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Home My WebLink About07-6999Leonard 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, vs. Plaintiff IN THE COURT OF COMMON FLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ANDREW RAMOS, Defendant NO. 60 9 9 q CZ 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, X Leonard A. Sangue Ice, 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, vs. Plaintiff ANDREW RAMOS, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW Defendant NO. -7 % 9 C ? ; 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, ANDREW RAMOS, 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, Andrew Ramos is an adult and competent individual who resides at 11 Paradise Drive, Carlisle, Cumberland County, Pennsylvania 17013. 3. That on or about June 30, 2005, the Defendant, Andrew Ramos was indebted to Chase Manhattan Bank on credit card account number 5183 3724 4001 3549 in the amount of $4,008.40. A copy of the final statement is attached hereto, made a part hereof and labeled Exhibit "A". 4. That, on or about January 1, 2006, Chase Manhattan Bank 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". A copy of Affidavit of Sale is attached hereto, made a part hereof and labeled Exhibit "C". 5. That, pursuant to the cardholder agreement entered into between the Defendant and Chase Manhattan Bank, the Plaintiff is entitled to pre-litigation interest of $3.24 per day from the date of charge-off which is calculated as follows: 29.49% annual percentage rate X $4,008.40 - 365 days or $3.24 x 600 days which equals an additional $1,943.14 reimbursement of costs and reasonable attorney fees in the amount of $750.00. 6. That, despite repeated demands by the Plaintiff, Defendant has failed to pay the sum of $6,701.54 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, ANDREW RAMOS, for $6,701.54 together with costs and interest. Respectfully submitted, ?d Leonard A. Sangu ce, 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, Jason W i I 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 ANDREW J RAMOS owes the balance of $4,008.40 to CACH, LLC on previously submitted invoices, which balance is due and unpaid as if the date of the execution of this Verification. I am aware that if any of the foregoing is willfully false, I am subject to punishment. I understand that false statements made herein are subject to the penalties relating to unsworn falsification to authorities. By: Dated: APP 2 7 2097 Authorized Representative Page 2of2 PAYMENT DUE DATE NEW BALANCE MINIMUM DUE 0710$/2005 I $4,008.40 $1,666.40 Jan 23 2007 ACCOUNT NUMBER: 5183 3724 4001 3549 0 csimile ANDREW J RAMOS 2440 11 PARADISE DR CARLISLE PA 17013-9725 C)CHASE Chase Platinum MasterCard- ACCOUNT NUMBER: 5183 3724 4001 3 19 NEW PAYMENT TOTAL TOTAL STATEMENT BALANCE DUE DATE CREDIT LINE AVAILABLE CREDIT CLOSING DATE $4,008.40 07!08/2005 33,100 $0.00 06/1312005 Here is your Account Summary: TOTAL Previous Balance $3.830.64 (-) Payments, Credits 0.00 (+) P=rvaftea, Caen, Debits 74.00 (+) FINANCE CHARGES 103.76 (_) New fWance 4.DDS.40 Mlnlmum Due 104.00 Past Ous - Pay Immedlateyr 554.00 Over line - Pay Immediately 908.40 Mhmum Payment Due 31,566.40 Herr are Your Charges and Credits at a glance: TRAM. POST REF. DATE ATE NO DESCRIPTION OF TRANSACTIONS CREDITS CHARGES 1013 08113 OVERLIMIT FEE 35.00 LATE CHARGE - MIN PYMT NOT RECD By DATE 39.00 Total of your credits and charges 0.00 74.00 DUE TO IMPROVEMENTS BEING MADE TO OUR ELECTRONIC PAYMENT SERVICE. WE WILL NOT BE ABLE TO PROCESS EPAYS FROM WED, JULY 20TH AT 4:00 P.M. UNTIL MON. JULY 25TH AT 8:00 A.M. EASTERN TIME. WE THANK YOU FOR YOUR PATIENCE AND APOLOGIZE FOR ANY INCONVENIENCE THIS MAY CAUSE. FAILURE TO MAKE PAYMENT HAS DAMAGED YOUR CREDIT RATING. WE WANT TO WORK WfTH YOU TO REBUILD YOUR CREDIT. CALL TODAY TO GET STARTED. Here's hnw we determined vnur lFinance Chartre*: Days in Billing Cvclle: 33 NOMINAL DAILY AVERAGE PERIODICIMIN. TOTAL ANNUAL. ANNUAL PERIODIC DAILY FINANCE FINANCE PERCENTAGE PERCENTAGE RATE BALANCE CHARGE CHARGE RATE RATE Cash 0.08080% 30.00 50.00 $0.00 29.49% 0.00% Purchases 0.08080% $3,891.24 3103.76 $103.76 29.49% 29.49% Please sae raverse side for balance computation method and other important inrormauen. Questions about your account? Credt Card lost or stolen? Coll Chase Customer Serolae 24 hours a Day, 7 days a week, toll-free, at 1-800-794-1396 or write P.O. BOX 15860, WIImington. DE 19686-5650. Para Servieio al ClieMe an Espaflol: 1-800-545-0464_ Page 1 of 1 EXHIBIT ? `` 11 CERTIFICATE OF PURCHASE I, Jason Willis , 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: ANDREW J RAMOS Original Creditor: Chase Manhattan Bank Account Number: 5183372440013549 3. On or about Tanuary 1, 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. DateARR2 7 07 B3 Sworn and subscribed to before me this c?- day of 2007. Notary Public My Commission Expires: =PPUUBLIC My Commission Expires 11/03/2010 EXHIBIT `l CHASE ! i AFFIDAVIT OF SALE STATE OF: TEXAS COUNTY OF: BEXAR 1. I, Elizabeth J Ranft-Garcia, am the Bank Officer of Chase Bank USA, N.A. and am authorized to make this affidavit on behalf of Chase Bank USA, N.A. 2. ANDREW J RAMOS had a credit card account with Chase Bank USA, N.A., account number 5183372440013549. The account was sold and transferred to CACH, LLC, on or just prior to 12/23/2005. 3. At the time of the sale to CACH, LLC, the amount pursuant to the terms of the cardholder agreement between Chase Bank USA, N.A. and ANDREW J RAMOS was $4,008.40. 4. Your deponent states that to the best of deponent's knowledge, information and belief that there was no unaccredited payment, just counterclaims or offsets against the account when it was sold. 5. Your deponent acknowledges that in making this affidavit that CACH, LLC is now the owner of said account, and authorized to collect, settle, adjust, compromise and satisfy the same and that Chase Bank USA, N.A. has no further interest in said account for any purpose. ZCas Ba SA A Elizabet FJJanft-Garcia On aw'4 I , 2007 before me personally appeared Elizabeth J. Ranft-G cia, who being sworn stated he/she was authorized on behalf of Chase Bank USA N.A to execute the within affidavit. EXHIBIT kd,4412 J / & r Notary Public ?aY`'Y ? '•: DOLORES A. RAMIREZ MY COMMISSION EXPIRES July 11, 2010 /•?rF,pii 1., cr7 .i - ` co s ?Y l?F l y. J ? h 1 SHERIFF'S RETURN - REGULAR CASE NO: 2007-06999 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CACH LLC VS RAMOS ANDREW 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 RAMOS ANDREW the DEFENDANT , at 1905:00 HOURS, on the 6th day of December , 2007 at 11 PARADISE DRIVE rART,TSLE. PA 17013 by handing to TAUREL RAMOS WIFE 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 Service Affidavit Surcharge )A//-7ja 7 18.00 4.80 .00 10.00 .00 ? 32.80 Sworn and Subscibed to before me this day So Answers: R. Thomas Kline 12/07/2007 JOHN RODGERS By : 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 Wickes-Barre, PA 18701 Phone: (570) 823-0101 Fax: (570) 825-7799 CACH, LLC, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff CIVIL ACTION - - LAW VS. ANDREW RAMOS, Defendant No.07-6999-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, Andrew Ramos for his 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 six thousand seven hundred one and 54/100 ($6,701.54) Dollars, being the amount demanded in the Complaint, together with costs and interest. Respectfully submitted, Leonard A. an ed e, Esquire 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. ANDREW RAMOS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - - LAW No. 07-6999-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, ANDREW RAMOS 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: 0 Leonard A. a ue ce, squire Sworn to and subscribed before me this dayofQ0_m_L1'(a 1??F 2008. A .'J 'L" NOTARY PUBLIC rtr OR?"*_A_V y#_MA LI NOTX%AL SE4L LWA L WIL0)K NdrY Pd* WVY In*" AM* Lucerne 25, X11 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. ANDREW RAMOS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - - LAW No. 07-6999-cv CERTIFICATE OF SERVICE I, Leonard A. Sanguedolce, Esquire, certify that on the above stamped date & time, 1 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: Andrew Ramos 11 Paradise Drive Carlisle, PA 17013 Respectfully submitted, Leonard A. Sa ue ce, Esquire Attorney for Plaintiff, CACH, LLC Leonard A. Sanguedolce, Esquire Attorney for Plaintil& CACK 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) 825-7794 CACH, LLC, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff vs. CIVIL ACTION - LAW ANDREW RAMOS, Defendant NO. 07-6999-civil IMPORTANT NOTICE 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. Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 800-990-9108 Respectfully submitted, Dated: a a 6 7 , IIIA'a.", J A - //--- ? , ?-Zr eonard A. S g olce, Esquire EXHIBIT 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 ANDREW RAMOS, Defendant NO. 07-6999-civil CERTIFICATE OF SERVICE 0 9 V rn m 0 0 4 I, Leonard A. Sanguedolce, Esquire, certify that on the _QL 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: Andrew Ramos 11 Paradise Drive Carlisle, PA 17013 A i om y Respectfully submitted, ?. Ty C5 2 ?0 1 Oq T D d O r ?p M Lod 4. ! ?O ry m Leonard A. S gu Ice, Esquire -0 0 N C a) -+? Law Offices: p oo a in- Harrison Ross Byck, Esq., P.C. (n D mm m 15 Public Square, Suite 202 o m 0 ( Wilkes-Barre, PA 18701 > D W -4 0) :3 0 (570) 823-0101 a OD(n (D m -4 C OQ O rA " N 0 S 3 z D 6 fQ Z Ei fD L 3Q ..1 8 ZO H?°1Nltd H A3N r 7, t .? ?.; ?'J "7'1 Q ? ? ? _ ? 1 ? C.,._ ?;?,. .?-{-?. T .? ? 71 ;' ? b ? W -. - lY4• "[ 10 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 ANDREW RAMOS, Defendant No.07-6999-cv NOTICE OF ENTRY OF JUDGMENT TO: Andrew Ramos 11 Paradise Drive 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 $6,701.54 TOGETHER WITH COSTS AND INTEREST FROM THE TIME OF THE PRESENT, AND CONTINUING TO ACCRUE UNTIL THE TIME OF PAYMENT. Prothono ry, WCBE ANDCOUNTY BY: 0 (0/08 . 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, VS. ANDREW RAMOS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - - LAW Defendant No.07-6999-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, Andrew Ramos, in the amount of six thousand seven hundred one and 54/100 ($6,701.54) Dollars, together with costs and interest from the time of the present and continuing to accrue until the time of payment. PROTHON 9Y, C ERLA D COUNTY BY: ,/,(.dog 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 tjfTHE r PR 0 THO-I m IQ: 09 CUMBERLAND COUNTY PENNSYLVANIA No. of Pages C CACH, LLC v. Andrew Ramos Court Of Common Pleas CUMBERLAND County, PA Plaintiff Defendant(s) CIVIL CASE NO. 2007-06999 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: JUL 2 12014 EW862 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 OFFIC iro, Esq. For the ' rm