The URL can be used to link to this page

Home My WebLink About07-6951 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CSGA, LLC 2200 Fletcher Avenue, 5'?' Floor Fort Lee, NJ 07024 Plaintiff V. CIVIL ACTION - LAW NO. l5?- lcJ?? Barbara A Satterly 150 Rustic Drive Shippensburg, PA 17257 D'iV it ?-FeT A Defendant NOTICE TO DEFEND YOU have been sued in Court. If you wish to defend against the claim 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 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 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. 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. Lawyer Referral Service Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166; (800) 990-9108 MIGLIACCIO, LLP By:4 4 ran W. Felzer, Esquire Atto ev ID # 38670 jtel (a),lobmlaw.com Thr Neshaminy Interplex, Suite 301 Trevose, PA 19053 Telephone (800) 834-4066 L. , CIVIL ACTION - COMPLAINT Plaintiff, CSGA, LLC, as Assignee of FIRST CARD CONVERSION, by and through its attorneys, Bronson and Migliaccio, LLP, represents as follows: 1. Plaintiff, CSGA, LLC, is a limited liability company organized and existing under the laws of the State of New York with a principal place of business at 2200 Fletcher Avenue, 5t' Floor, Fort Lee, NJ 07024. 2. Defendant, Barbara A Satterly, is an adult individual residing at 150 Rustic Drive, Shippensburg, Pennsylvania 17257. 3. Plaintiff, CSGA, LLC purchased certain accounts by which it is the lawful successor in interest to FIRST CARD CONVERSION , and thereby possesses all rights pertaining thereto, including all rights to an account belonging to Defendant, as more specifically described below. COUNT I - BREACH OF CONTRACT CSGA, LLC v. Barbara A Satterly 4. Defendant utilized an extension of credit made available by FIRST CARD CONVERSION, bearing account 4366103019071374, whereby Defendant would from time to time be advanced credit for purchases or expenditures in exchange for the promise to repay funds so utilized at an agreed upon rate of interest. All of the above was done at the specific request therefore by the Defendant. 5. There is a principal balance due and owing on the account in the amount of $6,956.10 plus accrued interest. A statement of account is attached hereto and marked as Exhibit "A" and is incorporated herein by reference. 6. There is an interest balance due and owing on the account in the amount of $8,239.84. A statement of account is attached hereto and marked as Exhibit "A" and is incorporated herein by reference. 7. Plaintiff has made demand upon the Defendant for payment. More specifically, a written demand was made at least thirty (30) days prior to the filing of this Complaint. 8. Defendant is in breach of the terms of the agreement for the extension of credit and has neglected and refused to pay the outstanding balance. No recent payments have been received on the account. WHEREFORE, Plaintiff CSGA, LLC respectfully requests judgment against the Defendant, Barbara A Satterly, in an amount not exceeding the limits for mandatory arbitration, as follows: a. The principal sum of $6,956.10, plus; b. Interest accrued in the amount of $8,239.84; C. Costs and interest at the legal rate; or d. For such other and further relief as this Court deems just and proper. COUNT II - UNJUST ENRICHMENT CSGA, LLC v. Barbara A Satterly 9. Plaintiff hereby incorporates paragraphs one through eight above as though more fully set forth at length hereinafter. 10. The principal balance of $6,956.10 represents the reasonable value of goods and services, the benefit of which is inured to the Defendant at the expense of FIRST CARD CONVERSION, creating an equitable claim which Plaintiff now holds as successor in interest. 11. The balance of $8,239.84 represents interest accrued as of the date of this filing. WHEREFORE, Plaintiff CSGA, LLC respectfully requests judgment against the Defendant, Barbara A Satterly, in an amount not exceeding the limits for mandatory arbitration, as follows: a. The principal sum of $6,956.10, plus; b. An amount of interest on the principal balance equal to the legal rate and running from the date the account was closed by the Original Creditor until present, representing the time-value of money on the credit extension utilized by the Defendant. C. Costs and interest at the legal rate going forward from today; or d. For such other and further relief as this Court deems just and proper. "K SUN & MIGLIACCIO, LLP Att neys for Plaintiff By Jordan W. Felzer, Esq., ID# 38670 jfe zer@lobmlaw.com Three Neshaminy Interplex Suite 301 Trevose, PA 19053 (800) 834-4066 w VERIFICATION I, Jeremy Hanauer, in my capacity as a Corporate Officer of CSGA, L.L.C., verify that the averments of fact contained in the foregoing Complaint are true and correct to the best of my knowledge information and belief. This statement is made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. Date: ) H U - 0 f ACCOUNT#: 13451143060308557 Forwarder: CSGA, LLC Acct#: 4366103019071374 ACCOUNT INFORMATION REPORT FINANCIAL Original Creditor: FIRST CARD CONVERSION Debt Type: CC STATUS: PRE-LEGAL WIP# Days Left Assigned to: LPASTEVENS 0 0 Placement 03/16/2006 $6,956.10 Last Payment $0.00 Principal $6,956.10 Interest $8,239.84 Attorney $0.00 Court $178.50 Misc $0.00 BALANCE $15,374.44 Personal Information Debtor 1 First BARBARA A Address 150 RUSTIC DRIVE City SHIPPENSBURG Country Work Tel (717)532-3442 Ext SS# DOB 07/03/1962 Spouse Bank -and-As set MI Last Name SATTERLY ST PA Zip 17257 Province Home Tel Fax Driver's License # State There is no bank information on this account. Debt ..._....- Service Provided CREDIT CARD Placement Breakdown Principal $6,956.10 Awarded Int Attorney Fees Court Costs Misc Costs Accrued Int $8,239.84 Total Placement $6,956.10 Original Loan Terms Contract Date Number of Payments Interest Rate % 0.27 Collateral Debt Type Credit Cards Last Payment Date 07/12/2002 Last Payment Amount Last Charge Date Last Charge Amount Original Loan Amount Amount of Payments Serial/Vin Number Page 1 of 1 10/26/2007 01:30:45 .. A ll ;1 00 q o 8 ? d ? y 0 n na d ni +a :CS tV 00 ? CLA, SHERIFF'S RETURN - NOT FOUND CASE NO: 2007-06951 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CSGA LLC VS SATTERLY BARBARA A R. Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT SATTERLY BARBARA A but was unable to locate Her in his bailiwick. COMPLAINT & NOTICE , He therefore returns the NOT FOUND , as to the within named DEFENDANT SATTERLY BARBARA A 150 RUSTIC DRIVE SHIPPENSBURG, PA 17257 DEFENDANT DOES NOT LIVE AT GIVEN ADDRESS. FORWARDING ORDER HAS EXPIRED. Sheriff's Costs: So answers - ... Docketing 18.00. Service 19.20 Not Found 5.00 R. Thomas Kline Surcharge 10.00 Sheriff of Cumberland County .00 52.20 BRONSON & MIGLIACCIO 12/04/2007 Sworn and Subscribed to before me this day of , A.D.