HomeMy WebLinkAbout03-5874IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
FORD MOTOR CREDIT COMPANY,
Plaintiff,
vs.
AARON A. CHACE,
Defendant.
CIVIL DIVISION
NO. 0~ - .~e'"~ 0,o~ ~"~
TYPE OF PLEADING: CIVIL ACTION
COMPLAINT
CODE - 011 - ASSUMPSIT
FILED ON BEHALF OF: Plaintiff,
Ford Motor Credit Company
COUNSEL OF RECORD FOR THIS PARTY:
DONALD S. MAZZOTTA, ESQUIRE
Pa. I.D. ~11461
LAW OFFICES OF DONALD S.
Firm #742
938 Penn Avenue
Pittsburgh, PA 15222
MAZZOTTA, P.C.
(412) 471-0300
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
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 SHOULD
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 ON AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Lawyer Referral Service
Court Administrator
4th Floor, Cumberland County Courthouse
S. Hanover Street
Carlisle, Pennsylvania 17013
(717) 24046200
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
FORD MOTOR CREDIT COMPANY,
Plaintiff,
vs.
AARON A.
CHACE,
Defendant.
CIVIL DIVISION
AND NOW,
its attorneys,
COMPLAINT - CIVIL ACTION
COMES the Plaintiff, Ford Motor Credit Company,
Law Offices of Donald S. Mazzotta, P.C., and
by
respectfully presents its complaint in civil action against the
Defendants above-named upon a cause of action whereof the
following is a statement:
1. Ford Motor Credit Company is a corporation doing
business at PO Box 6508, Mesa, Arizona 85216, and is hereinafter
referred to as "Plaintiff."
2. Aaron A. Chace is an individual residing at 123 Umberto
Street, New Cumberland, Cumberland County, Pennsylvania 17070,
and is hereinafter referred to as "Defendant."
3. Defendant entered into a written Lease agreement
(hereinafter "Lease") for personal property. Defendant agreed to
pay Plaintiff under the terms of Lease. A copy of Lease is
marked Exhibit "A", attached hereto and made a part hereof.
4. Plaintiff is the holder of Lease and is entitled to
payment under the terms thereof.
5. Defendant is in default for failing to pay in accordance
with Lease terms, and Plaintiff incurred a loss in the amount of
$8,671.29.
6. Plaintiff is entitled to interest from August 21, 2002
to October 30, 2003 at 6.000% per annum, totaling $641.04.
7. Demand for payment has been made upon Defendant, but
Defendant has failed or refused to pay.
8. Under the terms of Agreement, Plaintiff is entitled to
reasonable attorney's fees of 20.000% of the outstanding balance
due, in the sum of $1,734.26.
WHEREFORE, Plaintiff seeks judgment against Aaron A. Chace
in the amount of $11,046.59, plus interest from October 31, 2003
to date of judgment and costs of suit.
LAW OFFICES OF DONALD
BY:
S. MAZZOTTA,
, Esquire
Attorney~ for Plaintiff
DO~It~ ES ~7.7~ N/A
............................................................................................... +
PLANT~FF'S
EXHIBIT
i, Dcnald S. Mazzot%ar Esquire, stats that I am not a party tc
the action but that at the re.cuest of the Plaintiff! ~nd based upon
~now!edge, information, records, a.nd documents supplied to me by the
Plaintiff, the averments set forth in the Civil Action Cc~rp_!aint are
t~ae. A Verification executed by the Plaintiff can be supplied at time
of trial or upon re_cfuest.
I understand that false statements herein are made s-~bjsct to
t, he penalties cf 18 Pa. C.S.
authorities~
§490a. relati~ to unswcrn falsification to
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
FORD MOTOR CREDIT COMPANY,
vs.
Plaintiff,
AARON A. CHACE,
Defendant.
CIVIL DIVISION
No. 03-5874 Civil Term
ISSUE NO.
TYPE OF PLEADING: PRAECIPE TO
DISCONTINUE WITHOUT PREJUDICE
Code
Filed on behalf of: Plaintiff,
Ford Motor Credit Company
Counsel of Record for this
Party: Donald S. Mazzotta,
Pa. I.D.# 11461
LAW OFFICES OF
DONALD S. MAZZOTTA, P.C.
Firm #742
938 Penn Avenue, Suite 700
Pittsburgh, PA 15222
(412) 471-0300
Esq.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
FORD MOTOR CREDIT COMPANY,
vs.
Plaintiff,
AARON A. CHACE,
No. 03-5874 Civil Term
Defendant.
PRAECIPE TO DISCONTINUE WITHOUT PREJUDIC~i
TO: PROTHONOTARY
SIR:
this matter and mark the docket
Please Discontinue Without Prejudice the action regarding
accordingly.
LAW OFFIC
By:
~[~n~ey~for Plaintiff