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Home My WebLink About99-01528 AMERICAN GENERAL CONSUMER DISCOUNT COMPANY Plaintiff VD. COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA WILLIAM L. BAILEY RONALD N. LIETZEL HELEN S. BAILEY : TRADING AND DOING BUSINESS AS: BAILEY'S DIAMOND CENTER Defendants NO. 9'1. /5-:;J' L~,,"I -,:.._ CIVIL ACTION - LAW COMPLAINT 1. Plaintiff is American General Consumer Discount Company, a corporation authorized to do business in Pennsylvania with an office at 6 S. Hanover Street, Carlisle, Cumberland County, PA. 2. William L. Bailey, a defendant, is an adult individual trading and doing business as Bailey's Diamond Center at 123 Carlisle Plaza Mall, Carlisle, Cumberland County, PA. 3. Ronald N. Lietzel, a defendant, is an adult individual trading and doing business as Bailey's Diamond Center at 123 Carlisle Plaza Mall, Cumberland County, PA. 4. Helen S. Bailey, a defendant, is an adult individual trading and doing business as Bailey's Diamond Center at 123 Carlisle Plaza Mall, Carlisle, Cumberland County, PA. S. On or about July 29, 1994, Plaintiff and Defendants entered a dealer operating agreement to finance purchases of goods at Defendants' store in accordance with the agreement attached hereto, marked "Exhibit A" and is made a part hereof. 6. On or about July 23, 1997, Defendants, through their agents and employees, sold jewelry to a person representing himself to be Ken S. Baum. 7. On or about July 23, 1997, Defendants, through their agents and employees, requested Plaintiff to finance said sales pursuant to their dealer operating agreement and forwarded an application to Plaintiff to do so. Said application is attached hereto, marked "Exhibit B" and is made a part hereof. 8. Plaintiff approved said application and Defendants, through their agents and employees, delivered the jewelry to the person representing himself to be Ken S. Baum and or about July 29, >. <~) [ ~- ..,' \.:, " lilt i:.." <, ' ~:'. C'-: . . <i'- r~ ) , , \I" ~..1 I lL . , . ~ ..' I ("' U ... '..> N '<') /' \ . ...) " -.::::t- ' -~ ~ ..) I ~ ~ \~ '" -.:t- ~ ;::r o --. I'{\ "-.-., rJ> .,. l" ~ ~ '" v -', ~.,. -, ./ ~,_) Z AMERICAN GENERAL CONSUMER DISCOUNT COMPANY Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Vd. qq~ /'.1J'6 NO. ~ WILLIAM L. BAILEY RONALD N. LIETZEL HELEN S. BAILEY TRADING AND DOING BUSINESS AS BAILEY'S DIAMOND CENTER CIVIL ACTION - LAW 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. TRUe c;;opY FROM RECOf:fD In TlIlllill'1Olly whereof, J here unto let my,.., and of sal C u at Carlisle. PI. T 0 arc 19 9~ , COURT ADMINISTRATOR 4 TH FLOOR CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717)240-6200 NOTICIA an demand ado a usted en la corte, Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted de be presentar una apariencia escrita 0 en persona 0 por abogado y archivar en la corte en forma escrita sus defensas 0 sus objeciones alas demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previa aviso 0 notificacion y por cualquier queja 0 alivio que es pedido en la AMERICAN GENERAL CONSUMER DISCOUNT COMPANY Plaintiff vs. COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA WILLIAM L. BAILEY RONALD N. LIETZEL HELEN S. BAILEY CIVIL ACTION _ LAW TRADING AND DOING BUSINESS AS: BAILEY'S DIAMOND CENTER Defendants NO. COMPLAINT 1. Plaintiff is American General Consumer Discount Company, a corporation authorized to do business in Pennsylvania with an office at 6 S. Hanover Street, Carlisle, Cumberland County, PA, 2. William L. Bailey, a defendant, is an adult individual trading and doing business as Bailey's Diamond Center at 123 Carlisle Plaza Mall, Carlisle, Cumberland County, PA. 3. Ronald N. Lietzel, a defendant, is an adult individual trading and doing business as Bailey's Diamond Center at 123 Carlisle Plaza Mall, Cumberland County, PA. 4. Helen S. Bailey, a defendant, is an adult individual trading and doing business as Bailey's Diamond Center at 123 Carlisle Plaza Mall, Carlisle, Cumberland County, PA. S. On or about July 29, 1994, Plaintiff and Defendants entered a dealer operating agreement to finance purchases of goods at Defendants' store in accordance with the agreement attached hereto, marked "Exhibit A" and is made a part hereof. 6. On or about July 23, 1997, Defendants, through their agents and employees, sold jewelry to a person representing himself to be Ken S. Baum. 7. On or about July 23, 1997, Defendants, through their agents and employees, requested Plaintiff to finance said sales pursuant to their dealer operating agreement and forwarded an application to Plaintiff to do so. Said application is attached hereto, marked "Exhibit B" and is made a part hereof. 8. Plaintiff approved said application and Defendants, through their agents and employees, delivered the jewelry to the person representing himself to be Ken S. Baum and or about July 29,