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Home My WebLink About01-04090IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SOURCEONE CORPORATION, Plaintiff NO: ~ I ~/C)9 v. GLENDA M. NATCHER, CIVIL ACTION -LAW 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 ANY 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, Pennsylvania 17013 Tel. No. (717) 249-3166 (800) 990-9108 ~~ :, . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SOURCEONE CORPORATION, Plaintiff NO: v. GLENDA M. NATCHER, CIVIL ACTION -LAW Defendant AVISO LISTED HA SIDO DEMANDADO EN LA CORTE. Si usted desea defenderse de las quejas expuestas en las paginas siguientes, debe toma action dentro de veinte (20) dial a partir de la fecha en que recibio la demanda y el auiso. Usted debe presentar comparecencia escrita en persona o por abogado y presentar en lat Corte por escrito sus defensas o sus objeciones a las demandas en su contra. Se le avisa que si no se defienda, el caso puede proceder sin usted y la Corte puede decidir en su contra sin mas auiso o notification por cualquier otra queja o compensation reclamados por el Demandante. USTED PUEDE PERDER DINERO, O PROPIEDADES U OTROS DERECHOS IMPORTANTES PARR LISTED. LLEVE ESTA DEMANDA A UN ABOGADO 1NMEDIATAMENTE. SI LISTED NO TIENE O NO CONOCES UN ABOGADO, VAYA O LLAME A LA OFICINA EN LA DIRECCION ESCRITA ABAJO PARA AVERIGUAR DONDE PUEDE OBTENER ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Tel. No. (717) 249-3166 (800) 990-9108 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SOURCE ONE CORPORATION, Plaintiff NO: Dl- `fCJ94 C.tt~c.f ~-tu+~ v. GLENDA M. NATCHER, individual Defendant CIVIL ACTION -LAW COMPLAINT AND NOW, this day of June, 2001, comes the Plaintiff by its attorney, N. Christopher Menges, and files the following Complaint: 1. The Plaintiff is, SourceOne Corporation, an Oklahoma corporation, in the state of Oklahoma, that is authorized to do business in the state of Pennsylvania. 2. The Defendant is Glenda M. Natcher, individual, whose principal address is 31 Fairfield Street, Newville, Pennsylvania 17241. 3. The Defendant, did make Discover charges through Discover/Greenwood Trust Company, which totaled the sum of $2,736.55. 4. Pursuant to a Lost Application Affidavit, a copy of which is attached hereto, marked Exhibit "A" and incorporated herein by reference Defendant's original signed application can not be located. ,~; , 5. Pursuant to an account printout, a copy of which is attached hereto, marked Exhibit "B" and incorporated herein by reference, the Defendant ceased making payments on her account. The last payment received was July 21, 1998. 6. Pursuant to Bill of Sale, a copy of which is attached hereto, marked Exhibit "C" and incorporated herein by reference, the Plaintiff, SourceOne did purchase Defendant's account from Discover/Greenwood Trust Company on January 20, 1999. The Defendant accepted the services of the Plaintiff as being acceptable and in the ordinary course of business with an express or implied promise to pay therefor. 8. The Plaintiff maintained books of account, keeping an accurate running account of all debits and credits for the services provided to the Defendant. 9. The Defendant owes the Plaintiff the amount of $2,736.55 plus interest at the rate of 18% per annum ($1,227.74 as of 05/25/2001) on the past due balance on said account as shown by statement of account, a copy of which is attached hereto, marked Exhibit "D" and incorporated herein by reference. 10. Demand for payment on this account has been made on 10/6/2000,10/31/2000 and 06/13/2001. In spite of these demands, the Defendant has refused to pay said balance of $2,736.55 plus interest at 18 percent per annum. WHEREFORE, Plaintiff demands judgment against the Defendant in the sum of $2,736.55 plus interest of $1,227.74 as of 5/25/2001 (for a total of $3,964.29), plus interest continuing at 18 until payment in full has been made, plus costs of suit. Pursuant to Pennsylvania Rule of Civil Procedure 1021(c) in counties having rules governing compulsory arbitration the amount claimed does not exceed the jurisdictional amount requiring arbitration referral by local rule of the county which this was filed. MENGES, GENT & McLAUGHLIN By: N. ristop r e ges Attorney for PI tiff Attorney I.D. # 3166 145 East Market Street York, PA 17401 Telephone (717) 843-8046 EXHIBIT "A" ,~ LOST APPLICATION AFFIDAVIT After being duly sworn, as Attorney-in-Fact for SourceOne Corporation, I hereby affnm that after a diligent seazch, the signed application for credit, in reference to the account of Glenda M. Natcher, Discover Financial Services, Inc., SourceOne Corporation Account number 6011002750578189 has been lost. I further affum that the terms of the agreement attached hereto is in fact the terms of this account. Affiant further sayeth naught: COUNTY OF MECKLENBURG STATE OF NORTH CAROLINA SS.: BEFORE ME, Sherri Williams, a Notary Public in and for said County and State, on this 30th day of September, 2000, personally appeared S. J. Kefer, who is the Attorney-in-Fact of SourceOne Corporation and the person who executed the foregoing instrument, by virtue of the authority delegated to him in the attached Limited Power of Attorney, and I having fnst made lmown to him the contents thereof, he/she did aclmowledge the signing thereof to be his free and voluntary act and deed, for and on behalf of SourceOne Corporation. Witness my hand and official seal this day of 2000. III W NOTARY PUBLIC $lferr' , ~i'i~i My Commission Expires: OV. J EXHIBIT "B" CLNT: 811 DISCOVER-SOURCE ONE - 811 SOURCE ONE NAME: HATCHER, GLENDp M FH# PPL# ASGM: 11-01-99 LS'T CHG: LST PY: 87-21-98 PRT# pDDR: 31 FAIRFIELD ST NEWVILLE Pp 17241 EMPL: COUNTRY MEADOWS 717-975-3434 (1) LAST ACTION DT {fn) 89-18-08 --OWING-- -RECEIUED- (2) COLLECTOR ACTION {?) FWD AGN/AMT 2,736.55 0.00 (3) TIME TO WORX INT 835.36 0.00 (4) DATE WORN AGAIN 11-B2-BB CANCELLED 0.00 (5) PROMISED FMT AMT 0.80 ATTORNEY 8.00 B.BB (6) NEXT STEP TEL COURT 0.00 8.00 (7) FOLLOWUP PRIG C1-10) MISC 0.00 B.BO ($l PROMISED PMT DATE TOTALS-~ 3,571.91 0.00 (9l IMP NOTE LINES STATU.$ FWD NET W/JMT~ 3.571.91 COLLECTOR 783 DRUM: 213594-783 TOP OF NOTES DRL: SSN: 199347918 DOB: CDN: 6011002750578189 MISSING DATA 30 SEF~09:48AM~ET=00:06 EXHIBIT "C" BILL OF SALE Each of Greenwood Trust Company ("GTC" or a "Seller") and SCFC Receivables Corp. ("SRC" or a "Seller"), for value received, and pursuant to the terms and conditions of the Credit Card Accounts Sale Agreement with an Effective Date of May 15, 1998 among GTC, SRC and SourceOne Corporation ("Buyer"), transfers, sells, assigns, conveys, grants and delivers to Buyer, its successors and assigns all the Seller's right, title and interest in and to (il the Seller's unsecured consumer credit card accounts, which are described on computer files furnished by the Seller to the Buyer in connection herewith, and (ii) all proceeds of such accounts (each, an "Account") after the close of business on January 20, 1999. This BiII of Sale is executed without recourse and without representation of or -warranty of title, collectability, or otherwise, express or implied, except as set forth in the Agreement. Executed as of the 25"' day of January, 1999. GREENWOOD TRUST COMPANY By: Name: ~J . N~ ~'~L Title: ~~ SCFC RECEIVABLES CORP. By: ~~ Name: ,Q.cfitR~ ~1.Yrst Title: -/its pegrjrf~l,L7 25 EXHIBIT "D" ~~^ - STATEMENT UCM Servicin6 LLC Inc. ACCT NO. _ FORMERLX b9 DATE: 6~Q0.,_~ISCOVER/SOURCE ONE - ., A0275057$Y89 . UCMS ACCOUNT NEW CURRENT PAST DUE AMOUNT TOTAL AMOUNT PAYMENT DUE NUMBER BALANCE MINIMUM DUE DATE 213594 $3,571.91 $3,571.91 $3,571.91 $3,571.91 10/25/00 IRAN DATE DESCRIPTION AMOUNT 9/30/06 Principal Balance $2,736,55.... Unpaid Accrued Interest $835.3Cy- Balance $3,571.91 Ifyou have any questions concerning your accoant, call 1-888-743-8262 Exf. 1069 ACCOUNT SUMMARY STATEMENT DATE 09/30/00 PREVIOUS BALANCE $3,531.42 - PAYMENTS - CREDITS +DEBITS +FINANCE CHARGE $40.49 =NEW BALANCE $3,571.91__ ANNUAL PERCENTAGE RATE 18,00% Please return bottom portion of this statement with your payment. Write your UCMS account number on your check or money order. DO NOT SEND CASH. Make check payable to UCMS P.O. BOx 471827 Ifyou wish to pay your account using MasterCard or VISA, please call Charlotte, NC 28247-1827 1-888-743-8262 Ext. 1069 Return Service Requested CLOSING PAYMENT NEW CURRENT PAST DUE TOTAL ACCOUNT PLEASE ENTER TOTAL DATE DUE DATE BALANCE MINIMiIM AMOUNT DUE NUMBER AMOUNT ENCLOSED 09/30/00 10/25/00 $3,571.91 $3,571.91 $3,571.91 $3,571.91 213594 .. ,:. ~ I Mail payments to etd~.t ..~` .. e,kA 1724.1 , _" ucMs P.O. BOX 471827 QIARLOTTE, NC 28247-1827 VERIFICATION I, S. J. Kefer ~ Agent of, Source One the within-named Plaintiff, verify that the statements made in this Complaint aze true and cored to the best of n-~y lrnowledge, information and belief. T understand that false statements herein are made subject to the penalties of 18 Pa. Sec. 4904 relating to unsworn falsification to - authorities. BY: ource - SHERIFF'S RETURN - REGULAR CASE NO: 2001-04090 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SOURCEONE CORPORATION VS NATCHER GLENDA M RICHARD SMITH Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon NATCHER GLENDA M DEFENDANT the at 1625:00 HOURS, on the 1st day of August 2001 at 31 FAIRFIELD ST NEWVILLE, PA 17241 GLENDA NATCHER by handing to 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 18.00 Service 15.60 Affidavit .00 Surcharge 10.00 .00 43.60 So AnswQer~s R. Thomas Kline 08/02/20ni MENGES G Sworn and Subscribed to before By: me this 4 ~ day of i ~ a2 ~// ^~,, A . D . n P o honotary ' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SOURCEONE CORPORATION, Plaintiff NO: 2001-04090 vs. GLENDA M. NATCHER, Defendant CIVIL ACTION -LAW TO THE PROTHONOTARY..... ENTER NDGMENT in the above case for failure to file an Answer to the Complaint served on August 1, 2001 against Glenda M. Natcher, in favor of Source One Corporation, in the amount of $2,736.55 plus interest of $1,350.89 through 8/25/01, for a total of $4,087.44 with interest continuing from $/25/01 at the rate of 18% per annum, plus costs of suit. G.e~-~o~ cPr~-cJ~~ 'S "k~' The Notice pursuant to Pennsylvania Rule of Civil Procedure 237.1 was sent to the Defendant on September , 2001 and a copy of same is attached hereto. N. Christopher Meng Attorney for Plaintif I.D. #23166 145 East Market Street York, PA 17401 Telephone: 717-843-8046 Date: Judgment entered by the Prothonotary this lay of September, 2001 according to the tenor of the above statement. Prothonotary ,,. Y IN THE COURT OF COMMON PLEAS OF CUMBERLAND COU~Y, PENNSYLVANIA //~~ ~~ SOURCEONE CORPORATION, v. Plaintiff GLENDA M. NATCHER, T0: Glenda M. Natcher 31 Fairfield Street Newville, PA 17241 Defendant Date of Notice: August 2~, 2001 NO: 2001-04090 CIVIL ACTION -LAW IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN 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. )F 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. Lawyer Referral Service York County Bar Association 137 East Market Street York, PA 17401 Telephone (717) 854-8755 N. Christopl-'efNTe g s, Esquire MENGES, GENT & CLAUGHLIN, LLP Sup. Crt. I.D. No. 166 145 East Market Street York, PA 17401 Telephone: 1-717-843-8046 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SOURCEONE CORPORATION, Plaintiff, NO: 2001-04090 v. NOTICE OF FILING GLENDA M. NATCHER JUDGMENT Defendant. (~() Notice is hereby given that a Money Judgement in the above referenced matter has been entered against you in the amount of $3,557.07 plus interest on September _`~, 2001. ( ) A copy of all documents filed with the Court of Common Pleas, Cumberland County, Pennsylvania and original Judgment aze enclosed. Prothonotary Civil Div. Y: C~~~-c/ If you have any questions regarding this Notice, please contact the filing party N. Christopher Menges, Esquire 145 East Market Street York, PA 17401 (717)843-8046 (This Notice is given in accordance with Pa.R.C.P. 2236.) Notice sent to: Glenda M. Natcher 31 Fairfield Street Newville, PA 17241 York, PA 17402 IN TAE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA SOURCEONE CORPORATION, Plaintiff v. GLENDA M. NATCHER, CIVIL ACTION -LAW NO: Defendant uTA`TE OF North Carolina ( SS. COUNTY OF Mecklenburg Before me, a Notary Public, personally appeared Ss Kefer Plaintiff for Source One Corporation, imthe above captioned action, who being duly sworn according to law deposed and says that the Defendant above named is not in the military service of the United States of America, that the Plaintiff has personal lrnowledge that the said Defendant whose principle address is 31 Fairfield Street, Newville, Pennsylvania, 17241, Cumberland County and is a resident of Pennsylvania and is employed at or by N/A Sworn and subscribed to before me this t 6th day of ,7u1v ,2001 S E CORPORATION .~-o ~ z- Notary Public ~~ ~~ ~ ;~ 1 \, c~ C S ~ C'.'1 nri; ~~ r; '` `= C: =" ~, ~' c -''c C .n f ~1 cM; ~: en L3 ,_~ ~t c .y ;-n