HomeMy WebLinkAbout07-7599COMMOIKIWEALTTi OF PENNSYLVANIA NOTICE OF APPEAL
CO T OF COMMON PLE 5 FROM 1 1 lei 141q/07
btr C
I AL DIS?RICT DISTRICT JUSTICE JUDGMENT
COMMON PLEAS No. f) 7 _ 7.5 q aly; I TG'*
NOTICE OF APPEAL
Notice is given that the appellant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the District Justice
on the date and in the case mentioned below.
NAM! F APPELLANT
V1i
t
(?
e l? MAG. DIST. NO. OR NAME OF O.J.
6q- (- 02
ADDRESS OF APPELLANT ITT STATE ZIP CODE
07A P ?st
565
DATE OF JUDGMENT IN ME CASE OF (plaintiff) (Defendant)
12- 15 164- rd 1-14 1 ( VS. l
CLAIM SIGNATUR OF PEL L?&NT OR I ffS PA'TORNIFY OR AGE
CV 19 _ 3z q - a +
LT 19 V'/z?
This block will be signed ONLY when this notation is requir under Pa.
R.C.P.J.P. No. 1008B.
This Notice of Appeal, when received by the District Justice, will operate as
a SUPERSEDEAS to the judgment for possession in this case.
Signature of Prothonotary or Deputy
If appellant as Claimant (see Pa. R.C.P.J.P.
No. 100 ) in action before District Justice, he
MUS FILE A COMPLAINT within twenty (20)
da after filing his NOTICE of APPEAL.
PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE
(This section of form to be used ONLY when appellant was DEFENDANT (see Pa. R.C.P.J.P. No. 1001(7) in action before District Justice.
IF NOT USED, detach from copy of notice of appeal to be served upon appellee).
PRAECIPE: To Prothonotary
Enter rule upon
(Common Pleas No.
RULE: To
Name of appellee(s)
, appellee(s)
Signature of appellant or his attorney or agent
(1) You are notified that a rule is hereby entered upon you to file a complaint in this appeal within twenty (20) days after the date of
service of this rule upon you by personal service or by certified or registered mail.
(2) If you do not file a complaint within this time, a JUDGMENT OR NON PROS WILL BE ENTERED AGAINST YOU.
(3) The date of service of this rule if service was by mail is the date of mailing.
Date:
AOPC 312-90
19
, appellee(s), to file a complaint in this appeal
Name of appellee(s)
within twenty (20) days after service of rule or suffer entry of judgment of non pros.
COURT FILE TO BE FILED WITH PROTHONOTARY
Signature of Prothonotary or Deputy
C> ?
At O° r
D-)
..
90. LA J
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C? ar
coo
PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FILE COMPLAINT
(This proof of service MUST BE FILED WITHIN TEN (10) HAYS AFTER filing the notice of appeal. Check applicable boxes)
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF • ss
AFFIDAVIT. I hereby shear or affirm that I served
® a copy of the Notice of Appeal, Common Pleas No--
(date of service) __. 19 ?
receipt attached hereto, and upon the appellee, (name)
-_..____-__ __. 19 ? by personal service
upon the District Justice designated theren can
by personal service ? by (certified) (registered) mail, senders
- .... on
? by (certified) (registered) r73ail, sender's receipt attached hereto.
® and further that I served the Rule to File a Complaint accompanying the above Notice of Appeal upon the appellees) t.
whom the Rule was addressed on
19 ? by personal service ? by (certified) #,registercr:>
mail, sender's receipt attached hereto.
SWORN (AFFIRMED) AND SUBSCRIBED BEFORE ME
THIS _ DAY OF . 19
Signature of aftfan,
Signature of official before whom affidavit was made
Title of official ? -
My commission expires on 19__
THIS IS TO NOTIFY YOU THAT:
dud rl?ent DEFADLJUD DSF._: _12/03/.7-
g (Date. of.Judgment) _
® Judgment was entered for:
(Name) ROSE, HEATHER S
® Judgment was entered against: (Names) CONK0 TNEALTB FIRL1111CIAL SYSTEIILS
in the amount of $ '
Amount of Judgment $ .00
Judgment Costs : $__ 00
0
0
Interest on Judgment $ .
1
Attorney' Fees $
Total $ : 00
Post Judgment Credii#s
Post Judgment;Costs $
Certified Judgment Total $
ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE
OF APPEAL WITH THE PROTHONOTARY/CLERK OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. YOU
MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENTITRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL.
EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR MAGISTERIAL DISTRICT JUDGES, IF THE
JUDGMENT HOLDER ELECTS. TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUST
COME FROM THE COURT OF COMMON•PL'EAS AND NO FURTHER PROCESS MAY BE ISSUED BY THE mAGISTERIAL'DISTRICT JUDGE.-'
UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS, ANYONE INTERESTED IN THE JUDGMENT MAY FILE
A REQUEST FOR ENTRY OF SATISFACTION WITH THE MAGISTERIAL DISTRICT JUDGE IF THE JUDGMENT DEBTOR PAYS IN FULL,
SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT.
s?
spate ;,
My commission expires first Monday of January, 2012
AOPC 315-07
DATE PRIXTED: 12/03/07 10:36:00 AN
SEAL
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Commonwealth Financial Systems, Inc
120 N. Keyser Ave. CIVIL ACTION
Scranton PA 18504
Plaintiff :
vs. NO: b7 (T'Jg9 Civil te?M
HEATHER S ROSE
2117 PRINCETON AVE APT2
CAMP HILL PA 17011
Defendant :
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 to
Defend are served, by entering a written appearance personally or by an 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 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 REDUCED FEE OR NO FEE.
MIDPENN LEGAL SERVICES
401 EAST LOUTHER STREET
CARLISLE, PA 17013
717-243-9400
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Commonwealth Financial Systems, Inc
120 N. Keyser Ave. CIVIL ACTION
Scranton PA 18504
Plaintiff
vs.
HEATHER S ROSE :
2117 PRINCETON AVE APT2
CAMP HILL PA 17011 :
Defendant
NO: 01 7_5 9 4 tom' .trr.?
COMPLAINT
Plaintiff, Commonwealth Financial Systems, Inc, by and through its attorneys, Edwin A.
Abrahamsen & Associates, P.C., complains of the Defendant as follows:
1. Plaintiff, Commonwealth Financial Systems, Inc, (hereinafter "Plaintiff") is a
Pennsylvania corporation with a principal place of business located at 120 North Keyser Avenue
Scranton, PA 18504.
2. The Defendant HEATHER S ROSE (hereinafter "Defendant") is an adult
individual residing at 2117 PRINCETON AVE APT2 CAMP HILL PA 17011.
3. At all relevant times herein, Plaintiff was engaged in the business of debt purchase
and collection.
4. Defendant applied for and received a credit card issued by Citibank with the
account number 5424180428764259
5. The within account was sold by Citibank to Unifund for valuable consideration and
all rights under said accounts were assigned to Unifund. (See, Bill of Sale, Affidavit and
Assignment attached hereto as Exhibit "A.")
6. On or about October 22, 2003 Plaintiff was assigned all rights to certain credit card
accounts from Unifund, including the account opened by Defendant with account number
5424180428764259. (See, Bill of Sale, Affidavit, and Assignment attached hereto as Exhibit "B.")
7. Use of the Citibank credit card was subject to the terms of the Cardmember
Agreement, a copy of which was sent to the Defendant along with the credit card. (See, Copy of
Cardmember Agreement, attached hereto and marked Exhibit "C.")
8. Defendant used the Citibank credit card account number 5424180428764259, for
purchases, cash advances and/or balance transfers.
9. The Defendant was mailed account statements relative to the Defendant's use of the
subject credit card.
10. The Defendant defaulted under the terms of the Agreement by failing and refusing
to make monthly payments on the account as they became due.
11. The account became delinquent on December 31, 2004.
12. The principal amount was $2,570.74 at the time it was received by Plaintiff.
13. Pursuant to the account agreement, any unpaid balance accrues interest at the rate
of 24.99%.
14. The total amount due and owing the Plaintiff including interest, is $8,828.24.
15. Pursuant to the terms of the Agreement, Defendant is liable for Plaintiffs court
costs and reasonable attorney's fees in the amount of 25% of the balance.
WHEREFORE, Plaintiff requests judgment in its favor and against Defendant in the
amount of $8,828.24 plus costs of suit, reasonable attorneys' fees of $2,207.06 and any other relief
as the Court deems just and appropriate.
Respectfully
Edwin A. /crd, & Assoc.
Michael F. Esquire
Scott J. BeAttorney I. 285/93600
1729 Pittston Avenue
Scranton, PA 18505
mratchford@eaa-law.com
sbest@eaa-law.com
)+-A
BILL OF SALE, ASSIGNMENT AND ASSUMPTION AGREEMENT
THIS BILL OF SALE, ASSIGNMENT AND ASSUMPTION AGREEMENT is dated as
of August 28, 2003, between Citibank (South Dakota), National Association, a national banking
association organized under the laws of the United States, located at 701 East 60th Street North,
Sioux Falls, SD 57117 (the "Bank") and Unifund CCR Partners, ("Buyer"), with its
headquarters/principal place of business at 10625 Techwoods Circle, Cincinnati, OH 45242.
For value received and subject to the terms and conditions of the Purchase and Sale
Agreement dated August 28, 2003, between Buyer and the Bank (the "Agreement"), the Bank
does hereby transfer, sell, assign, convey, grant, bargain, set over and deliver to Buyer, and to
Buyer's successors and assigns, good and marketable title to the Accounts (as defined in the
Agreement) free and clear of all encumbrances, equity, lien, pledge, charge, claim, or security
interest.
Except as set forth in the Agreement and this Bill of Sale, this Bill of Sale, Assignment
and Assumption Agreement is executed without recourse and without representations or
warranties including, without limitation, warranties as to collectibility.
Citiba ou i akota), Unifund CCR Partners
Na ' nal Associ 'on
By: By:
n?,?, yr (Signature)
L«" aids
N e: : 1 in. f i 11ce '0 F France Name: DIY
-?
Title: Title:1rL? (??
unifundcbsd0501doc
1+
uniFund
Unifund CCR Partners
BILL OF SALE
Unifund CCR.Partners, for value received and in accordance with the terms of the Accounts
Receivable Purchase Agreement by and among Unifund C;CR Partners and Commonwealth
Financial Systems ("Purchaser°), dated as of October 14, 2003 (the Agreement"), does
hereby sell, assign and transfer to Purchaser all of its good and marketable title, free and
clean of all liens, claims and encumbrances in and to the Accounts listed in the Account
Schedule attached as Appendix A to the Agreement, without recourse and without
representation or warranty of collectibility, or otherwise, except to the extent stated in the
Agreement.
E
xecuted on:
TJDM: M OCR PARTNERS
s Fund, Inc.
By i?n
A By
David RosenbergCEO/ Chairman
For Uni.fund Use ONLY 13
Client # PID CID #
f::? 1b; C
CARD AGREEMENT
ibis Card A,grearnent Mfich incTr<dss your card carrier.
is ;four contract vex h us and governs ,he up- of ,:our card
and acccurft. ih-3 card carrier contwis important acCOLn' t
information, inclt=dTig your arinual percentage rates and :h4
amount cf any membership fee. Flea se read anti F:F? thier=
CUcurnems for your recotes.
FACTS ABOUT RATES AND FEES
For conphe;te infrr ma ion about these facts. please see the
rEtated sections tri th s Card kgl::emant.
RATES-FINANCE CHARGES
Purchase and Cash Advance APRs: See card carrier. An
AFGs based cr. tee Prime Fate mazyr ar mt, balling pedol.
Default APIs:: See crud carrier. The Default APR equals tie
'rime Efate plus up to 23 ?9°'4, or up tr, 23.9995.3, vitid` -; er is
greater. All APRs may automrticatly increase up to the Default
r.FR if you fail to rnal,,e a palmerst to us when due? exceed
.cur oredit line. or make a payn, -nM to us that is not horored.
Minimurn Finance Charge: $0.50.
TRANSACTION FEES--FINANCE CHARGES
Balance Transfer Fee: 3% of each bal4a rce transfer, $5
minimum, $75 maximum.
Purchases Made in a Foreign Currency Fee: 3% of each
purchase after its coirversion into U.S. dolmrs.
Gash Advance Fee: 3% of ewh cash advance, $5 minimum.
OTHER FEES
t00u a ee: S1 5 cm to $259{ $39 Fon balances of P50 and ot;er.e? of
S1
(Wer-the-Credit-dine Fee: S3a.
Annual Mernbership Fee: See card carrier
Returned Payment Fee: S39.
Returned Convenience Check Fee: Sag.
Stop Payment on Convenience Check Fee: Sr9.
Rates, fees, and terms may change: We may oharage the
rates, tees, and a.w,7,s of your account at any tine for arrf
rep-sorr. These reasons nta: W Weld an ornat on in
tour credit report such 2s your failure to make payrnenls to
ancother creditor vfteft due, amounts owed to other creddors,
tt3 weber of credit accounts outstanding, or the number of
credit inquiries, ihece reasons may also inctide crarnpetitive
or market-related factors. If rte make a change for arry of
these reasorts, you will rewire advance notica and a right to
apt cut in accordance ;edi appfir ably lavr.
Definitions
arsavatthe, relationship established tetwteen you and Us tie'
tiis Card Agreement
,4M annual pme•.. qe rate
Quffio!UE useerg =-nv lperson you a `9,N tD use Y11'.3X av?r? it.
card. 3L4L li trt eC.^,°55 deu=ces,
r}t,.. 1e or more CwrCS of other
including arc- ;u ii numbers, :hat we isSue to ye;i to r 4tain
credit under this Card Agreexv;"t
Caard A rssr eat (i?r Gt£?rrr?„i?: mis docutEtent aid, tt-e
,,;rd cariicr.
tile, uF, end Dojo: vttith3n 5c:ln`h 0? N.4., t::e i; :F,- e
your a-=r_*Av'rtL
you, IrDvr. and jtours: t =e person v-;ho applied c open the
her pe son fespr<?sit ill tar ccr?plyi ::i.h
^csun. and a o
c`tls,=.Yrser:?etitr i.hcltiiii tg th5 Dersol to wt-om r.e „ ddrss
`vlli!riy Str..ef?1?ntrs.
Your Account
You arsee to use jour account In accordance ihth VMS
grecm tt This, ;,gre:mant is bincEnq on :?cu uniers ;'ou
ral'^?ryet :'cur account .,11hin 30 day'S 41 6-r rM ig 1le card
r
and trcu hve ncit used or aulboriz,0 use of the card. `'ou
mu„ p-dy us for all amouras due on your c'.CCOunt as 5D_'Csil d
i1 this Agreement. Your accoLsrrt must only be used for lay'tul
trrsarion5.
k,tharized user.. You may aato:v,,au-, W zed user to use
:?c!ir B.`rou. You T re-Kt.est adohtiong ca.ds'.or aUt -.rl E5
users. You musf pay us or alt charges made by authcrted
risers vean if you did not intend to be responsVe for L ose
charges You must notrty us tore eke apy pemisslan you
-e to an aulhorized uses tD °,.1 e a card or io use your acmurt.
Credd l rw. Your ire.dal credi+i line app ars an the card {,anner.
T ne f:i„ zmzurlt of your credit tine is available to buy Or leas'
goods or services where Etta card is honored. Part of your
credit ire, called the cash advance lim is availab a for rash
ad?ences. We may change your credit fine or cash advance
:in t at arnr tirrie for any reason. We vAl tto`fy you of arrd
change. but the change may take effec before you rec:!rg tone
cll. the total taWxs an your a=unt, inalvding ped dic
finance charges and fens, rnust always r6nrtain bet ON, me
c mdt sine. Hmutever. if the total WPM exceeds your vviit
iine you must still pay us. tf your aunt `a a c;vc4
talanu. t; may reduce he ved4 balance by xTf nervy
oharges on your atx;.urr You "nay not rnatn a.in a cred*
5Nance in excess of yotf creoit line.
Rilling Statement our billing statemsrit shows •the total
11 e, j&.ftdrr, aaance charges. fees. ,Tsinimu , amount
dcre, am paymeri cue date. it arcs sfhovvs your current
c-eat line and cash advarce Iitn:R; &l fter:d Est Of urrert
charges. payments and credits: a rate summary; and other
irt?portant e4tormatiart Wre daitrara statement to ontr one
address. You must notify Customer 5enits of a change in
addrrss. If we deem y6L- acft3un- 1, arix-1t5cl,61a cg :nttrtuie
co'!K. ien ]mzceedings by srrding. ft to an outssidc a'`-Rtic",: or
_ttGnn_y for cc-tlection, we may Stop sendila you 5toif <Tte'ltS.
P3ric•dic final a charges and tees rXiniinve t0 arvue v#cr; +t
;:e s cG _anding sia4erner.:s_
-hP total: amount you o . e Us vnlpcar3 25 the h,ew Enall :c:
hs tilfing statement. To deterrinitne the °de':. (afar a we
teain v'itt, the tQial balance zl the stag of if'te b m.. peri
'ce zed 31jr Gjrc; hues or cast: ad .;r.ces aed `u-W, t any
-edfs v payrrents c:editel as of that bitting period. We
u'jcn add 2r ' periQdiC f': zn. cY ch es or feeS and 9Ti'ab:e C=ttl3'
:c ?stm5r-is.
APRs
APRs Based uu Prime: We cd- date a. - APR h-ssed r n th,e
?i.S. Prime Rate ("Prune Rate) by addrino the aaplicabie
arnmir. then appears an the C =d :;rrler io the Prrrne Rate.
For earth billing oui;A ve use trv Prim Rate published
11 Vms HKA ut??? ?uJli?r-4 tU^ineSs days prit,'f to the
St tarnen Closing fate for that biding period. it The Vaal;
Street SL . z1 do- not publish IN Prime Fate. we may
su'ros tote a Simla: published rate. A. charge In an APR due
to a ctanae in the Orlme Rate te€,es One* aS V. the firs( ray.
of the titrRQ period for which %t"e Cal:U6,9 the A?R. `gee 8rN Y
tt,e new aLplic??!a APR w any WLziirag balances, subject to
airRv prornorRanat rate that may apply.
Default Rate: All your A.PFS r;i<, increase if you refauft antler
ar' Cafd +-r;=rnew, that you Lave V& SUS Elise you fat=. to
m6ke a p`ynnerit to us t lien djea. you F.xzeed your credt line.
or ;r;u make a payment to us that is not horsoved. fr.. u g=_?
cir mst=:R s. R'e may automatically increase your APRs
(induding an promotional APRs) on all balances to the
Default APP. which equals the Prime Rate plus up to 23 o.°•t:.
or up to 28.99'0.:vftichever is 4rte Fan rs corsiderad in
dverrnini;ng your Cetault APR r:ay include hash king your
:croup i= teen open, the timing or seriousness of a default
under any Card Agreement that (Du have v th us, or ruler
indications of acceurit per'ormarce. The Ceiault AFF. takes
effect as 0 the fist day of t'ne bi:li;-g period in %vhich you
de cud We may 1uvier the AFR for new phrchases and'or
msh uh s-ices if you mast Me tar= of cll Card Agree cobs
that you h_tia with us for six ctxsnutice biting periods
Existing Shires remain subjW to Ov Ceiaal APR unt,l paid
i'11af.:rnle ss'Re tell you Ctll?rise
Eq. ,ct of APR Increases: If an APR ineress . C'Erisdic
finance ch_2.s increase and;¢ ur nlir•IMU.M pa t e=r<<rra
increase.
parfordic FiftarlcE Charges Based On APRs
Perfodio Finance Charges: PeriCMc finarrr, cfrarps art
1 finite. charges that are add d to your axcur:war+ s+?
r= the applic-Ole APR to tn,102W.C_s cn ;=cur _c:oant. VA,
vjOu ` .
c?"tlatc penodic tiitart Chargx,.. sap e•rarayetb for eac t•alarce
subject to di`tere it :era`s, f yr er„.rn f13. ; zrcard purrases.
st'idard cash ad:'arxes, and e3r11 promotional utter. The iG %.I
psriodic finan:? cttarp foi tote hillirin per Cd -KcUMM tte dalI
^li t;•alanc fu 'r Eech d.; in t iD
x finance charges icy
nj.j 5a ?illlr a period. This methcd of MICUt3ang periodic financx
Ch?SCe$ rresuifs i!1 Galh.= C?rlpiki tdlny of Iln:rir.? ctarvGS.
when Periodic Finance Charges Begin to kccrue: Periodic
;inanse c':i_ras begin t,: accr=.;e on a. Cti ae -'rivl tale daty
it is added to ti d oily tal3'1:e and xrnlinue to _c:;'ue unt'I
py ?mditcd to vo-ur 3,mourt. (Ch revs ir:ctuds
;;ient it fill is ..
urcha`"es, b.lsnre transfers, Cas a:i=; ir1,;Ea Irr0nractiun
. otter fees. a,?"i 3:1-f m?;nurn `i,crr ?;.h,aria.;t i'w c.r
i =
Ll ,old pq-;odc tin;:fr=s chards on purc)asc5
bal2n %e tra'ls'ers; ;hat apipsar vn , ,ur cu.'ent nilirr •cl3 mars
, the NEE. B.lrnce on the last sta in:r, by Ii
if
JM paid todate 01 t'iu statemert 3nJ you pay '•'ox Iles:
{'i 3"t??r". 1'?E ace
lr!?t.
Palm- try 1!,* c,?vrn P.t due do_-? on Cur _ur-ert ,
if '-eau rnBoe a bLiance varsiei; you r•?a be urable u a.-
heriolic inanca char-Es cn new purchases. a,; Jess!ibed an
the 4z!larice transfer o der.
Calculation of Periodic Finance Charges:
For each tatanm we multip, a the cad., talar.c: d tha
applicable &:N :ricd`c rate. tr:'e do tai tor e- h day is tit
;, rF:?
biding pcri"d. i da`} pGriu:l 'i^„ h3 : pplicatie AN
prided by '.65. A billilg ;?rico: hegi is on the d3;; attar the
si? ' . metlrM 1;1,,g "3tC df the are rows bil irg perio=d c'lj
£P,i1?rGS!ny? ?la1e 7f IN nilrrent a:il:ng Gertud.
IeCiUdeS ii :E
+Ta get its caiwy bale.rice. u.e eke tide t-egirmlil'•1 Nul:rice
`o: eac'1 balance "air•f day llrc ding J p3`d pr*bdic inarc£
c`r: arm f; i pi-vicus b ll'•.rrg Fcriads;. add ar; re'•a cha=ps,
anJ any peri,:dre f ra:ice ch::gv on rte pre, i0US Cif-s
Balance, subtract any xedits nr Fasrterrts crF:liled as of ;hat
-ay, and nyeke otter adj;istrrrer713. A cr dif bra anu i; ae. ted
as 8 Ltance of aera.
+ i.;'e add a Ow-3e fo th.!e daily DELncB VIt cad
a purchase to the apprwwe balance as of the Sale "ate
cri'.te t=illTa7 sfatttre:it.ws zed a tmares r:iftr or cas'.i
advalm to the appro-priate taiarce as of the post Gate cn
tli sttiment.'Na add an trans-Won fees for p.ircrases.
balance tiarsfe*s, or cash advarces to tie SWrie batanr:e
as file tranSaclir?'i as ct the same date ft ar$wj3n is
added to ite iai:`y, talan.e. ?lie Post Cate is the data :ire
rt h Safi reclassi for tier valance `P-rrfer or c4Lh advance,
ircladi-?g 3 f°QJr5f t-h"ct,.te Kompl=_i: a tala a trarsfe, :r
cash advgiw camenierce check fcr a sprchic amount. If
soj send a taianse tr3rsfer or c wv? n res check direr Fy
to ,sm-nuon t the Post Die is 'N date .,e++_ re:ei',s the :.h;;;k
for pa;Tnert
Tu pet the tcW periodic tin=e OUC-r, Ve zdd LP _II ct the
daily persodc finance charges for eac ta`:ance for each dw
in the biting period.
. For saclt dance. tte k4axt Sabye:;! iO France Ch me o f
dad;
the >.?tEmert is ilia averet: of the balances duriaa the
5F,Mg period. If you rnultip;y tllsr fic=Y4 for each talanze by
71:
the mmlter of d?;s in the biting , .rlud and ,ry 'Lilt appli"a
dairy oMadic rate, `h3 reset is the periccic finan?er c'"=arces
f r ,he balance, except for rr:ipor .os atiuns muse]
by ridding.
Minimum Finance Charge, I -h_ ,ericdic rte `inance cha,g3
,n=DUId ahersr_se be 13s; than SG -i] -fie asset a mirily1w,
F1.f(ANC4 CHARGE of SG.K. We add 0.i£ amount to ary
bal:rce :h :-t is assesspd a finance chamme.
Transaction Fees
Transaction Fees and APRs: J;:ou are z sawasd c :rzns_cti•'rn
fee for a balance trarsfcr, a pur:;h3se insde in 3 forciail
currency. or a cash , dvmce. the t- m(.-,a:'toI fee ,gill cause
i4FR ar he 511ing stat r dim! art which iha transa :halt
ifl:
5rct appears to eed our norr:lra A?R.
Transaction Fee for Balance Ttansfers; You attain a
balarce i'arister it vcu obtain funds through a hala-me
trcrls.fer c"_ck or iransiar a baler c? a ir; a cash
ad-man-ce mr erirres check. Vie treat J- arce tra:l5fels ale.
pur-d-=ases inless ct:len,.-ise pm' ided in th:s Aj-- rccner;t.
For eat, balance transfer =tie add an addhiom-1 FINANCE
GMRGE of 3`0 of the amount of 111 bal:rc? transfer. M
for less than S5 or more ;Iran 5.
Transaction Fee for Purchases Made in a Foreign Currency:
For eac`i p-L rchase made in a foreign curraxy ve add as
adri fcoat FlRANCE CHARGE cf 3"N6 6f t`s pumtase a-nu!nt
after I cumkrsion into J.S. daJars.
Transaction Fee for Cash Advances: You Wain a Cass
ad varier A you ctUln hinds through a1 a:aeri`t_d Cellar
r;tad' me (KTIA) cum-anisrca check. h; {1i: barkir.9, cr
finazial institution: make a -mm transfer. !yiair a nl.l.e{
orcer.'meveler's d'r0, latiBr. lxt casino c`N.-P, or siileilar
iter , or eatgaQe in a Simi Y. t-ansac oi. For each .:ish
advance .re add an additinal FINANCE CHARGE o; 3F C#
the ar''I'0 11rtt Gs ilt;r C•a5h adr-anse. Wt ;net less thF1) +5.
Other Fees
Lair: ree• 'a`ds Odd a I_:3 tee -.,o The St"rld3.d parCftas° bala'rre
for each tilling pe?iM >r:-U fail to icy, by i+s due d:.te, th-e
Mintrnurl Amount Due Pms the Amount O xr Credit' inn:
a:ct!,n on rouir i Fina statente:ttj. -has Ice rs based on your
shc
co ant baanse as rsf the payn rsnt due date.1 is: S15 cn
balances up to 5100, $29 on balances of $'00 tip to S250.
and Sw9 on balances of 5250 and ov,.-r.
Over-the-Credit-Line Fee!: 4.ra"e ajd F. S29 fee t'a t)e standard
p.-chast balanve if .Poo. r acwurlt balsa:a exceads vnur crRdil
?,en
vane at ,-r. :irt:e Curing the` b'illitirg pcrIoJ. ::e adj t)is -te
if fransactiuns t%rA, auihorize cr periodic Nance char-es, :_es,
anJ r t`t:.r eharoes you incur are a reasan ?he acr-ount b I1--nee
-reeds veur ;,resit 1 ne. Ve add this fSe even if the acCowt
iofan e `a.lh belc,a, your credit Fire by the end of ite t: IH11rr,
ieriod.
hanual Membership Fee:',Aie _dil a:ix ? f p ir"+};1- rrn j
mz: srl7e, ship ee to he stan'd_M p,wchas e ::air l; e. Tats fee i5
?
non-r_{.d'u:iJA-bl sunless yoj notify uS IQ Twicel your a-.coun',t,;tl,in 3401 days of ilie mailing orueli, nc date of tic tiling
staierr 't on v:ht she fee is bill s.
Returned Faym-ent Fee: Y'Ve add a $39 iur. to he standard
Jr ch ads b Janoe it a G;'ncri Gli::ck or siTilar it ldrument is
tt- ' 1_0rorA or is retuned be'cruse it :ar.rot tr., processem. r
i ca. if an auto-matic debit is returrivd unpaid. "he assess ;his fee
the 'first time 'your fih ck or payments not roared. even if
:t is honored upon resubmissicr.
Returned Convenience Chssk Fee: We acid a 539 fee t4 the
crneenienrce
standard adeance to a ice If t.,e decline to io irir P.
chcc?. We rnEy decline to ho n or these check if, to, a)zr P-1 e.
the Lmount ut Me cheep N:ould ca=se the balarcw to exoved
the cash advance Wit or credit line. i, van default, if you d;d
rot comply w th our instructions rergar'Jiri the ctiec?l or if
,our account has been clased_
Stop Payment on Garmniettce Check Fee: We add : S39 fea
to the standard advance ba`ance if .re ha-ror :cur request to
sop payment or, a corrv'eniertce ct ieck. To stop pa;:rr.Tt on
a correenlence tiha k ue vie us at P.O.6ax 64.00. SIOUX Falls,
South Dakota 5'7117, or call the Gustrner Service nLmtt:er on
the billing statement. If you caR, you mast mrifirnr the call in
trritir.g r,i ti 14 days. A wrifien stop pryntent order rarnafps
in effect for 6 months unl>?s rsnekind an fAftlrg.
Balance Transter Cherim and Convenience Cherks: Each
check must be In ne for tt ;it was issued and used acoDrding
t0 :r'?` it $trtjGthons we g1r?. Th8 CGkS Tl St rroi CP
to pay an arnount of rd us under this or anc r Card
Agrevnwnt that YOU :tae'3 .h LS. S do not car if' these
c'rc>z or return MY such d':e t':s :.h Et rave teen parj.
Information on Foreign Currency
Conversion Procedures
f you m7:e a rrstictian in a t3 inn currenc;', o he. ihaa a
cash ad:rarce made a brarc`t ci i?TF?4 of ore of ur affil atss%
Master-Card. s,isa or .'Lmai:cart Express. doper. ro ;,n 'a,h ch
card is usej, cariverts the arrmo?rd into U.S. 'j :l rs as fellows:
MasterCard ccrnpiies sti,t) ifs fo°rigi c:jrr t'rcy ocn? s ion prcce.duras then is cffe . I::';<istetGard Mk , •enit uses
a og'r'e:3.im rate in effect cre ds'; G'+cr to i.3 +t'_!•!€ac-
con prccessia? Gate. Such r-_ts is arthsr a '?: alesal
market rats ort h_ Lovs-nnent-mandated ralp.
Visa Con'.(i!1zs tr iih i`a fcre°r n yr s eilryr c ;rt ers;t r=.
.,
^sihren it _f`?ct.:''isa c?rrer:t;r r: _s C C[?+^:
prociedut? in t ?,.
son rte :n eifact on its applicablzl cen:r:J p:ocassh:g
cats Such r: s R t`!er a rate it S lect5 irrAt "'IS gar':??e
of rates b'd21_h+is in ::I:o:esae aura-r?r; r':t=.rk=1s: :iri:lr
Born ;1t tat, r=..Corve,,, air Ill(;
,.ry Ai-aerir;.n Express voniplies • .,i`h its floteign currc-.1..,
con,ersicr- prilf c lures iiwr, in 5,f cl. urlvss a Larucular
rale is retl0tW by app'ivatle la's:,, the rte user by
rr eftan Express shall be the i-ghes; interbank rate
s3 %1,.-d cn the 1:l si:iess tay pro-, trj ,l a da., o'I':?1i G1
the trait-•actir;r s processed by Ar"rcricMn Evprest.
1
If a cast ad'woe is made in a'areign currencl, at a tranvh
or .;TPA of ore of cur afi4ltrs. the amount is on':?e_ ed into
u
U.S. ubt4rs by t•4r d?rista'w in aci•Grr:ance Mth i:s foreign
curre-icy, 4-on ersisn pmcedums t_i,_n in _fl.;ct. Our aftil_ e
currently uses a conversion rate in etfe : on 1i3 applirabig
pri sing data. Such rte is sitter a n>c-polr?t nait.st ra`3
ort`a gavemment-'i'rndated rate.
Tie Mrelgn cuarenc'g carriers'-.can rate. s& rtrac1 o•i file
appliiczble prodsing dale *.'or a tramxlion I:Uy jiffer `rcn
die raie in eriml on the Sale or P:v et lat3 flit vonr I;1.Il:rig
stateTzent for ihai transaoiaa.
if a vansaction is co'tveried by a third Ciarly prior to suet
transaction b;.inrg pro essed hy MasterUcrc.Visa, or
Arnerticant E.,xxppress, the fnreign ourrenc}i consersir:r. rate `or
that trarsacii-an *314e the rate sere; e:d by tat third party,.
Payrnents
liffinlmum AmoEmt Cue: Each morn you mu;,, ray{ at least
the fhirimum Amount =Due by tie pj rl, Merit due :alts. 7he
soarer you pa;' tie t' ew Salanca. rte less yeupry in
periodic fi lance cnarg=s.
Try calculaie the riininl:Jnt,anoint Due, oe_ 5 ;in :%Ah aril'
past dine amount a-Id add arc amount in xp.*ss of your cmd
lane 46'e then add the largec-t of tl'e fol`rrcalg:
The tlert '*alanc ',in the hill ng z terser., it is less t art
520;
S20 if the ?be.w BaiarrDp is at ieast S21
• 1 % of the idew BaLnce ivVch caleulaticn :s rounded
down to IN nearest orAz,,) plLs the amount G, year
billed finance charges and arry applicable late fse; r,=r
4 1.5% of the Nlevw Csal n:;e ;which calculation is roanded
do 'fn 710111e nearest do la'1.
Ftmvever, tie W.-Trim-um Arnourt Due rower exceeds ti New
Edwlce. In cGlcuiating thie M1nimurr;?rlount ]ue. we na;
subtrnt front the Nm v balance certaisr less addsd to ;-our
2C CJt1'.11. Urlf,j tl'e Galin] pcri d.
Application at Payments: Vie apply p_ nnenis and credits ;o
fur; Lit:: balances before bighei ARR i aian eve Tlr t mhvii;
"our Savinas •:Fi' by r Jed =k y nu Tana ir;i:mi, IOIS tl;at fire
uti:Lt r/icher AF s.
Payment Instructions =';iyn'enis arJ'Jredited in 1 cordanc¢
i i h he ,payment ir-I;>lrliiil r:a 07 tic bhi-17 m --ncnt. You
TL st pay us 11 U.S. dollaiS u5 tr] :i uty;ck, s;ml ar instrr:nent,
or autornatic ,debt tll;;t $ drf?':? run and honored h a 5arik
n the U.S. Cc not send nosh. i"=e r, i ;accept late cr partial
payments. 2nd pd, a+iT13i11S ill; i reflect "pia it full ' or
otter restric?iva endc,rserents, ri.ltri+ Iris±rg our r;ghts.
WE reserve the right to accept pery-ments made in foreign
currency -a-id iostrunte:its drm an on limns on depos t cuslde
tale U-3 If we da, %%re -elect the currency co r: ersicr rats at
our d scretioa and credit voFJr account in U.S. dollars after
deducting any costs inct.r:ed in processing rour payment, Or
,-ve mwy br.l you separzt-ly or such cos a.
Opt anal Pay by Phone Service: You rna;. real Jdsl to ?rKrl e
your peg ant by phons using car npt ore;?I F by ph;i:ty
5eMce. Each time yoJ MI.Ve sJ.?h a i6-l:CSt, you agree to Pay
us the arnount shovin in rite FGy kid: PI-one s%tic-r, cn the
back of the biding statement. Our represenlatiiyes are trained
to tail you this arro:Jnt it ym decide id, use t Nis opfkmal Pay
by Phone sen-rice.
Credit Reporting
Vile n- y report inforTati®r about your account to credit
reporting agencies. Late payments, Hissed pan-,erts. or
other defaults on v ur account msay appsar of I your credit,
report_ If you rarest cards an your ac-Tent for ethers, we
may report account i for,m-atim in ifis narnas of these other
peepie as u:eii, l eve nay aiso cttai l fo?ic+r:-up c-edii -erot`s
on you ,tor example- twh= ?-/8 r irrF VLtr a:c;urt to, a
Credle Il ie incremcfi$I. If You ehsh la P:.II&/ rilll ,?i?.4k: I i; s k,e
co(ftC.ed, tints us at the Cusicner'Ser: rze lid ltess Jn ,rJ
biting statsr='irnt.
If ;.4u think '«re repo:1;,G er• oneCUS i-liD1-rn101 td, ? credit
reF011ing agency=..y7ite us at ti-4e Cus£omer cer0ce address
on ish„ 5_1irt statemert. w.e %011 prom Pty hi est:cate the
maaur and if :tie agrep veth you, 1.rm :A14 c ormact each
credit reporting agency to ar 0 •va rep; rtmd and r'cuest a
001're17;on. If. after cur =rt,r?iiga# an 'e ;a di: agr-_e Afh y 0j,
,aa :will teli.em.n a riting or b to:ephcre and tell you hc4
io sut:m:. 8 staierrient 10 :Iicse nz.r.ciCa fJr 1-71rdis!Cr in ynJr
crecI4 report.
Ctts.rlges W this Agreement
We may change the rates, fees, and lerms of this
Agreement at any time for any reason. These reasons
may be based an information in your credit report, such
as your failure to make payments to anoiher creditor
when due, amounts owed la other creditors, the number
of credit accounts outstanding, or the number of credit
inquiries. These reasons may also include competitive or
market-related factors. Changing tears includes adding,
replacing, or deieling provfsiGnS FeI`af9nQ tU your account
and to the naWre, extent, and enforcement of the rights
and abligations you or>.ve have relating to this Agreement.
These rhanges are binding an you. However, if the change
will cause a tee, rate Or MinlC,lurrl payment to Increase,
we will mail you written notice at least 15 dais before
the beginning of the billing period in which the change
becomes effective. If you do riot agree to the change, you
must notify us in v riting within 25 days after the effective
date of the change and pay us the total balance, either
at eace or under the terms of the unchanged Agreement.
Men we notify you otherwise. ass of the card after the
effective date of the change shall he deemed acceptance
of the new terms, even it the 25 days have not expired.
Defar; it
'Y'ou default rondo his Arreerllyni if you ffl to i ity the
Mlinimurn .1.'rlount Cie b its :lue date: -Meedf y6ur Credit
iins: pEy b a check or similar r-Mrne li t'>af is au,t snared
or that &e mtsl rslum hen a ii c<`pmt be p'C1GN?'aR?; ?Vy
by auto=cratic detit that i'a rGturged. unpa'd. file `er bankniptcy:
or defeat ur:der a!rs other Card, Agr ern rent that _::,u have us. If ycu Matill,4 mall close your actm. at and den•rrd
'sr m6ale p=ayrnont Gf the total balance. if;o=u gage us a
security Mte.est in a Ccrtific, = of De a-BI IS Taff Jse the
deposit wrount to pay ary incunt you owe.
VERIFICATION
I, Michael F. Ratchford, attorney for Plaintiff, Commonwealth Financial Systems, Inc, am
fully familiar with the facts set forth in the within Complaint and am authorized to make this
Verification on behalf of Plaintiff. I Verify that the facts set forth in the within allegations are
true and correct to the best of my knowledge, knowing that any false statements are punishable
by law pursuant to 18 C.S.A. 4904.
LAW OFFICES
E.. mnn A. ABMMMSEN
ASSOCIATES, P. C.
1729 Pittston Avenue • Scranton, PA 18505
'lull Free: 1-800-503-1665 Phone: 570-558-5510 Fax: 570-558-5511
December 17, 2007
Cumberland County Sheriffs
1 Court House Sq.
Carlisle, PA 17013
Re: Commonwealth Financial Systems, Inc vs. HEATHER S ROSE
Our file Nos.: 07-00463
Dear Sheriff:
In regard to the above-noted matter, enclosed please find the following:
1. A true and correct copy of the Complaint;
2. The completed form for service;
3. A check for service;
4. A self-addressed return envelope for the return of service.
Please serve the named defendant in accordance with the County Rules of Civil
Procedure. If you should have any questions or concerns, please do not hesitate to call me at
(570) 558-5510.
The defendants address is : HEATHER S ROSE 2117 PRINCETON AVE APT2 CAMP
HILL PA 17011
Thank you for your attention to this matter.
Edwin A. sen & Associat P.C.
Michael F. Ratchfo s uire
mratchfordna,e com
Enclosures
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COMMONWEALTH OF PENNSYLVANIA
Mag. Dist. No.:
09-1-02
NOTICE OF JUDGMENTR RANSCRIPT
CIVIL CASE
PLAINTIFF: NAME and ADDRESS
rCOMMO]Ri18ALTH FINANCIAL SYSTEMS, INd
120 N EBYSZR AVE
SCRANTON, PA 18504
L J
VS.
DEFENDANT: NAME and ADDRESS
r-ROOZ, HEATHER S
2117 PRINCETON AVE APT/STE 2
CAMP HILL, PA 17011
L J
Docket No.: CV-0000324-07
Date Filed: 9/12/07
MDJ Name: Hon.
ROBERT Y. MANLOVE
Address: 1901 STATE ST
CAMP HILL, PA
Telephone: (717 ) 761-0583 17011-0000
ATTORNEY FOR PLAINTIFF :
SCOTT J. BEST
120 N SEYSER AVE
SCRANTON, PA 18504
THIS IS TO NOTIFY YOU THAT:
Judgment: DEFAULT .JODt LB#RT D$F.
- (Date of-Judgment)
® Judgment was entered for: (Name) RASE, HEATHER S
12/03/07
® Judgment was entered against: (Nam eO) COI?ONiiBAI'TS FINANCIAL SYSTEMS
in the amount of $
F1 Defendants are jointly and severally liable.
Damages will be assessed on Date & Time
This case dismissed without prejudice.
Amount of Judgment Subject to Attachment/42 Pa.C.S. § 8127
F] Portion of Judgment for physical damages arising out of
residential lease $
Amount of Judgment $ .00
0
Judgment Costs $
00
Interest on Judgment $ .
Attorney Fees $ •
Total $ .00
Post Judgment Credits $
Post Judgment Costs $
Certified Judgment Total $
ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE
OF APPEAL WITH THE PROTHONOTARY/CLERK OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. YOU
MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENT/TRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL.
EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR MAGISTERIAL DISTRICT JUDGES, IF THE
JUDGMENT HOLDER ELECTS TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUST
COME FROM THE COURT OF COMMON PLEAS AND NO FURTHER PROCESS MAY BE ISSUED BY THE MAGISTERIAL DISTRICT JUDGE.
UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS, ANYONE INTERESTED IN THE JUDGMENT MAY FILE
A REQUEST FOR ENTRY OF SATISFACTION WITH THE MAGISTERIAL DISTRICT JUDGE IF THE JUDGMENT DEBTOR PAYS IN FULL,
SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT.
1
{ Date
I certify that this is a true arid cofrect copy of tf?e record of the pro
Date 1. F .
My commission expires first Monday of January, 2012
AOPC 315-07
t,
Mp u
Magisterial District Judge
q.t4ining the judgment.
:K .
,Wgtster al;rtDistrict Judge
n? u SEAL
DATE PRINTED: 12/03/07 10:36:00 AN
AV A- 4
PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO PILE COMPLAINT
(This proof of service MUST BE FILED WITHIN TEN (10) DAYS AFTER filing the notice of appeal. Check applicable boxes)
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF_..&11 l ll 4_?.!_...........
AFFIDAVIT: l hereby swear or affirm that I served
?/C1,?i -Ter m
a copy of the Notice of Appeal, Common Pleas No ? ? upon the Dis ict Justice designated therein on
date of service) C....._ _- ......._. v ..: b personal sekk? (certified) (registered) mail, sender's
S on
receipt attached hereto, and upon the appellee, (name), _
V+ ? by personal service y (certified) (registered) mail, senders receipt attached hereto.
® and further that I served the Rule to File a Complaint accompanying the above Notice of Appeal upon the appellee(s) to
rrhorn the Rule was addressed an__ t 9
personal service [:] by (certified) (registered)
mail, sender's receipt attached hereto. If
SWORN (AFFIRMED) ANJD SUBSCR D BEFORE ME
THIS,- ? AY OF I?CQ M 'W1
Signature of affianf
was made
77777-of
- NOTAR?AL SLAL
My co im on expir*tjj*RE LpEH , 19
NoiarY rukj- NA COUNTY
CIN OF SCRANTON, LACKAWAN
MY Commission Expires (v1ar ?_, 2009
NOTICE OF APPEAL
COMMONWEALTH OF PENNSYLVANIA
C0 7T OF COMMON FILE S FROM FI led )vIca
4Jl7IIIC1/CL,D(StR C?
DISTRICT JUSTICE JUDGMENT
COMMON PLEAS No. 07 _ ,7JT 9Q 1 ;yi # M
NOTICE OF APPEAL
Notice is given that the appellant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the I rict Justice
on the date and in the case mentioned below.
NAG. DIST. NO. OR NAME OF D.J.
- "
``
l
E4
v)e 6q- -GZ.
-
ADDRE OF APPELLANT
STATE
DATE OF JUDGMENT IN THE CASE OF %8%Iif%fIJ - (D.Wd-f)
I r vs.
CLAIM rp.
Cv19 '2y- SI NA R OF ELL NT OR OR Y R ADEN
LT 19 1
This block will be signed ONLY when this notation is requir under Pa.
If appellant s laimant (see Pa
R.C.RJ.P. No. 10086.
This Notice of Appeal, when received by the District Justice, will operate as No. 1001 in action before District
a SUPERSEDEAS to the judgment for possession in this case. MUS 1LE A' COMPLAINT within
da after filing his NOTICE of APPEAL.
Signature of Prothonotary or Deputy
i.C.P.J.P.
stice, he
fnty (20)
PRAECIPE TO ENTER RULE TO FILE COMPLAIN' TA-MD, TO FILE
(This section of form to be used ONLY when appellant was DEFENDANT (see Pa. R.C.P.J.P. No. 1001(7) in action before I rict Justice.
IF NOT USED, detach from copy of notice of appeal to be served upon appellee).
PRAECIPE: To Prothonotary
Enter rule upon
(Common Pleas No.
, appellee(s), to file a complain this appeal
Name of appellee(s)
) within twenty (20) days after service of rule or suffer entry of judgme )f non pros.
Signature of appellant or his rney or agent
RULE: To
Name of appellee(s)
, appellee(s)
(1) You are notified that a rule is hereby entered upon you to file a complaint in this appeal within twenty (20) days of the date of
service of this rule upon you by personal service or by certified or registered mail
(2) If you do not file a complaint within this time, a JUDGMENT OR NON PROS WILL BE ENTEkED- AGAINST YOU.
(3) The date of service of this rule if service was by mail is the date of mailing.
Date
AOPC 312-90
.19
Signature of Proth 'ary or Deputy
COURT FILE
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SHERIFF'S RETURN - REGULAR
CASE NO: 2007-07599 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
COMMONWEALTH FINANCIAL SYSTEMS
VS
ROSE HEATHER S
GERALD WORTHINGTON , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
ROSE HEATHER the
DEFENDANT , at 2045:00 HOURS, on the 10th day of January , 2008
at 59 VILLAGE COURT
MECHANICSBURG, PA 17055
HEATHER S ROSE
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
Service
Affidavit
Surcharge
Q,., ,fi/oy
So Answers:
18.00
24.96 .? . ? ?
.00
10.00 R. Thomas Kline
.00
52.96 01/11/2008
EDWIN ABRAHAMSEN
Sworn and Subscibed to
before me this
of
By.
day Deputy S iff
A. D.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Commonwealth Financial Systems, Inc
120 N. Keyser Ave.
Scranton, PA 18504
Plaintiff
vs.
Heather S. Rose
59 Village Court
Mechanicsburg, PA 17050
Defendant
CIVIL ACTION
NO: 07-7599 Civil Term
PRAECIPE TO ENTER AN APPEARANCE
To the Prothonotary of Cumberland County:
Please enter my appearance as attorney of record for Heather Rose, 59
Village Court, Mechanicsburg, PA 17050 in the above captioned case.
Anthony B. Andre eski, Esquire
317 Erford Road
Camp Hill, PA 17011
717-433-4191
I.D. No. 88995
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