HomeMy WebLinkAbout03-4092IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
ASSET ACQUISITION GROUP, LLC, ASSIGNEE OF
FIRST USA
vs. COMPLAINT IN CIVIL ACTION
JOEL E. STONER
Defendant
FILED ON BEHALF OF
Plaintiff
COUNSEL OF RECORD OF
THIS PARTY:
WILLIAM T. MOLCZAN, ESQUIRE
PA I.D.#47437
Weltman, Weinberg & Reis Co., L.P.A.
2718 Koppers Bldg.
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WVVR#02979603
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
ASSET ACQUISITION GROUP, LLC, ASSIGNEE OF
FIRST USA
Plaintiff
VS.
JOEL E. STONER
Defendant
Civil Action No.
COMPLAINT IN CIVIL ACTION AND NOTICE TO DEFEND
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 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
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
ASSET ACQUISITION GROUP, LLC, ASSIGNEE OF
FIRST USA
Plaintiff
VS.
JOEL E. STONER
Defendant
Civil Action
COMPLAINT
AND NOW COMES, Plaintiff, by and through its counsel, WELTMAN, WEINBERG &
REIS, CO., LPA., and hereby files this Complaint against Defendant, Joel E. Stoner, and, in
support thereof, Plaintiff avers as follows:
1. The Plaintiff is a corporation with its principal place of business located at P.O.
Box 340740, Denver, CO 80237.
2. Plaintiff is the owner of this account, which is the subject matter of this action.
3. Defendant is an adult individual residing at 331 S. Enola Street, Enola, PA 17025.
4. Defendant requested the account and made use of said account and has currently
a balance due and owing to Plaintiff, as of September 8, 1999, in the amount of $6,788.90.
5. Plaintiff claims interest at the legal rate of six (6%) percent per annum from
September 8, 1999.
6. Plaintiff avers that interest calculated at the aforesaid rate from September 8, 1999
to July 17, 2003 amounts to $1,513.27.
7. Plaintiff avers that payments totaling $400.00 thereby reducing Defendant's
balance to $7,902.17.
8. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed
and/or refused to pay the balance.
WHEREFORE, Plaintiff demands Judgment in its favor and against Defendant, Joel E.
Stoner, individually, in the amount of $7,902.17 with finance charges thereon at the rate of 6%
per annum from July 17, 2003, plus costs.
THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED SHALL
BE USED FOR THAT PURPOSE.
WELTMAN, WEINBERG & REIS, CO., L.P.A.
WILr_IAM T. IVlOLCZAN, ESQI~rRE
PA I.D.#47437
Weltman, Weinberg & Reis Co., L.P.A.
2718 Koppers Bldg.
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR#: 02979603
VERIFICATION
The undersigned does hereby verify subject to the penalties of 18 PA.C.S. §4904
relating
to unsworn falsifications to authorities, that he/she is ~(~.~_.~ ~ ~'~,'~ ~O~
(Name)
('"~L~r~/.~\ ~l'~;h ~ ~ of 7~.'~-'~i: ~r..~ll~ ~-~q ~,~':* ,t% ~L1.-~, plaintiff herein, that
(Title)' (Company)
he/she is duly authorized to make this Verification, and that the facts set forth in the foregoing
Complaint are true and correct to the best of his/her knowledge, information and belief.
(Signature)
Ww~ 02979603
SHERIFF'S RETURN
CASE NO: 2003-04092 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
ASSET ACQUISITION GROUP LLC
VS
STONER JOEL E
- REGULAR
CPL. KATHY CLARKE , Sheriff or Deputy Sheriff of
Cumberland County, Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE
STONER JOEL E
DEFENDANT , at 1600:00 HOURS, on the
was served upon
the
8th day of September, __
2003
at CUMBERLAND CO SHERIFF'S OFFICE ONE COURTHOUSE
CARLISLE, PA 17013
JOEL STONER
a true and attested copy of COMPLAINT & NOTICE
SQUARE
by handing to
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing 18.00
Service 10.35
Affidavit .00
Surcharge 10.00
.00
38.35
Sworn and Subscribed to before
me this /?~ day of
~/~ J~, ~m73._% A.D.
So Answers:
R. Thomas Kline
09/09/2003
WELTMAN WEINBERG REIS
By:
y Sheriff
SHERIFF'S RETURN -
CASE NO: 2003-04093 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
BANK OF AMERICA N A
VS
PINTO JOHN D
REGULAR
CPL. MICHAEL BARRICK
Cumberland County, Pennsylvania,
Sheriff or Deputy Sheriff of
who being duly sworn according to law,
was served upon
the
4th day of September,
by handing to
together with
says, the within COMPLAINT & NOTICE
PINTO JOHN D
DEFENDA/qT , at 1502:00 HOURS, on the
at 1416 SIMPSON FERRY ROAD
NEW CUMBERLAND, PA 17070
JOHN D. PINTO
a true and attested copy of COMPLAINT & NOTICE
2003
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing 18.00
Service 11.73
Affidavit .00
Surcharge 10.00
.00
39.73
Sworn and Subscribed to before
me this /~ day of
_~~ _2~_~ A.D.
· 'Prothonotary
So Answers:
Thomas Kline
09/05/2003
BURTON NEIL & ASSOC j
IN THE COURT OF COMMON PLEAS OF CUMBERLAND, COUNTY, PENNSYLVANIA
CWIL DWISION
ASSET ADVANTAGE GROUP, LLC, ASSIGNEE OF
FIRST USA
Plaintiff
VS.
JOEL E. STONER
Defendant
No. 03-4092 CW1L TERM
PRAECIPE TO SETTLE, DISCONTINUE
& END
FILED ON BEHALF OF
Plaintiff
COUNSEL OF RECORD OF
THIS PARTY:
William T. Molczan, Esquire
PA. I.D.#47437
WELTMAN, WEINBERG & REIS CO., L.P.A.
2718 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR#02979603
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
ASSET ADVANTAGE GROUP, LLC, ASSIGNEE OF
FIRST USA
Plaintiff
VS.
JOEL E. STONER
Defendant
Civil Action No. 034092 CIVIL TERM
PRAECIPE TO SETTLE DISCONTINUE AND END
TO THE PROTHONOTARY OF COUNTY:
Please kindly Settle Discontinue and End the above captioned matter upon the records of the Court an
mark the cost paid.
Sworn to and sub[~/oed
Before me the "~
OAR...,ptOber, 2003
WELTMAN, WEINBERG & REIS CO., L.P.A.
PA. I.D.#47437
WELTMAN, WEINBERG & REIS CO., L.P.A.
2718 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWRg02979603