed and refused to pay the amount due and owing. 9. The loan has been assigned to and purchased by the Plaintiff, . 10. The following amounts are currently due and owing from the Principal Balance $4.086,22 Defendant: Reasonable Allorney's Fees (20%) $ 817,24 $4,903.46 9. The Account has been assigned by PNC Bank to the Plaintiff including all rights to collect the amount due from the Defendant. WHEREFORE. the Plaintiff. Unifund CCR Partners demands that judgment be entered in its behalf and against the Defendants, Robert W. Shaffer. Jr. and Warren T. Shaffer in the sum of $4,903.46 plus costs and interest. TUCKER ARENSBERG, P,C, By: ~\~ JOnath~)S. McAnney, Esquire 1500 One PPG Place Pillsburgh, PA 15222 Allorneys for Plaintiff Lit 151703 1J!:8JEW~J'!PJ" The undersigned verifies that the statements made In the foregoing Complaint are true and correct to the best of her knowledge, information and belief and understands the statements therein made are made subject to the penalties of 18 Pa,C,S, ~4904 relating to unsworn falsification to authorities, 126472.1 11112/97 l' , w .>, r~ l.:::l .. ~ ~ " ....... -c:: -- " ry '-.I -- tt ~:"'l <::. - (--.J ~ ~. ....'\ r:J ~( . ~J \ .J:::-.-, '-" '-!l ,,~, "" C, '" ~.l .. ';~ '1 ;:;. "t~ " IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA UNIFUND CCR PARTNERS, CIVIL DIVISION ARBITRATION DIVISION No. tfJ h f II (It ~L'lL Plaintiff. COMPLAINT IN CIVIL ACTION Filed on behalf of Unifund CCR Partners, Plaintiff vs. ROBERT W. SHAFFER, JR., and WARREN T. SHAFFER Defendants. Counsel for Unifund CCR Partners: Jonathan S. McAnney, Esquire Pa. I.D. #50041 LIT 151703 Tucker Arensberg, P.C. Firm #287 1500 One PPG Place Pittsburgh. PA 15222 (412) 566-1212 TRUE 'oPV In Tastj FRoM RECoRD and ~ :--.1 here unlll!llll my hand r . It Car1~a.L .., IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION UNIFUND CCR PARTNERS. Defendants. ) ) ) ) ) ) ) ) ) ) No, Plaintiff, vs. ROBERT W. SHAFFER, JR., and WARREN T, SHAFFER. 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 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 BE'-OW TO FINE OUT WHERE YOU CAN GET LEGAL HELP. COURT ADMINISTRATOR 4TH FLOOR, CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 4. On or about October 30, 1991. the Defendants applied for and were approved to receive a Ccnsumer Installment Loan (hereinafter "Loan") totaling $6.622.12 from the First Bank of Trust Company a PNC Bank, Such Loan was issued at Account Number 631060847. 5. Said loan was to be paid by the Defendants to PNC at the rate of $171.46 per month for 48 months beginning on December 5,1991. 6. Beginning in or about Apri/1992 and continuing thereafter the Defendants began to be in default on the loan by failing to make the monthly payments to PNC. 7. As of the present, the Defendants owe $2,859.84 in principal, and $1,226.38 in interest. The total amount owed is $4,086.22. 8. Despite written and oral demands for payment, Defendants have failed and refused to pay the amount due and owing. 9. The loan has been assigned to and purchased by the Plaintiff. 10. The following amounts are currently due and owing from the Defendant: Reasonable Attorney's Fees (20%) $4,086.22 $ 817,24 $4,903.46 Principal Balance 9. The Account has been assigned by PNC Bank to the Plaintiff including all rights to collect the amount due from the Defendant. WHEREFORE, the Plaintiff, Unifund CCR Partners demands that judgment be entered in its behalf and against the Defendants, Robert W. Shaffer, Jr. and Warren T. Shaffer in the sum of $4,903.46 plus costs and interest. TUCKER ARENSBERG, P.C. I~I' 'i By: /( ! '/1".."1..-- JOnath~n)s. McAnney, Esquire '.. 1500 One PPG Place Pittsburgh, PA 15222 Attorneys for Plaintiff Lit 151703 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION UNIFUND CCR PARTNERS, Plaintiff, No vs, ROBERTW. SHAFFER. JR., and WARREN T. SHAFFER, Defendants, TO: Robert W. Shaffer, Jr. 505 Hogestown Road Mechanicsburg. PA 17055 J DATE OF NOTICE: March..Y.1999 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN THIS CASE, UNLESS YOU ACT WITHIN TEN (1 0) 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: COURT ADMINISTRATOR 4th FLOOR CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 240-6200 / / Jonatl)a , ,McAnney, Esquire TUC'1E ARENSBERG, P,C, 1500, ne PPG Place Pittsb'urgh, PA 15222 lit: 160422 ;:. , t , , , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA UNIFUND CCR PARTNERS, CIVIL DIVISION ARBITRATION DIVISION No, 98.6811 CIvil Plaintiff, TEN DAY NOTICE AGAINST , ROBERT W. SHAFFER, JR., ONLY vs, Filed on behalf of Unifund CCR .-. Partners, Plaintiff ROBERT W. SHAFFER, JR., and WARREN T. SHAFFER .",- Defendants, Counsel for Unifund CCR Partners: Jonathan S, McAnney. Esquire Pa. 1.0, #50041 LIT 160422 Tucker Arensberg, P,C, Firm #287 1500 One PPG Place Pittsburgh, PA 15222 (412) 566-1212 :;J ~ " ) '" .J , I ., C" -, 1 " '-, ~? ;, , ") =.:' ,,",-, :=j C-.> ::;'j -< CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the within Ten Day Notrcn ? was served on the followlllg by first class mall, postage pre-paid on tile -===-- day of March, 1999: Robert W. Shaffer. Jr. 505 Hogestown Road Mechanicsburg, PA 17055 Ii!: 160422 ~ '?\\\ ~ Jonathan S, McAnney, Esquire U r~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION UNIFUND CCR PARTNERS, Plainllfr, No 98.G811 C,Vil vs. ROBERT W. SHAFFER. JR., and WARREN T. SHAFFER, NOTICE OF JUDGMENT Defendants, TO: Robert W. Shaffer, Jr. 505 Hogestown Road Mechanicsburg, PA 17055 You are hereby notified that a judgment was entered against you and in favor of Plaintiff in the above-captioned proceeding on (.) p,2, \ l I C( , 1999, The default judgment is in the amount of $4.903.46 plus costs of suit. /) -.ld::C ').. ( Deputy 9, 71Jc:Jz/2('l.,) ( LIT 163825,1 " .;1 .'; r. i , " F (0 n ~ t -..0 f!:.: ("\ -<- v F r\ (, ,", ~ '.... '.' ~ .~ ., 6" -I , . , ~ ...0 ~ ~ ; .... '\' loJ V Q if" 1""----_ ~ ~ " R -/.::" -. -I-.... .. -....z t;- '. I.::l ~ II , , r 1 " fi I' t. F.' G_'~ L ~; P i,~ J ~\~ ~- ~ ':--' ~ ("'. ,~ ~ ~ --0 ~ 'S o \LI), , - T'~ r---. ~- \ i ___ ?--v ~ - ~" rt-. c::.J; ;"' .., I 1~. ' "" 1".-' f'-I .... I, )(, ~ ~' .......... ~" +. "-'-' ~ c::;, ~ ~y " )v . ,-, "'0 '" ('. rv "", " , ~" .......... ~ ..... \:" ~ :~") I ~: ) .1 . I , J ."'j : .~ , ,'C,J :.., ," - ~:2 r' 1 WRIT OF EXECUTION and/or AlTACHMENT COMMONWEAl TH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) TO THE SHERIFF OF ... __ _C!:!~I3_~:RL"!,,.r:'. _ _ To SatiSly the deb!. IOlerest and costs due NO 'J,~_~ (, 8 II CIVIL 19 CIVIL ACTION. LAW _COUNTY Uni fund Cell P,lrtn"rs . --'. '~-'.'" _._-~.. .._~..__... .-... -----..-.-- --.-..-----.-- '--""-"-'-. from !.~ ~":~__~__~S_ha_ f f" r . .1 r-=-.:.....~~_2 0 _ Ca rl 17055. -- --- ---------_ __ PLAINTlFF(S) Pike, Lut 409, Mechanicsburg p^ "0,', __'.0' __._ ___._ '._ _'___ ___ --~-_...._-- - ----,-..... .".-... ._'---------_.,,~- ---------,...-,.----------- ------.-- ---..------- - -------- DEFENDANT(S) (1) You are direcled to levy upon Ihe prope~yolthe delendanl(S) and 10 se"~iz,,,. l",vy. adv",r- tis", and sdl all person~~___p":op<:rty_o_~ the def"!:ld__~~_~the premis"s list"d above. ----~-~.... --~-..-_.---~-__.___._____u_._.__"__ ---------.-.--..----. (2) YOII are also directed to allach the properly ot the defondanl(S) nol levied upon in the POssession 01 _ ------------- -----'-~------'------_._..~-----_. ._------~_.- .....--- .. --- --..---.-.-- --_._-~.- - -- . -..-----.... "-- ---.~---_.._--~ GARNISHEE(S) as follows: and to notffy the garniShee(s) that: (a) an attachmenl has been issued; (b) the garnishee(s) iSfare enjoined from paying any debito or lor the account otlhe defendant(s) and from delivering any prope~y of the defendanl(s) or otherwise disposing thereof; (3) ff prope~yotthedefendanl(S) nol levied upon an subject to attachment is found in the possession of anyoneolher than a named garnishee, you are direcled to notily hirwherthal he/she has been added as a garnishee and is enjoined as above stated, A to $4.903.46 moun ue I from 4/20/99 to 8/30/99 @ 6% nlerest L.L. $106.39 --- Due Prothy Other Cosls $.50 $1. 00 Ally's Comm AttYPaid $121.02 Plaintiff Paid % Dale: August 30, 1999 CURTIS R. LONG by: Deputy REQUESTING PARTY: Name Jonathan s. McAnney, Esq. Address: 1500 One PPG Place Pittsburqh PA 15222 Allorneylor: Plaintiff Telephone: (412) 566-1212 Supreme Cou~ 10 No, 50041