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Home My WebLink About01-0669 FX (2) LAW OFFICES OF COLAVECCHI RYAN & COLAVECCHI 221 E. MARKET ST. (ACROSS FROM COURTHOUSE) P. O. BOX 131 CLEARFIELD, PA ~ ".~ ,-- ,~" ,- -," ,1"'0 - ,. .".~'" , "'""--" ;: ...". ',..-,,"A,e ~,.",,"J '-'''-''c, ~,,, "" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CLAIMS RECOVERY SYSTEMS, INC., Assignee from CREDITONE, LLC, Assignee from DEBTONE, LLC, Assignee from HOUSEHOLD FINANCE CORPORATION, Plaintiff Vs. MICK K. RIEGEL, Defendant CIVIL DIVISION C--- No. 01 - l.t".? - ~G~""t tCC/L.r'\ COMPLAINT Filed on Behalf of: Plaintiff, CLAIMS SYSTEMS, INC. RECOVERY Counsel of Record for This Party: JOSEPH COLAVECCHI, ESQUIRE Pa. I.D. #06810 COLAVECCHI RYAN & COLAVECCHI 221 East Market Street P.O. Box 131 Clearfield, PA 16830 814/765-1566 LAW OFFICES OF COLAVECCHI RYAN & COLAVECCHI 221 E, MARKET ST, (ACROSS FROM COURTHOUSE) P. O. BOX 131 CLEARFIELD, PA , . -..\ "' ~'\ 1- '" c.__.' '.' .:,~ -'""- ^ ~ ' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CLAIMS RECOVERY SYSTEMS, INC., Assignee from CREDITONE, LLC., Assignee from DEBTONE, LLC, Assignee from HOUSEHOLD FINANCE CORPORATION, No. 01 - ~ (.9 (;,;J r ~ - ..., Plaintiff Vs. MICK K. RIEGEL, Defendant NOTICE 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 FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 249-3166 800/990-9108 ~" LAW OFFICES OF COLAVECCHI RYAN & COLAVECCHI 221 E. MARKET ST. (ACROSS FROM COURTHOUSE) P. O. BOX 131 CLEARFIELD, PA , ,;-'" '-1--- -""'1~~'W"'--' "",'" , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CLAIMS RECOVERY SYSTEMS, INC.,: Assignee from CREDITONE, LLC, Assignee from DEBT ONE , LLC, Assignee from HOUSEHOLD FINANCE CORPORATION, Plaintiff (7,_:':';'.1 7~ No. 01 - (,(, 9 '-"'::'~ vs. MICK K. RIEGEL, Defendant COMPLAINT 1. Plaintiff is Claims Recovery Systems, a corporation organized. and existing under the laws of the Commonwealth of Pennsylvania having its principal office 6 1/2 E. Mall Plaza, Carnegie, Pennsylvania 15106, which is assignee of CreditOne, LLC. CreditOne, LLC. is assignee from DebtOne, LLC, which is assignee from Household Finance Corporation. 2. Defendant is Mick K. Riegel, an adult individual, whose current mailing address is 120 West Green Street, Mechanicsburg, Pennsylvania 17055-1916. 3. Household Finance Corporation and Defendant entered into a Personal Credit Line Account Agreement dated October 1, 1997. A copy of said Agreement is in the possession of the debtor, the original Loan Agreement has been lost, stolen or destroyed. 4. Defendant has defaulted on this Agreement leaving a LAW OFFICES OF COLAVECCHI RYAN & COLAVECCHI. 221 E. MARKET ST. (ACROSS FROM COURTHOUSE) P. O. BOX 131 CLEAR FIELD, PA -- ~ -" ','_"'L:,";_" L{ -'. ~~"'. balance due and owing to plaintiff in the amount of Ten Thousand Six Hundred Sixty-nine Dollars and Forty-seven Cents ($10,669.47), plus interest in the amount of Nine Hundred Fifty Dollars. 5. Plaintiff has demanded payment of the said amount due under said Agreement but Defendant has refused and still refuse to pay the same or any part thereof. WHEREFORE, Plaintiff demands judgment against Defendant in the amount of Ten Thousand Six Hundred Sixty-nine Dollars and Forty- seven Cents ($10,669.47). , ESQUIRE Plaintiff 2 LAW OFFICES OF COLAVECCHI RYAN & COLAVECCHI 221 E. MARKET ST. (ACROSS FROM COURTHOUSE) P. O. BOX 131 CLEARFlELD, PA '1.;,,J..- - ;.~~." - '. -<.", -' ..;.""'.,- ,,,,,..,,. .._~." '- VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. CLAIMS RECOVERY SYSTEMS BY: 3 \~ll"""'-'" ~. ",I - ^~. t:.. SHERIFF'S RETURN - REGULAR CASE NO: 2001-00669 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CLAIMS RECOVERY SYSTEMS INC VS RIEGEL MICl( K CPL. MICHAEL BARRICK , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon REIGEL MICK K the DEFENDANT , at 0019:02 HOURS, on the 6th day of February 2001 at 120 WEST GREEN STREET MECHANICBSURG, PA 17055 by handing to MICK K. REIGEL a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 5.58 .00 10.00 .00 33.58 So Answers: ~~4f!, R. Thomas Kline 02/07/2001 JOSEPH COLAVECCHI Sworn and Subscribed to before By: me this /~ /B. day of J4,u.. ~I A.D. , ~ (2.n~n;.) '.!!f!7 othonotary , ~~i _~~ LAW OFFICES OF COLAVECCHI RYAN & COLAVECCHI 221 E. MARKET ST. (ACROSS FROM COURTHOUSE) P. O. BOX 131 CLEARFIELD, PA ........1' .. 1;- ~),' ~" ".~ ..~'c.,~';.,~i~':;;'- _',,,,",,,, ~' , ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CLAIMS RECOVERY SYSTEMS, INC., Assignee from CREDITONE, LLC, Assignee from DEBTONE, LLC, Assignee from HOUSEHOLD FINANCE CORPORATION, Plaintiff Vs. MICK K. RIEGEL, Defendant CIVIL DIVISION No. 01 - 669 - Civil Term PRAECIPE FOR JUDGMENT Filed on Behalf of: P1aint:iff, CLAIMS SYSTEMS, INC. RECOVERY Counsel of Record for This Party: JOSEPH COLAVECCHI, ESQUIRE Pa. I.D. #06810 COLAVECCHI RYAN & COLAVECCHI 221 East Market Street P.O. Box 131 C1earfie1d, PA 16830 814/765-1566 LAW OFFICES OF COLAVECCHI RYAN & COLAVECCHI 221 E. MARKET ST. (ACROSS FROM COURTHOUSE) P. O. BOX 131 CLEARFIELD, PA ',,' ,--,-, '-I' ~ ,,' ..;.c; ~ , ',' r ,"' "0""""," ~"'''?'''''.,.-', ,,~_, ,'"', , ~ ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CLAIMS RECOVERY SYSTEMS, INC., Assignee from CREDITONE, LLC, Assignee from DEBTONE, LLC, Assignee from HOUSEHOLD FINANCE CORPORATION, No. 01 - 669 - Civil Term Plaintiff vs. MICK K. RIEGEL, Defendant PRAECIPE FOR JUDGMENT TO: PROTHONOTARY OF CUMBERLAND COUNTY The Defendant, MICK K. RIEGEL, having been served on February 6, 2001, and no answer having been filed, a further ten (10) day notice was then served on MICK K. RIEGEL on February 28, 2001, being attached to this Praecipe. No answer still having been filed to the Complaint, please assess damages as follows: 1. Amount of Debt: $10,669.47 2. Interest from 2/1/01 to 3/13/01 : $ 71.75 3. Costs: $ 79.08 TOTAL AMOUNT OF JUDGMENT: JOSEP COLAVEC I, ESQUIRE Attorney for Plaintiff .- LAW OFFICES OF COlAVECCHI RYAN & COLAVECCHI 221 E. MARKET ST. (ACROSS FROM COURTHOUSE) P,O, BOX 131 CLEARFIELD, PA -. .. HO' ~ ,:"'~;0'",i,_:>,.,",,,;, ,~;, " " .. - AFFIDAVIT JOSEPH COLAVECCHI, ESQUIRE, being duly sworn according to law, deposes and states as follows: The last known address of judgment creditor is 6 ~ East Mall Plaza, Carnegie, Pennsylvania 15106. The last known address of judgment debtor is 120 West Green Street, Mechanicsburg, Pennsylvania 17055-1916. I hereby certify that according to Rule 237.1 et seq., notice to Defendant was given as indicated by a copy of Important Notice attached hereto and made a part hereof. JOSE <l~~ LAW OFFICES OF COLAVECCHI RYAN & COlAVECCHI 221 E. MARKET ST, (ACROSS FROM COURTHOUSE) p, O. BOX 131 CLEARFIELD, PA J., ., .~ L._. ~~ c IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CLAIMS RECOVERY SYSTEMS, INC., Assignee from CRED I TONE , LLC, Assignee from DEBTONE, LLC, Assignee from HOUSEHOLD FINANCE CORPORATION, Plaintiff Vs. MICK K. RIEGEL, Defendant TO: MICK K. RIEGEL l20 West Green Street Mechanicsburg, PA 17055 DATE OF NOTICE: February 28, 2001 No. 01 - 669 Civil Term IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN THIS CASE. UNLESS YOU ACT WITHIN TEN (10) 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 249-3l66 800/990-9108 16830