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Home My WebLink About07-3206 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CITIFINANCIAL I CIVIL DIVISION I I I Plaintiff(s), I I No. 2007- v. I I TOWER S. SWARTZ, I an individual I I I Defendant(s), 1 I I COMPLAINT I I I Code No. ('~7 .. 3~~ l~~ ~ 1 I Filed on Behalf of: I PLAINTIFF I I I I ATTORNEY OF RECORD FOR THIS PARTY I I Louis B. Swartz I I PA. ID # 00242 I I (SWARTZ, LOVEJOY & ASSOCIATES 116th FLOOR LAW AND FINANCE BUILDING (PITTSBURGH, PENNSYLVANIA 15219 I I I (412) 288-0300 <76863 NOTE: THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE 1 '~ <76863 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CITIFINANCIAL Plaintiff (s) , v. TOWER S. SWARTZ, an individual Defendant(s), No. 2007- 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 days (20) 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 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. 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. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 1-800-990-9108 717-249-3166 NOTDEFCU.PLE J <76863 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CITIFINANCIAL Plaintiff(s), No . 2 0 0 7 - 9 .~ OG ~:/ ~z-w-~ v. TOWER S. SWARTZ, an individual Defendant(s), COMPLAINT 1. Plaintiff(s) is CITIFINANCIAL. Plaintiff's address is ATTN: PAYMENT PROCESSING, FORT MILL, SC 29715. 2. Defendant(s) is TOWER S. SWARTZ, an individual. Defendant's address is 30 BIG SPRING AVE, NEWVILLE PA 17241. 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 $7,472.99 plus interest from July O1, 2003. WHEREFORE, Plaintiff demands Judgment against of dant(s) in the amount of $7,472.99 Plus legal interest and costs. Louis B. Swart Attorney for PL INTIFF SWARTZ, LOVEJOY & ASSOCIATES 16th FLOOR LAW AND FINANCE BUILDING PITTSBURGH, PENNSYLVANIA 15219 (412) 288-0300 ~' @76663 Plaintiff(s), IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CITIFINANCIAL v. TOWER S. SWARTZ, an individual No. 2007- Defendant(s), VERIFCOM.PLE VERIFICATION The undersigned, ~~~ ~~~ , avers that he/she is the -~ of Plaintiff, is authorized to make this verification on behalf of Plaintiff, the statements of fact contained in the attached Complaint are true and correct to the best of his/her information, knowledge. and belief, and are made subject to the penalties of 18 Pa. Cons. Stat. Ann. Section 4904 relating to unsworn falsification to authorities. Date 0 ~l fJ w `~4. d ~.J "~ ~. E y~=., -< ~:." t: _' ~. '^c rv ~°- N "L7 C'1 -tiJ ;. ~~ ~, ~~ -'G SHERIFF'S RETURN - REGULAR CASE N0: 2007-03206 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITIFINANCIAL vs SWARTZ TOWER S ROBERT BITNER Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon SWARTZ TOWER S the DEFENDANT at 2100:00 HOURS, on the 31st day of May 2007 at CUMBERLAND COUNTY PRISON CARLISLE, PA 17013 TOWER SWARTZ 1101 CLAREMONT ROAD by handing to 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 ~~~b')~ ~ 18.00 16.32 .00 10.00 .00 44.32 Sworn and Subscibed to before me this day So Answers: R. Thomas Kline 06/01/2007 SWARTZ LOVEJOY & ASSOCIATES By r Deputy Sheriff of A.D. w IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CITIFINANCIAL ~ CIVIL DIVISION I I Plaintiff(s), ~ ~ No. 2007-03206 v. ~ I TOWER S. SWARTZ, ~ an individual ~ I Defendant(s), ~ I ~ PRAECIPE FOR DEFAULT JUDGMENT I I ~ Code No. i ~ Filed on Behalf of: 1 ~ PLAINTIFF I i ~ ATTORNEY OF RECORD FOR THIS PARTY I ~ Louis B. Swartz I ~ PA. ID ## 00242 I I ~SWARTZ, LOVEJOY & ASSOCIATES 16th FLOOR LAW AND FINANCE BUILDING PITTSBURGH, PENNSYLVANIA 15219 I x(412} 288-0300 $76863 NOTE: THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE 876863 h IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CITIFINANCIAL Plaintiff(s), v. TOWER S. SWARTZ, an individual Defendant(s), No. 2007-03206 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 $ 7,472.99 PLUS INTEREST FROM 07-01-2003 T0: 07-30-2007 $ 1,830.37 TOTAL $ 9,303.36 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 bef filing this praecipe. Louis S. Swar Attorney for ~AINTIFF SWARTZ, LOVEJOY & ASSOCIATES 16th FLOOR LAW AND FINANCE BUILDING PITTSBURGH, PENNSYLVANIA 15219 (412) 288-0300 cs ~ ~ o ~ ~. ~ "" `J',~' f ~s3 s~ Q .~.,, w ~~ -Q a ~ w b .r ~~- .~, ,_ =:~ ~ ~ ~ "'i i ,;~ -r _ ~ c~ ~ t ;76663 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CITIFINANCIAL v. TOWER S. SWARTZ, an individual Plaintiff (s) , Defendant(s), No. 2007-03206 DEFAULT NOTICE TO THE DEFENDANT: TOWER S. SWARTZ, an individual 30 BIG SPRING AVE NEWVILLE, PA 17241 IMPORTANT NOTICE OMYOU 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.OP 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 ,L~ O~ 1-800-692-7375 ~~L~DI,IIS ~. ~V1/8~Z Date Louis B. Swartz Attorney for PLAINTIFF SWARTZ, LOVEJOY & ASSOCIATES 16th FLOOR LAW AND FINANCE BUILDING PITTSBURGH, PENNSYLVANIA 15219 (412) 288-0300 NOTE: THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE defnote/defnotex ra q "T3 L:L'~ ~-- ~ tom"' ~~3 _ ~' 1.. V~.:~: fiJ ~~' A ~-~'' :::. L~ ~