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HomeMy WebLinkAbout07-4168 AMERICHOICE FEDERAL CREDIT : IN THE COURT OF COMMON PLEAS OF UNION, :CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF v, :2007- ~ I lv$ CIVIL TERM MICHAEL J. DOEBLEY, 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 prompt action. You are warned that if you fail to do so, the case may proceed without you and a Judgment maybe entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers 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. Court Administrator Cumberland County Court House 1 Courthouse Square Caxlisle, PA 17013 (717) 240-6200 ~._.._ JOH~rtf J. KOPF~KY, ESQj~Ij~E Supr e Court ID #53147 ~/ 300 North Second Street, 8`'' Floor Harrisburg, PA 17101 (717)221-1111 Attorney for Plaintiff AMERICHOICE FEDERAL CREDIT UNION, PLAINTIFF v. MICHAEL J. DOEBLEY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2007- y~~O ~ CIVIL TERM COMPLAINT AND NOW, comes the Plaintiff, by and through its attorneys The Shagin Law Group LLC, and respectfully avers the following in support of its Complaint: 1. Plaintiff is AmeriChoice Federal Credit Union, a Pennsylvania Credit Union doing business at 20 Sporting Green Drive, Mechanicsburg, Cumberland County, Pennsylvania. 2. Defendant is Michael J. Doebley, an adult individual who currently resides at 19C Somers Avenue, Somers Point, New Jersey. 3. On or about June 2, 2003, the Defendant entered into a Credit Card Agreement with the Plaintiff for a credit card account with the credit limit of $12,960.00; a copy of said Agreement is made a part hereof and marked as Exhibit "A." 4. Pursuant to the terms of the Agreement, Defendant is to pay to the Plaintiff on the balance of his credit card a minimum sum of $275.00, monthly, until such time as the credit card balance is paid in full. 5. The Defendant defaulted under the terms of the Agreement by failing to pay the required installment of March 1, 2007, and subsequent installments thereafter. 6. The Defendant is due and owing the total sum of Thirteen thousand, eight -hundred forty -eight dollars and sixty-eight cents ($13,848.68). 7. Despite repeated demands for payment, the Defendant owes and continues to owe said sum to Plaintiff. 8. Pursuant to the Agreement, interest is to accrue on the unpaid balance at the rate of 18% until the total amount owed is paid in full. 9. In addition, pursuant to the Agreement, Defendant is to pay all costs of collecting the amount owed under the Agreement. WHEREFORE, Plaintiff demands judgment in favor of the Plaintiff and against the Defendant in the amount of $13,848.68, plus interest at 18 %, all attorney fees, and the costs of this suit.. Respectfully submitted, ~~ l~, z~ Jo a .Kopeck squire Sup e Court ID #53147 300 North Second Street, 8"' Floor Harrisburg, PA 17101 (717) 221-1111 May-17-2007 10:27 AM AmeriChoice FCU -SPORTING GRN (717)5919695 1/2 .-.....r'.r • ~ ,r /, , ;S~ .N ~l.I~ ;~ ..- - , ~~-. ~~ 'A1~IERICtiotCE table that Includes the AARIo and ~- ~ ,.: Y ~ ~ ~ ~;: R@DERAtL CREDIT UtU-ON ' then regUlred Cd6t disclosures }Or :;° ~-r. ~~•'~~ •• 2d SRortingg Qrean Drive ~.•• ' d:A~ " Mach&nfcabur , PA 17050 radii card' appllcetlons is on the ^:> x~t~^ a (717) 795-o2a~ ~verss side ofi this application. ~EDdT PP~.9C~-TION •. - • (~ (adtvldual Credit: You must complete the Applicant section about yourself end the Dlher section about your spouse ti: (1) you rive In or the property pledged as collateral is located In a community roperty state (AK, AZ, CA, ID, LA, NM, Ny, TX, WA, WI), (z) your spouse Witl use the account, or (3) you are relying on your spouse's income as s basin for repayment. If you are relying on income from eiimany, child support, or separate melntenance, complete the ocher section to the extent possible about the person on whose payments you are relying. O Joint Credit: If you ere eaDlvtnD with another Derson_ comelete the Aaellcenl and ©Ihar nAraions_ (Lnet - Fhet - Inernq~ ~ ~ ~ Ut~IVaE numlieR ~ BTA7E 'L ~ Z+f r-^ di DRNER'B LICENSE NUMBER / tTATE NOME PIiCNE I WOR `7 NEI EKT. ~S 91R7H DATE HOME PNpNE 7 s 6' ~S 6ti tie 9 -3~ 5- ( , 8688 I (:•, A ~~ ~~ ® (r + ~O~ S~MAILADDRESa ADDRESS ($tt9e1- CRy - 8t Zip) . RENT YEARS AT THl PRESENT AODAE88 (Street • Clp+- 61eb • : %L cvr,;;7'!-1 ~"z ltr 1 n pt' ? ADnRESa ,~ I ADDRE88 (Street • DIty~BiMe -Zip) , OWN RENT YEApB AT THIS PREVIOU8 ADDRE88 (Stteot • City - 81nte . IPLETE FOR JOI CREDIT, SECURED CREDIT OR IFYCU LIVE IN A COMMUNITY PROPERTY STATE: PISTE POR JOINT CRGDIZ >i>E'URED CREDIT OR IFYOU LIVe IN A CCMMU MARRIED SEPARA3'ED UNMARRIED (stn s • DNolwd - WMOwed) MARRIED ~PARATEp • ~ •., , UNMARRIED 8 e - Lprorcatl - >! merlt/IncoTne NAME AND ADDREB$ OF,~MPLOYER D rIr O I meat/Incpnle NAME AND ADDgiE68 CF 6NPLOYEp ~~~A ^t;,'avW1r r'"r~~-ti~1 ~' I ~ i l~ 1~G 1•F Ai~w G-yr,~!'N~ N3"o~ iT DATE POSn10N 1~ALI Y, C ILD SUPPORT, OR eEPAr1ATE MAINTENANCE INI IP D~O N1OTCH008ETOHAVEITCCN8IDERE0. OXMENTOIN~M PEA V ~ ~ ~ $TNER INCOME N LETS ~r •pflvCSS _~v!' " SOURCE IE AND ADDREeB OF PREVIOUS EMPLOYER ~1 }-~ ~~ ~ BTAFiT DATE POSITION MME NE 13~i( EA18T~4 EA NCT)CE: IrF IMONY~ NOT C~N008E TO HAVEPAfi~MAI ~ ANCE INCCME NEE EMPLOYMENT INCOME OrtWERINCCME PER $ PER $ PER NET GROSS 80URCE BTA~T DATE lEN9.DATE NAIAC AND ADDRE66 OF PREVIDLIS eMPLOYER eTA DATE I S A6E rKJC. wti iN '~tJ•GT/lCrssv N t~v _ r Deposit Account Narne & Recount rduln6er vA E relditor Nance & Account ~luiinbgr bALance MDNTNLY PAYMENT BAVIN06 $ CpEDTTOR v ~ ~ (:.. S'~ o ~ $ CHECKINt3 $ CREO(TOFIU 1 6 ~a O $ Other Asaatl3 CREDITOR ~ e)n`VS 1/ $ $ OTHER PROPERTY $ CREDITOR t7S~O ~tl Z ~ S OTHER $ AUTO $ AUTO TIC ~ MAKE '~'~~L f4 YEAR (,+ OTHER $ $ Other Irrformatlon " " PucANr oTHeR YEe t0 ANY QUi91toN AboutYou rFYOU ANSWER OTNERTHANNt, EXPLAIN ON AN ATTACHED 3NEET. YES NO YES NO 1, ARE YOU A U.B, CIT1zBN OR PERMANENT RBBIDEN-r ALIE3V7 2. Do YOU CURRENTLY WAYS ANY ouTSTANDINt3 JUDT3MSNT8 OR HAVE YOU EVER FILED FOR BANKRUPTCY, HAD A DEaT ADJUSTMENT PIJIN CONPiRMED UNDER CHAPTER 13, HAD PROPERTY PORECLOSep UPON OR gEP088E88Eb IN THE LAST 7 YEARS, OR BEEN A PARTY IN A LAWSUtT7 ~ 3. ARE YOU A CO•MAKl:R, CO-SIANER OFI GUARANTOR ON ANY LOAN NC7 USTED ABOVE? FOR WHOM (Namv of Others Ohngq(ad on Loen): TO WHOM (Name or crecRto~: Personal Reference` I H>=LAt,uNeHtr: ~~~.r~~R - G., ~~~~ ,~,~~,cs v~y HflMS PHONE. ~c~ ... ~~ ~ rr 3 ~-g - NAME AND ADDRE86 OF NEAREST RELATIVE NOT LMNO WITH YOU: Z SD>k8Y•S I~ UL~', SG 11-te~S j4otN7' /tl~i ~ SiTate Law Notices OHIO RESIDENTS OIdt.Y: The Ohlo laws against dlscrimina- copy of the agreement, statemern or decree, or has actual knowledge of Its terms, tlon require that ail creditors make Credit equally available to al! creditworthy customers before the credit Is granted or the accourd is opened, (2) Please sign if you ere not and that credit reporting agencies maintain separate Credit histories on each Indlvlduaf applying for this account or loan with your spouse. The credit being applied far, !f upon request, The Ohlo Civil Rights Commission administers compi(ance with this law, granted, will be Incurred In the interest of the marriage or family of the undersigned. W[SCONSIN RESIOt:NTB ONLY: (i1 No provlslon of arty marital property agreement, unilateral statemern under fisction 766,56, or court decree under Section 766,70 will adversely affect the rlahts of the Credit Union unless the Credit Union Is furnished a 81ONATURE FOR WIBOONSIN RESIDENTS ONLY DATE You promise that everything you have stated in this application Is correct to the best understand that the use of your card wlfl constitute acknowledgment of receipt and of your knowledge, If there are any Important changes you will notify ua In wrfing agreement to the terms of the credit card agreement. A condition of your account Is immediately. You autharize the Credit lJnlon to obtain credrt reports In Connect)on your grantfnB us a security Interest in your shsro accounts. By signing below you with this appllcatlon for credit end for any update, Increase, renewal, extension, Or grant us a Security interest In ail ladlvldual and feint share and/or depoafl collection off the credit received. You understand that the Credit Un'lon will rely on the accounts you have with us now and in the fuhlre to secure Your credit card information in this application and your credit report to make Its decision. If you acsaunt. Shares and depastts in an indlvldusl Retirement Account sad eny other request, the,Credlt Union w111 tell you the name and address Of any credft bureau accauM that would Teas speofal tax treatment under stage ar federal taw if Iran from which It received ~ credit report an you. It Is a federal crime to willfully and es seourify are not sub'ect to this security Interest. When you are In default we deliberatery provide incomplete or incorrect lnformatlan on leap a plicatlons made may apply the balance ~n these accounts to any amounts due under the credit card to federal credit unlans or state chartered cTedft unions Insured by NCUA. You agreement, CREDIT UNION ~ APPROVED NO.OR CARbB ~-- CREDIT LIMIT s CREOIT CARD NUMBER USE ONLY ^ bECUNSp CREDIT COMMITTEE OR LOAN OFFICER 81tiNATURE ®CUNAMUTUAL8ROI1P,,wo,soor,ALLR13Hi5R6$EflVED DSTACH AND RETURN THIS AppLICATION TO YOU) CREDIT UNION acavso• X01 ToDRDER: ,-A00$66.50,z "' E~t~'I -~ I7 " A .' VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. AmeriChoice Federal Credit Union, Plaintiff BY: ~ DATED: S`/~ ~ 0a7 --~ James Gla Iter, Vice-President C':~ n.' C~ C:J ry +~ ~ `- ~ ~ t.__ J ~ ] ~ __- T r v ~ a : {~' UI ~ ; - - ~: "- rv ,:~ R '~ .. w ...F ~:/