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Home My WebLink About07-2363IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CITIFINANCIAL INCORPORATED, I CIVIL DIVISION a corporation I I I Plaintiff(s), I 1 No. 2007- a.~3 ~~~~ ~~ v. I PATRICIA A KELLEY, I an individual I I I Defendant(s), I I 1 COMPLAINT 1 i I Code No. I I Filed on Behalf of: I 1 PLAINTIFF I I I ( ATTORNEY OF RECORD FOR THIS PARTY i I Louis B. Swartz I I PA. ID # 00242 I I 1SWARTZ, LOVEJOY & ASSOCIATES 116th FLOOR LAW AND FINANCE BUILDING 1PITTSBURGH, PENNSYLVANIA 15219 ( I 1(412} 288-0300 @76909 NOTE: THIS IS AN ATTEMPT TO COLLECT A DEBT AND RNY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE <76909 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CITIFINANCIAL INCORPORATED, a corporation Plaintiff (s) , v. PATRICIA A KELLEY, an individual No. 2007- Defendant (s) , NOTICE TO DEFEND AND CLAIM RIGHTS 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 AN ATTORNEY AND FII.ING 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 CLAi1VIED IN THE COMPLAIlV'T OR FOR ANY OTHER CLAIM OR RELIEF REQUESTED BY THE PLAINTIFF. YOU MAY LOSE MONEY OR PROPERTY OR OTHER RIGHTS IlVIPORTANT 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 THE TELEPHONE OR THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 1-800-990-9108 717-249-3166 @76909 r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CITIFINANCIAL INCORPORATED, a corporation v. Plaintiff(s), No. 2007- 233 l..~v~~ `~"' " l PATRICIA A KELLEY, an individual Defendant(s), C01`SPLAINT 1. Plaintiff(s) is CITIFINANCIAL INCORPORATED, a corporation. Plaintiff's address is ATTN: PAYMENT PROCESSING, FORT MILL, SC 29715. 2. Defendant(s) is PATRICIA A KELLEY, an individual. Defendant's address is 7 PINE RD, MOUNT HOLLY S PA 170650000. 3. Plaintiff, at Defendant's special instance and request, opened for the Defendant a credit account which Defendant thereafter used and there is a balance due and unpaid, despite demand, in the amount of $8,122.00 plus interest from November 14, 2005. WHEREFORE, Plaintiff demands Judgment agains efendant(s) in the amount of $8,122.00 Plus legal interest and costs. LVU1.~i ts. Ewa tz Attorney for PLAINTIFF SWARTZ, LOVEJOY & ASSOCIATES 16th FLOOR LAW AND FINANCE BUILDING PITTSBURGH, PENNSYLVANIA 15219 (412) 288-0300 ~ , @76909 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLV~IA CITIFIN CIVIL DIVISION a corpo~tiOn INCORpO~TED, I i I Plaintiff(s~~ ~ ~'• I No. 2007- I PATRICIA I ~((~ ~t._~ an indivi ualLLEY, I I I I Defendant I !s), I ~RIFICATION The undersigned, that he/she is the _~ ~ avers is authorized t0 ~ °f Plaintiff, make this ~rerification Plaintiff °n behalf of the statements of fact contained in the attached Complaint are true and correct to the informatio best of his/her n- knowled ge and belief o the penalties and are made subject of 18 Pa. Cons. Stat. relating to Ann. Sect' unsworn falsification to ion 4904 authorities. ~OM. pLg Da t e ~ `.: 1 ~~ w d ~ ~~ w ~ ~ L.) ~` ...J 'Cj t;C+ "~C3 f7"t ('t' 2.. f.~' ~ `~C '~ ~~: ~: qty ~_~-; l~ .~ ~w d "t7 fx'{ ~~~ ~~ ~, w IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CITIFINANCIAL INCORPORATED, I CIVIL DIVISION a corporation I I I Plaintiff(s), I I No. 2007-02363 . v. I I PATRICIA A KELLEY, an individual I I I Defendant(s), I I I PRAECIPE FOR DEFAULT JUDGMENT I I I Code No. I I Filed on Behalf of: I I PLAINTIFF I I I I ATTORNEY OF RECORD FOR THIS PARTY I I Louis B. Swartz I I PA. ID # 00242 I I ISWARTZ, LOVEJOY & ASSOCIATES 116th FLOOR LAW AND FINANCE BUILDING (PITTSBURGH, PENNSYLVANIA 15219 I I ((412) 288-0300 $76909 NOTE: THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE s ~' ~. 876909 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CITIFINANCIAL INCORPORATED, a corporation Plaintiff(s), No. 2007-02363 v. PATRICIA A KELLEY, an individual Defendant(s), PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Enter judgment against Defendant(s) and in favor of Plaintiff in Default of an Answer or a Notice of Intention to Appear as follows: AMOUNT CLAIMED IN COMPLAINT $ 8,122.00 PLUS INTEREST FROM 11-14-2005 TO: 06-18-2007 $ 775.71 TOTAL $ 8,897.71 I certify that I mailed a notice of default to the defendant(s) in the form attached hereto on the date stated thereon which was more that ten (10) days befo~~/tE'iling this praecipe. Louis B. Swar Attorney for TIFF SWARTZ, LOVE) & ASSOCIATES 16th FLOOR LAW AND FINANCE BUILDING PITTSBURGH, PENNSYLVANIA 15219 (412) 288-0300 ;76909 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CITIFINANCIAL INCORPORATED, a corporation Plaintiff(s), v. PATRICIA A KELLEY, an individual Defendant(s), No. 2007-02363 DEFAULT NOTICE TO THE DEFENDANT: PATRICIA A KELLEY, an individual 7 PINE RD MOUNT HOLLY S PA 170650000 IMPORTANT NOTICE UMYOU 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 (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 PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.~P IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. PENNSYLVANIA LAWYER REFERRAL SERVICE 100 SOUTH STREET, P.O. BOX 186 HARRISBURG, PA 17108 Date ,~~~~,~ 1-800-692-7375 ~OU1S ~. 51Na~ Louis B. Swartz Attorney for PLAINTIFF SWARTZ, LOVEJOY & ASSOCIATES 16th FLOOR LAW AND FINANCE BUILDING PITTSBURGH, PENNSYLVANIA 15219 (412) 286-0300 NOTE: THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE defnote/defnotex ~~'' ~~ V ~ a-~- W _ r 3 ~° C -iit1,,, ~.., \-~' 4~; ~. ~, ~:, . y,, -= r v --. CX+ ~s i _...; ~-- -rt _ ~fCvry °~ t {~.? ~. .a, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CITIFINANCIAL INCORPORATED, ~ CIVIL DIVISION a corporation ~ I I Plaintiff(s), ~ ~ No. 2007-02363 v. ~ I PATRICIA A KELLEY, ~ an individual ~ I I Defendant(s), ~ I ~ AFFIDAVIT OF NON-MILITARY ~ SERVICE ~ Code No. I ~ Filed on Behalf of: I ~ PLAINTIFF I I I ~ ATTORNEY OF RECORD FOR THIS PARTY I ~ Louis B. Swartz I ~ PA. ID # 00242 ~SWARTZ, LOVEJOY & ASSOCIATES 16th FLOOR LAW AND FINANCE BUILDING PITTSBURGH, PENNSYLVANIA 15219 x(412) 288-0300 $76909 NOTE: THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE i ~` 876909 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CITIFINANCIAL INCORPORATED, a corporation Plaintiff(s), No. 2007-02363 v. PATRICIA A KELLEY, an individual Defendant(s), AFFIDAVIT OF NON-MILITARY SERVICE I, LOUIS B. SWARTZ, do depose and say that the above-named defendant(s) Patricia A. Kelley are not currently in the naval or military services of the United States, either directly or indirectly. These statements are made subject to the penalties of 18 Pa. Cons. Stat. Ann. Section 4904 relating to unsworn falsification to authorities. C? ~-~~ ~i C~ -~ .--+ ~ ' ~ ~ . <<. .~-, s , ',c~: .-_ -~:~ -- , ;. .~ `~' } ° -° - SHERIFF'S RETURN - REGULAR CASE N0: 2007- 2363 P COMMONWEALTH O PENNSYLVANIA: COUNTY OF CUMB RLAND CITIFINANCIAL INCORPORATED S KELLEY PATRICI~ A JESSICA HERMAN EN Sheriff or Deputy Sheriff of Cumberland Cou ty,Pennsylvania, who being duly sworn according to law, says, the with'n COMPLAINT & NOTICE was served upon KELLEY PATRICI A the DEFENDANT at 1203:00 HOURS, on the 2nd day of May 2007 at 11 BENTLEY LACE CARLISLE, PA 117013 PATRICIA 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 Cos s: Docketing 18.00 Service 10.5& Affidavit .00 Surcharge 10.00 .00 ~/~,~r~D ~., / 3 8 . 5 6 Sworn and Sub Gibed to before me thi day of , So Answers: R. Thomas Kline 05/03/2007 LOUIS SWARTZ By. Dep Sheriff A.D.