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Home My WebLink About07-6992Leonard 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 PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW RONALD WHITE, Defendant NO. D 7 - 1 9 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, Leonard A. an olce, Esquire IMPORTANT NOTICE If this is the first Communication you have received 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. 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. CIVIL ACTION - LAW RONALD WHITE, Defendant NO. 0 '7- L 4 9a2 dit--4 -z, 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, RONALD WHITE, and in support thereof 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, RONALD WHITE, is an adult and competent individual who resides at 1917 Chatham Drive, Camp Hill, Cumberland County, Pennsylvania 17011. 3. That, on or about January 30 2004, the Defendant, Ronald White was indebted to Bank of America, N.A. on credit card account number 5491 0007 0815 1761 in the amount of $9,734.56. A copy of the final statement, kept in the regular course of business 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 $6.66 per day from the date of charge-off which is calculated as follows: 24.99% annual percentage rate x $9,734.66 365 days or $6.66 x 600 days, which equals an additional $3,996.00, 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 $14,730.56 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, RONALD WHITE, for $14,730.56, together with costs and interest. Respecltfull submitted, C? Leonard A. ng edolce, 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 Rann?ll , 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 RONALD R WHITE owes the balance of $9,734.56 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 4 0 Fjw Account 15 10007 0815 1761 P050MM ce $9,734-5 ?awna a?v?°B?Fnena3,150.5 JAN. 29, 2004 WFM Ctomerr slrelOeM-2500ca11: or loghonptt/Aycard.fleet.com aa?? kg :For Chanect pay, eeto pp11 FlseteCreQ1toara'serrvices. Make c anle RONALD R WHITE 109487 FLEET CREDIT CARD SERVICE 1991177 CHATHAM DR PO BOX 15368 WILMINGTON DE 19886-5368 11988653686821 !1701159171701 5491000708151761 0973456 0315056 Detach at perforation and return form above with payment. ACCOUNT SUMMARY FOR 1 f A A, RONALD R WHITE Fleet PLATINUM Account NBA36r8007 0815 1761 ?.. PAYMENT INFORMATION $9,461. 9 <. :.: szers/ .00 era 00 s Period $15 .0 , ;.;.;,.; -•? ;.. .i_ Limit $1,43 .56 + 70.00 DUE $3,15 .56 202 87 $9,734. 6 Total Credit$211160:00 Cash Advance Lim$4;150.00?Billing Cycle C1osakd0 "Ol: Available Cr$di89 Cash Advance Ava$1*51e: Days in Billing Iycle: A RECORD 7FSIM?CIOn AMe OF Y Pp1Y:p Deb OUR CaAKCjES AND Ri/MMIPi M»IbM 9.wKzwlwa ' tMrwCfkn ONialpNOn fiwOEl GWpM O1/ 201/ OVERLIMTT FEE 12/ 012/3 LATE FEE O1/ 201/ "FINANCE CHAR EURCHASES $160.03 CASH ADVANCE $42.8 For information on your account or to rea ; , 1- 800-492-2500 T `5 s: = 0 5 http://mycaCrd.fleet.com WILMINGTON . PO BOX 15480 35.00 35.00 :02.87 172.87 61.69 34.56 a sea .<.. »s?xe:. :.:::::; •, ion .,.- :•:.,: :;: ?.::, :;::?::>•:,. :::.ri:Et 1'111" ... ?•' 0.00 »:w,;.chi :i:t?;.:SiY... ::}:w•+. ?:tli'!M'. ....c.-a •:i>.: tF .::t'r -'y,Nr?„'.? O.OO VA: 0.00 ANNUAL PERCENTAGE RATE for purchases and balance transfers (ind7ludWoiany finance charge fees): ANNUAL PERCENTAGE RATE for cash advances (includes a44 Bice charge fees): If you have a variable rate account, your periodic rates may vary. INFORMATION FOR YOU PLEASE CALL US IMMEDIATELY AT 1-800-544-2028 YOUR ACCOUNT IS PAST DUE YOU MAY NOW MARE PAYMENTS ONLINE QWWW.MYCARD.FLEET.COM YOUR ACCOUNT IS CURRENTLY CLOSED EXHIBIT SEE REVERSE SIDE FOR IMPORTANT INFORMATION ?? CERTIFICATE OF PURCHASE 1, Dawn Rannell 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: Original Creditor: Account Number: RONALD R WHITE Bank Of America,N.A 5491000708151761 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 day of 2007. PRUDENCE TINBERG NOTARY PUBLIC Notary Public STATE OF COLORADO My Commission Expires 05/03/2010 My Commission Expires: EXHIBIT In V ? * O ? r- ' s»• ? ~ CD ? 8 SHERIFF'S RETURN - NOT SERVED CASE NO: 2007-06992 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CACH LLC VS WHITE RONALD R. Thomas Kline , Sheriff , who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT to wit: WHITE RONALD but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT & NOTICE NOT SERVED , as to the within named DEFENDANT , WHITE RONALD 1917 CHATHAM DRIVE CAMP HILL, PA 17011 EIGHT ATTEMPTS AT SERVICE WERE MADE, BUT NO ONE WAS HOME. COMPLAINT HAS EXPIRED. Sheriff's Costs: So answe Docketing 18.00 ` Service 46.08 ` Affidavit .00 R.yThomas-Kline Surcharge 10.00 Sheriff of Cumberland County ig31Jo7(?, ? i4.08 JOHN P. RODGERS 12/21/2007 Sworn and Subscribed to before me this day of A. D.