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HomeMy WebLinkAbout04-0335 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLV ANlA CIVIL DIVISION CREDIGY RECEIVABLES, INC. SUCCESSOR IN INTEREST TO FlRST SELECT, INC. Plaintiff Y8. MARTHA MILLER Defendant No. 04 - .Jd.,5 C;(.>'~l ~~ COMPLAINT IN CIVIL ACTION FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: WILLIAM T. MOLCZAN, ESQUIRE PA l.D.#47437 Weltman, Weinberg & Reis Co., L.P.A. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh,PA ]5219 (412) 434-7955 WWR#02583700 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CREDIGY RECEIVABLES, INC. SUCCESSOR IN INTEREST TO FlRST SELECT, INe. Plaintiff vs. Civil Action No. MARTHA MILLER Defendant COMPLAINT IN CIVIL ACTION AND 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 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 LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE,PA 17013 (717) 249-3] 66 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA CIVIL DIVISION CREDIGY RECEIVABLES, INC. SUCCESSOR IN INTEREST TO FIRST SELECT, INC. Plaintiff vs. Civil Action No. 04 ~ (ll~L1EAJ; MARTHA MILLER Defendant COMPLAINT AND NOW COMES, Plaintiff, Credigy Receivables, Inc., successor in interest to First Select, Inc., by and through its counsel, WELTMAN, WEINBERG & RBIS, CO., LP A, and hereby files this Complaint against Defendant, Marhta Miller, and, in support thereof, Plaintiff avers as follows: I. The Plaintiff, Credigy Receivables, Inc., successor in interest to First Select, Inc., is a corporation with its principal place of business located at Two Sun Court, Suite 450, Norcross, GA 30092. 2. Plaintiffis the owner of this account, which is the subject matter of this action. 3. Defendant is an adult individual residing at 9 North 2nd Street, Apt. 2, Lemoyne, Pennsylvania, ] 7043. 4. Defendant requested the account and made use of said account and has currently a balance due and owing to Plaintiff, as ofJanuary 12, 2004, in the amount of$2,221.14. 5. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed and/or refused to pay the balance. WHEREFORE, Plaintiff demands Judgment in its favor and against Defendant, Marhta Miller individually, in the amount of$2,221.14 with finance charges thereon at the rate of 6% per annum from January 12, 2004, plus costs. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED SHALL BE USED FOR THAT PURPOSE. WELTMAN, WEINBERG & REIS, CO., L.P.A. I '//~/R/ ~ /f/?"\..' I ./A~i-~/" :4- WILLIAM T. MOLCZ , ESQUIRE PA LD.#47437 Weltman, Weinberg & Reis Co., L.P.A. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#: 02583700 VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA..C.S. i4904 relating to unSW011l falsifications to authOlities, that he/she is {\j aAC'.--,,\ (~a sd-) (\ A V(Name) _ t\jS+. /)f?i'f'.vf;-urr/!. of (;ru./q Vj Re~(\0?.k6'.f pt~plaintiffherein, that (Title) J (~ofupany) he/she is duly authorized to make this Verification, and that the facts set forth in the foregoing Complaint in Complaint are true and con-ect to the best of his/her knowledge, infoDnation and belief. (S~- 4/~ WWR# (SL ~7ieO _.."--_..._..,_.,..._"._-~"..-,.~" fJ () 'Ig. it- 1 .~ 1:. ~ ~ \'"....) - 1 ~ ~ ~ r ~ '-Z.. " ,,' " Gel) L_ ::"! r'" -~ ,- ,,;\ ~-' "\ , SHERIFF'S RETURN - REGULAR CASE NO: 2004-00335 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CREDIGY RECEIVABLES INC VS MILLER MARTHA RONALD HOOVER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon MILLER MARTHA the DEFENDANT , at 1128:00 HOURS, on the 28th day of January , 2004 at 9 NORTH 2ND STREET APT 2 WORMLEYSBURG, PA 17043 by handing to MARTHA MILLER 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 So AnS?~~ 18.00 11.04 .00 10.00 .00 39.04 R. Thomas Kline 01/29/2004 WELTMAN WEINBERG REIS Sworn and Subscribed to before By: ,-~) / ,,/ . ~ <.- ~),<.ri.~.!~' ;:".' " ;:G.;.~./ Deputy Sheri"l'f me this do ~ day of 9AA~ J(}f)'f / A.D. - Q )-vu l.'''', A ./ P othonotary ) ~ , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CREDIGY RECEIVABLES INC. Plaintiff No. : -04-335-CIVIL TERM vs. PRAECIPE FOR SATISFACTION OF JUDGMENT MARTHA L MILLER Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan, Esquire PA. 1.0.#47437 WELTMAN, WEINBERG & REIS CO., LPA 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#02583700 ~ IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CREDIGY RECEIVABLES INC. Plaintiff vs. Civil Action No. : -04-335-CIVIL TERM MARTHA L MILLER Defendant PRAECIPE FOR SATISFACTION OF JUDGMENT At the request of the undersigned attorneys for the Plaintiff, you are directed to satisfy the above-captioned Judgment. WELTMAN, WEINBERG & REIS CO., L.PA By: William T. Molczan, Es PA. I.D.#47437 WELTMAN, WEINBERG & REIS CO, LPA 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 I/VWR #02583700 Sworn to and sUbiqribed before me this I y f April, 06 " \ ""'1 L.,.~__ ': "JL'~j ...~':/)