HomeMy WebLinkAbout03-5970UMLIC VP LLC
STEVE N. CHICOINE
Plaintiff
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
NO.
CIVIL DIVISION - LAW
NOTICE TO DEFEND
YOU HAVE BEEN SUED 1N 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 filing in writing with the Court your defenses or objections to the claims set
froth 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
TWO LIBERTY AVENUE
CARLISLE PA 17013
(717) 249-3166
UMLIC VP LLC
STEVE N. CH1COINE
Plaintiff
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. -- ._gq 7d5t
: CIVIL DIVISION - LAW
COMPLAINT
The Plaintiff, UMLIC VP LLC, by its attorneys, KNUPP, KODAK & IMBLUM, P.C., bring this action of
Assumpsit against the Defendant to recover the sum of TWELVE THOUSAND, FIVE HUNDRED SEVENTY-SEVEN
DO LLARS AN D FOURTEEN CENTS ($12,577.14), along with interest thereon from August 16, 2003, upon a cause of action
of which the following is a statement:
1. The Plaintiff, UML1C VP LLC, is a corporation orgauized and existing under the laws of the state of North
Carolina, having mailing address of Post Office Box 471827, Charlotte, North Carolina 28247.
2. The Defendant, STEVE N. CHICOINE, is an adult individual residing at 6979 Wertzville Road, Enola,
Cumberland County, Pennsylvania 17025.
3. Defendant did apply for a Credit Card Account with Plaintiff. Subsequent thereto, Plaintiff issued same.
Upon receipt and use of said card, Defendant did agree to abide by Plaintiff's terms and conditions for the card.
4. Defendant did, at various times, in various places, and for various amounts, avail himself of using the card
for credit, thereby creating a balance due and owing in the amount of Ten Thousand, Four Hundred Eighty Dollars and
N inety-Five Cents ($10,480.95), as set forth on Plaintiff" s Statement of Account attached hereto, marked as Exhibit "A" and
made a part hereof.
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"yom" ~fcr Io ~ch ~nd nj] of thc pcrsens who nppJy for ~nd ~t~ ~lcd a Nt~stcrC_~-d anct/or VISA issued by us. inciudin~ ~ll ce-
VERIFICATION
of UMLIC VP LLC, vel~.t~ th~.'4: the ~tatemem~ mad~ in the aforegoing do,umm~ ~ trtm and ,ozr~t. I uad,r~tand
that false statements h~rein a~e made subject to tho penalties of 1 $ Pa. C. $. §4904, relating to unsworn falsification
lo authorities.
Dated:
UMLIC VP LLC
29857
F:\USRR\STACY\¢CP COMPLAINTS\WORK',29gITrno,wpd;210,t03
SHERIFF'S RETURN -
CASE NO: 2003-05970 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
UMLIC VP LLC
VS
CHICOINE STEVE N
REGULAR
RON KERR
Cumberland County, Pennsylvania,
says, the within COMPLAINT & NOTICE
CHICOINE STEVE N
DEFENDANT , at 1443:00 HOURS,
at 6979 WERTZVILLE ROAD
ENOLA, PA 17025
STEVEN N CHICOINE
a true and attested copy of COMPLAINT & NOTICE
Sheriff or Deputy Sheriff of
who being duly sworn according to law,
was served upon
the
on the 17th day of November ,
together with
by handing to
2003
and at the same time directing His attention to the contents thereof.
Sheriff,s Costs:
Docketing 18.00
Service 6.90
Affidavit .00
Surcharge 10.00
.00
34.90
Sworn and Subscribed to before
me this /~ day of
So Answers:
R. Thomas Kline
11/18/2003
KNUPP KODAK IMBLUM
By: D~eputy/S~heriff