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Home My WebLink About07-6997Leonard A. Sanguedolee, Esquire Attorney for Plaintiff, CACH, LLC. Identification No. 204325 Law Offices: Harrison Ross Byck, Esq., P.C. 15 Public Square, Suite 202 Wilkes-Barre, PA 18701 Phone: (570) 823-0101 Fax: (570) 825-7799 CACH, LLC, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY vs. NANNETTE SLUSSER, CIVIL ACTION - LAW Defendant NO. 09 - (,,q 97 Cry ??.. NOTICE 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 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, 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 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 800-990-9108 Respectfully submitted, - ?W'zo&= Leonard A. an edolce, Esquire IMPORTANT NOTICE If this is your first Communication from this office, please be advised of the following: Unless, within thirty (30) days after receipt of this notice, you dispute the validity of the debt, or any portion thereof, the debt will be assumed to be valid by CACH, LLC. If you notify me in writing within the thirty-day period that you dispute the debt, or any portion thereof, I will obtain verification of the debt or a copy of the judgment against you and a copy of that verification will be mailed to you. Additionally, if, within the previously described thirty (30) days, you request in writing the name and address of your original creditor, I will furnish you with that information if that creditor is different than the current creditor (CACH, LLC.). Please note, that the law does not require me to wait until the end of the thirty-day period before suing you to collect this debt. If, however, you request proof of the debt or the name and address of the original creditor within the thirty-day period that begins with your receipt of this Notice, the law requires me to suspend my efforts (through litigation or otherwise) to collect the debt until I mail the requested information to you. Please be guided accordingly. "This is an attempt to collect a debt and any information obtained will be used for that purpose." Leonard A. Sanguedolce, Esquire Attorney for Plaintiff, CACH, LLC. Identification No. 204325 Law Offices: Harrison Ross Byck, Esq., P.C. 15 Public Square, Suite 202 Wilkes-Barre, PA 18701 Phone: (570) 823-0101 Fax: (570) 825-7799 CACH, LLC, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff vs. CIVIL ACTION - LAW NANNETTE SLUSSER, Defendant NO. 0 7- 6 9 q7 Ctt;,=l COMPLAINT AND NOW, comes the Plaintiff, CACH, LLC, by and through its Attorney, Leonard A. Sanguedolce, Esquire, and files this, its Complaint, against the Defendant, NANNETTE SLUSSER, and avers as follows: 1. That, the Plaintiff, CACH, LLC, is a Delaware corporation with its principal place of business located at 370 17th Street, Suite 5000, Denver, Colorado, 80202. 2. That, the Defendant, NANNETTE SLUSSER, is an adult and competent individual who resides at 723 Pitt Street, Carlisle, Cumberland County, Pennsylvania 17013. 3. That, on or about October 17, 2004, the Defendant, Nannette Slusser was indebted to Bank of America, N. A. on credit card account number 4305 5003 4555 4151 in the amount of $6,282.77. A copy of the final statement is attached hereto, made a part hereof and labeled Exhibit "A". 4. That, on or about October 6, 2006, Bank of America, N.A. assigned the above referenced debt, for good and valuable consideration, to CACH, LLC. A copy of Certificate of Purchase is attached hereto, made a part hereof and labeled Exhibit "B". 5. That, pursuant to the cardholder agreement entered into by the Defendant and Bank of America, N.A., the Plaintiff is entitled to pre-litigation interest of $4.30 per day from the date of charge-off which is calculated as follows: 24.99% annual percentage rate x $6,282.77 365 days or $4.30 x 600 days, which equals an additional $2,580.93, reimbursement of costs and reasonable attorneys fees, in the amount of $1,000.00. 6. That, despite repeated demands by the Plaintiff, Defendant has failed to pay the sum of $9,863.70 which remains due and owing on the above referenced account. 7. That, the claims raised in the Complaint are subject to an agreement to submit these claims to arbitration. WHEREFORE, Plaintiff, CACH, LLC, prays this Honorable Court for Judgment in favor of Plaintiff and against Defendant, NANNETTE SLUSSER, for $9,863.70 together with costs and interest. Respectfully submitted, hd2ti?mi I. ??ezm&= Leonard A. S ng dolce, Esquire Law Offices: Harrison Ross Byck, Esq., P.C. 15 Public Square, Suite 202 Wilkes-Barre, PA 18701 (570) 823-0101 Attorney for Plaintiff, CACH, LLC VERIFICATION I, Dawn Rannells hereby depose and state that: The language of the foregoing document is that of counsel and not necessarily my own; however, I have read the foregoing document and the factual information contained therein is true and correct to the best of my personal knowledge. I am the Authorized Representative and a duly authorized representative of the plaintiff; The factual allegations set forth in the foregoing pleading are true and correct to the best of my knowledge, information and belief, and they are that NANNETTE M SLUSSER owes the balance of $6,282.77 to CACH, LLC on previously submitted invoices, which balance is due and unpaid as if the date of the execution of this Verification. I am aware that if any of the foregoing is willfully false, I am subject to punishment. I understand that false statements made herein are subject to the penalties relating to unsworn falsification to authorities. By MAR 1 3 2007 Dated: Authorized Representative I 0 Fket Asoomm molar 4305 5003 4555 4151 rolot7ua ;0 00 Amaat ??'°,•.Fi.a.r, NOV. 13, 2004 For aaasaa b0oryhn ad; tA,ltalrr alrvloa r 1400404-2500 a loamtac M4' • Far aarl/a at Mdrooo alaau 1100 1a1a1 ea Mot. • Moto ah*ot wyoel. to F1a1t CmM Ora dw*m CREDIT CARD SERVICES NANNETTE M SLUSSER / 723 N PITT ST P.O. BOX 1070 CARUSLE PA 17013-1952 NEWARK, NJ Ni1 07101-1070 11111,11111111111111111111{1111 F yy oil 11111111111111111olllIll 1111141114111 114 Ill Ill 1111{{IIllp1 4305500345554151 0000000 0000000 itaalat 11 wAalrlal ow nkm tool otara V*b pop=& ACCOUNT SUMMARY FOR NANNETTE Y SLUSSER Aoaala mma r: 4305 5009 4555 4151 PAYMENT INFORMATION 471237 • = ?!i;•"ea;`;?`? X0.00 '`?•:$?•-.?'? to-> $1,132.00 .... u:s + 0.00 =. _ $0.00 ' . :L; :a• , , + 0.00 $0.00 - ..?..:., + 0.00 NOV. 13,2W4 $0.00 ToW C/di! LIgR: SIA06AC Cwh AdWAWS Lima: $1,so0.9o Y B" CYdo 010 O.lal l6n7r04 AvO" Crodit: 10.00 Comb Advulop AvtiltbN:>>0.00 Don In om q Cyow. 30 A REGARD nP V[YlA MASH F: AMn frrcrwra Tm a1~ am Pcow Dft 11oAnarlC? --- Numaar - - Tr row"n 0450"on Lro&a p,rpro IS17 1617 IMMO12001000M Ct1AROEOFFA000UNT-MMNCPALS 471237 1617 1Vt7 MMUMM"S M 0MRW0"ACCmmT-Fl NANCECNAWJIW 1,476A0 For Idomladw an yaw acwLml or to Mach C Wmw WvW: ! o r•` is i . ;c ' ^'', j . Uir: P,Q SOX law ME,Iw101ON M 1Mi0 iN0 TWO- rGnvcla 1 R\>iM l r 7wplomant41aan o awpowd- AL PERCENTAGE PATE Itrawhadit O plotldlsaartlaanlae11?/Neap!4.000% ivy= lew. at r.ewi llaa Seeaaa4l? pI-la law. Mar vary. fM MXVW6W fOR IMFORIART W&QWAnol1 5311 off@ Rao 19 a 21 041117 ZXpage 1 of 1 5449 9341 N112 OtAMII a L EXHIBIT Q CERTIFICATE OF PURCHASE Dawn Rannells 1• , hereby depose and state that: 1. I am an Authorized Agent of CACH, LLC, a Colorado Limited Liability Company. 2. As such, I am authorized to give this Certificate, and possess sufficient personal knowledge to do so regarding: Customer Name: NANNETTE M SLUSSER Original Creditor: Bank Of America,N.A Account Number: 4305500345554151 3. On or about October 6, 2006 this account was issued by the original creditor. CACH, LLC is the current owner of the account and purchased the account for good and valuable consideration. Date: MAR 1 3 2007 Sworn and subscribed to before me this 2007. Notary Public My Commission Expires: By: /J-day of A/a--- PRUDENCE TINBERG NOTARY PUBLIC STATE OF COLORADO My Commission Expires 05/03/2010 Exmfa T ? ?? 11 g= ` } fJ SHERIFF'S RETURN - REGULAR CASE NO: 2007-06997 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CACH LLC VS SLUSSER NANNETTE MARK CONKLIN Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon SLUSSER NANNETTE the DEFENDANT , at 1715:00 HOURS, on the 6th day of December-, 2007 at 723 PITT STREET CARLISLE, PA 17013 NANNETTE SLUSSER by handing to a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 9.60 Affidavit .00 Surcharge 10.00 .00 /a/i7/0 7 4?- 37.60 Sworn and Subscibed to before me this So Answers: R. Thomas Kline ??77 12/07/2007 JOHN RODGERS By: day Deputy Sheriff of , A. D. I Leonard A. Sanguedolce, Esquire Attorney for Plaintiff, CACH, LLC Identification No. 204325 Law Offices: Harrison Ross Byck, Esq., P.C. 15 Public Square, Suite 202 Wilkes-Barre, PA 18701 Phone: (570) 823-0101 Fax: (570) 825-7799 CACH, LLC, Plaintiff VS. NANNETTE SLUSSER, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - - LAW Defendant No.07-6997-cv PRAECIPE FOR ENTRY OF JUDGMENT BY DEFAULT TO: Prothonotary, Cumberland County Enter judgment by default, in favor of the Plaintiff, CACH, LLC, and against the Defendant, Nannette Slusser for her failure to plead to the Complaint in this action within the required time. The Complaint contained a Notice to defend within twenty (20) days of the date of service thereof. The Defendant was served with the Complaint on December 6, 2007. Attached hereto as Exhibit "A" is a copy of the Plaintiffs written Notice of intent to file Praecipe for Entry of Judgment by Default, which I can certify was mailed by first class mail to the Defendant at her last known addresses on December 28, 2007, which is at least ten (10) days prior to the filing of this Praecipe. Please assess damages in the amount of nine thousand eight hundred sixty three and 70/100 ($9,863.70) Dollars, being the amount demanded in the Complaint, together with costs and interest. Respectfully submitted, Leonard A. Sa ue ce, squire Leonard A. Sanguedolee, Esquire Attorney for Plaintiff, CACH, LLC Identification No. 204325 Law Offices: Harrison Ross Byck, Esq., P.C. 15 Public Square, Suite 202 Wilkes-Barre, PA 18701 Phone: (570) 823-0101 Fax: (570) 825-7799 CACH, LLC, Plaintiff VS. NANNETTE SLUSSER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - - LAW No. 07-6997-cv AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA SS COUNTY OF LUZERNE I, Leonard A. Sanguedolce, attorney for Plaintiff, CACH, LLC, being duly sworn, depose and say that: To the best of my knowledge, information and belief the Defendant, Nannette Slusser is not in the Military Service of the United States nor any State or Territory thereof, or its allies as defined in the Soldiers and Sailors Civil Relief Act of 1940 and amendments thereto. Dated: O -0// f A Leon ue ,Wde, Esquire ard A.' 8 Sworn to and subscribed before me this, _ day of 2008. NOTARY PUBLIC c0M 1fLVAMA L NOTARIAL SEAL UM L WILSON, NO" Pj6,1 L11"Eak" Avg* , LY?M11e P"nb t ?' ... . s .... Y S?,i??. Y r .... ?b'?.. :il±, :*'.: 411141.E '."??{? #4°yr':_. Leonard A. Sanguedolce, Esquire Attorney for Plaintiff, CACH, LLC Identification No. 204325 Law Offices: Harrison Ross Byck, Esq., P.C. 15 Public Square, Suite 202 Wilkes-Barre, PA 18701 Phone: (570) 823-0101 Fax: (570) 825-7799 CACH, LLC, Plaintiff VS. NANNETTE SLUSSER, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - - LAW Defendant No.07-6997-cv CERTIFICATE OF SERVICE I, Leonard A. Sanguedolce, Esquire, certify that on the above stamped date & time, I caused to be served a time-stamped copy of each of the following documents: Praecipe for Entry of Judgment by Default, Entry of Judgment and Notice of Entry of Judgment along with a Certificate of Service, upon the below listed Defendant, by United States, first class mail, postage prepaid, addressed as follows: Nannette Slusser 723 N. Pitt Street Carlisle, PA 17013 Respectfully submi ed, eonard A. '48 a u Ice, squire Attorney for Plaintiff, CACH, LLC Leonard A. Sanguedolce, Esquire Attorney for Plaintiff CACH, LLC Identification No. 204325 Law Offices: Harrison Ross Byck, Esq., P.C. 15 Public Square, Suite 202 Wilkes-Barre, PA 18701 Phone: (570) 823-0101 Fax: (570) 825-7799 CACH, LLC, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff vs. CIVIL ACTION - LAW NANNETTE SLUSSER, Defendant NO. 07-6997-civil IMPORTANT NOTICE Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 800-990-9108 Respectfully submitted, YOU 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 NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Dated: a W/O A?tj I. I ?n u Leonard A. a edolce, Esquire EXHIBIT `` 0 a Leonard A. Sanguedolce, Esquire Attorney for Plaintiff, CACH, LLC Identification No. 204325 Law Offices: Harrison Ross Byck, Esq., P.C. 15 Public Square, Suite 202 Wilkes-Barre, PA 18701 Phone: (570) 823-0101 Fax: (570) 825-7799 CACH, LLC, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff vs. CIVIL ACTION - LAW NANNETTE SLUSSER, Defendant NO. 07-6997-civil CERTIFICATE OF SERVICE I, Leonard A. Sanguedolce, Esquire, certify that on the JJL day of December 2007, 1 made service of the Original Important Notice of intention to enter default judgment upon the below listed Defendant, by United States, first class mail, postage prepaid, addressed as follows: Nannette Slusser 723 N. Pitt Street Carlisle, PA 17013 C0 0 1 ?? 0 < 9 57- In 40 j am m n N D d w 0 zA LA r 0) m vg m N CC G CA N y M S 0 :3 30 (D r_ I v . Q 5z C S n D is m Cl) ( A c *6 0 > n Ci c CC) n m CL o = °- a0 -n N ((D cmn .NM -P s z v ? 1 L8 L 3Q0 p' V L 09n00 ' ! 93MOO A3Nlld? C "OW Respectfully submitted, eonard A. an edolce, Esquire Law Offices: Harrison Ross Byck, Esq., P.C. 15 Public Square, Suite 202 Wilkes-Barre, PA 18701 (570) 823-0101 c .,F rC ? O Fir '? ? a=? ` t ? - \'+ O "*- ?. ? w. ? E ? a ?? ? ? ..:?. ? _ ;?. ,, ? ?? "' ? Leonard A. Sanguedolee, Esquire Attorney for Plaintiff, CACH, LLC Identification No. 204325 Law Offices: Harrison Ross Byck, Esq., P.C. 15 Public Square, Suite 202 Wilkes-Barre, PA 18701 Phone: (570) 823-0101 Fax: (570) 825-7799 CACH, LLC, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff VS. NANNETTE SLUSSER, CIVIL ACTION - - LAW Defendant No.07-6997-cv NOTICE OF ENTRY OF JUDGMENT TO: Nannette Slusser 723 N. Pitt Street Carlisle, PA 17013 AS PRESCRIBED BY LAW, YOU ARE NOTIFIED THAT A JUDGMENT HAS BEEN FILED IN THIS OFFICE AGAINST YOU BY PLAINTIFF, CACH, LLC, IN THE AMOUNT OF $9,863.70 TOGETHER WITH COSTS AND INTEREST FROM THE TIME OF THE PRESENT, AND CONTINUING TO ACCRUE UNTIL THE TIME OF PAYMENT. Proth notary, MB RLA COUNTY BY: 1 / I b/08 Leonard A. Sanguedolce, Esquire Attorney for Plaintiff, CACH, LLC Identification No. 204325 Law Offices: Harrison Ross Byck, Esq., P.C. 15 Public Square, Suite 202 Wilkes-Barre, PA 18701 Phone: (570) 823-0101 Fax: (570) 825-7799 CACH, LLC, Plaintiff VS. NANNETTE SLUSSER, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - - LAW Defendant No.07-6997-cv ENTRY OF JUDGMENT Pursuant to Praecipe filed for Entry of Default Judgment, Judgment is hereby entered in favor of the Plaintiff, CACH, LLC and against the Defendant, Nannette Slusser, in the amount of nine thousand eight hundred sixty three and 70/100 ($9,863.70) Dollars, together with costs and interest from the time of the present and continuing to accrue until the time of payment. PROTHO OTARY, MBER D COUNTY BY: ///&/02 SHAPIRO LAW OFFICE, P.C. Kenneth S. Shapiro, Esq. Attorney I.D. #26850 712 Darby Road P.O. Box 20 Havertown, PA 19083-0210 (610) 668-0707 PRO T HONG -T - No. of Pages JF THE P 2014 Jilt. 22 12 OUMBERL SP1 gyp; PENNSYLVANIA F� NNS YC q OUNT Y Court Of Common Pleas CUMBERLAND County, PA CACH, LLC Plaintiff v. Nannette Slusser Defendant(s) CIVIL CASE NO. 2007-06997 ENTRY OF APPEARANCE TO THE DIRECTOR OF THE DEPARTMENT OF COURT RECORDS OF CUMBERLAND COUNTY, PENNSYLVANIA (CIVIL DIVISION): Kindly enter my appearance on behalf of CACH, LLC, Plaintiff herein. I hereby certify that this change is not intended to, nor will it, delay this proceeding to the best of my knowledge, information and belief. Papers may be served at the address set forth below: Dated: J U L 2 12 014 EW870 Kenneth S. Shapiro, Esq. Attorney ID # 26850 Shapiro Law Office, PC 712 Darby Rd P.O. Box 20 Havertown, PA 19083-0210 Telephone # 610-668-0707 FAX # 610-668-1815 Respectfully submitted, SHAPIRO LAW OFFICE, P. K- Mnir.. Sh.. ro, - sq For the fi