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Home My WebLink About07-4496 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHASE BANK USA, N.A. Plaintiff No: ~~' 1(yC1(o C,iv~l TPa'r-~ vs. PATRICK P SMITH COMPLAINT IN CIVIL ACTION Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt,42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 Seventh Avenue, Suite 2718 Pittsburgh, PA 15219 (412) 434-7955 FAX: 412-338-7130 06039082 C J Pit SJS IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHASE BANK USA, N.A. Plaintiff vs . Civil Action No d 7- y `~/qG ~.! T~-- PATRICK P SMITH Defendant COMPLAINT 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. 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. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 COMPLAINT 1. Plaintiff, CHASE BANK USA, N.A. is a corporation with offices at 3700 WISEMAN BLVD. SAN ANTONIO TX 78251 . 2. Defendant is adult individual(s) residing at the address listed below: PATRICK P SMITH 655 COLONIAL VIEW RD MECHANICSBURG, PA 17055 3. Defendant applied for and received a credit card issued by Plaintiff bearing the account number 4266851055738303 . 4. Defendant made use of said credit card and has a current balance due of $13325.57 5. Defendant is in default of the terms of the Cardholder Agreement having not made monthly payments to Plaintiff thereby rendering the entire balance immediately due and payable. 6. Plaintiff avers that the Cardholder Agreement between the parties provides that Plaintiff is entitled to the addition of interest at the rate of 6.000°s per annum on the unpaid principal. 7. Plaintiff avers that the Cardholder Agreement between the parties provides that Defendant will pay Plaintiff's attorneys' fees. 8. Plaintiff avers that such attorneys' fees will amount to $1500.00 9. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed and/or refused to pay the principal balance, and accrued interest or any part thereof to Plaintiff. Wherefore, the Plaintiff prays for judgment in its favor and against Defendant PATRICK P SMITH INDIVIDUALLY in the amount of $13325.57 with continuing finance charges thereon at the rate of 6.000% per annum from July 10, 2007 plus costs. James WELT , 4 3 6 eves 06039082 C J Pit SJS Pit sbur (4 ) 4 F 4 This law firm is a debt collector at mp ing our client and any information obtai e will Warmbrodt,42524 WEINBERG & REIS CO., L.P.A. th Avenue, Suite 2718 h, PA 15219 ~-7955 -338-7130 to collect this debt for be used for that purpose. . ~ VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA. C.S. 4904 relating to unsworn falsifications to authorities, that he is John K Wells, Manager of Chase Bank, USA, N.A.., plaintiff herein, that he 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 knowledge, information and belief. ase Bank, USA, N.A. (Signature) -be. t'J n, ~ ~ ~ c a O ~.~ r 1"" n7~ ~ ~ ; ~-a . - ca _~ ~ ~p _ ~ ~ O, `` , w ~ ~--+ ~_ .. ~~ SHERIFF'S RETURN - REGULAR CASE N0: 2007-04496 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CHASE BANK USA NA VS SMITH PATRICK P SHARON LANTZ Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon SMITH PATRICK P the DEFENDANT at 1319:00 HOURS, on the 6th day of August 2007 at 655 COLONIAL VIEW ROAD MECHANICSBURG, PA 17055 by handing to PATRICK P SMITH 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 18.00 Service 10,56 Affidavit ,00 Surcharge 10,00 ~~17ItQ C.~... .00 38.56 Sworn and Subscibed to before me this day of , So Answers: Jr ~~~~ %~ R. Thomas Kline 08/07/2007 WELTMAN WEINBERG_& REIS By: A.D. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHASE BANK USA, N.A. Plaintiff vs. PATRICK P SMITH Defendant No.: 07-4496-CIVIL TERM PRAECIPE TO SETTLE, DISCONTINUE AND END WITHOUT PREJUDICE TO REFILE FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: JAMES C. WARMBRODT PA I. D #42524 WELTMAN, WEINBERG 8~ REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#06039082 Y ~i IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHASE BANK USA, N.A. Plaintiff vs. Civil Action No.: 07-4496-CIVIL TERM PATRICK P SMITH Defendant PRAECIPE TO SETTL,~. DISCONTINUE AND END WITHOUT PREJUDICE 70 REFILE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: SIR: Settle, Discontinue and End the above-captioned matter upon .the records of the Court without prejudice to refile and mark the costs paid. WELTMAN, WEINBERG 8~ REIS CO., L.P.A. By: Attorney or laintiff 271 S K peer Building 436 S enth venue Pitts rgh, P 15219 (41 434-7 55 SWORN TO AND SUBSCRIBED before me this ~ ~ ~ day of 2007 N ARY PU I s'f.ay11l~ w ~ii~,~t~6lty='uw~iic Gtyt3Ft~i~~.~f « ,.il~Ftu~`rY4 ;;esu ;y ~crr;<n,_~'a~ : ~~:;~ ~s June ~ "_ ~ .:0 fWem~~ j~~-;wivanla Asso _.-on ~f '' °" ~ es f ~ c ~~ rr; ` ~ _ ... ~ -.,. ,.,, , ~ ~- ~ ~ ~ =~7 ~~,' ~ C ~ r .... .,~