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Home My WebLink About08-1707/' IN THE COURT OIF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CASE NUMBER: CV-08- % 70 ~! C'.ccn.~ ~~•-~. ACC, LLC Vs RACHELLESYBRANDT Defendant(s) Plaintiff(s) TYPE OF PLEADING: Judgment CIVIL DIVISION CLASSIFICATION: Civil Actions FILED ON BEHALF OF: American Credit Collection LLC Name of Party- Indicate Plaintiff or Defendant Name, Address and Telephone (X) Counsel of Recorded Marjorie DeSanto Barlow. Esquire ,(Attorney for ACC. LCCI PA I.D # 28207 DeSanto & Barlow, P.C. 400 Spruce Street, Suite 301 Scranton, PA 18503 (866) 760-6205 ~3~~ii~1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF CIVIL DIVISION AMERICAN CREDIT COLLECTIONS, LLC P.O. Box 264 Taylor, PA 18517 vs. DEFENDANT RACHELLESYBRANDT 70 Station RD Newville, PA 17241-9516 NO.: 08-CV- l 70 7 l.lvt ~ ~~,~-, COMPLAINT IN CIVIL ACTION FILED ON BEHALF OF PLAINTIFF ATTORNEY OF RECORD OF THIS PARTY: Marjorie DeSanto Barlow, Esquire PA I.D # 28207 DeSanto & Barlow, P.C. 400 Spruce Street, Suite 301 Scranton, PA 18503 (866) 760-6205 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PLAINTIFF AMERICAN CREDIT COLLECTIONS, LLC P.O. Box 264 Taylor, PA 18517 vs. DEFENDANT RACHELLE SYBRANDT 70 Station RD Newville, PA 17241-9516 NO.: 08-CV- COMPLAINT 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 obligations 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 maybe 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 ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. NORTHPENN LEGAL PENNSYLVANIA REFERRAL SERVICE 65 Elizabeth Ave. Ste 800 PA Bar Association Bethlehem, PA 18018 P.O. Box 186 ((800) 982-4387 Harrisburg, PA 17180 (800) 692-7375 AMERICAN CREDIT COLLECTIONS, LLC: P.O. BOX 264 TAYLOR, PA 18517 PLAINTIFF VS. RACHELLE SYBRANDT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL DIVISION 70 Station RD DOCKET NO. 08-CV - /7Q ~ Chid ~~,.,,,,, Newville, PA 17241-9516 DEFENDANT COMPLAINT NOW COMES, the plaintiff by and through its Attorney, Marjorie DeSanto Barlow, Esquire and hereby complains as follows: 1. The Plaintiff is AMERICAN CREDIT COLLCTIONS, LLC, a Pennsylvania Corporation with offices located at P.O. Box 264, Taylor, Lackawanna County, Pennsylvania. 2. The defendant is RACHELLE SYBRANDT competent individual, who is a citizen of the United States and who currently resides at 70 Station RD, Newville, Cumberland County, Pennsylvania. 3. Defendant received a credit card with CITI BANK bearing the account number (5424180389651628). 4. Defendant made use of said credit card and has a current balance due of Twenty-Seven Thousand Nine Hundred and Seventy-Two Dollars and Fifty Cents ($27,972.50) as of February 19, 2008. 5. Defendant is in default by failing to make monthly payments when due. As such, the entire balance is immediately due and payable to Plaintiff. 6. Plaintiff is entitled to the addition of interest at the rate of 25.740% per annum on the unpaid balance from February 19, 2008. (A copy of Plaintiff's STATEMENT is attached hereto, marked as Exhibit "1" and made a part hereof). 7. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed and/or refused to pay the balance due to Plaintiff. Wherefore, the Plaintiff, AMERICAN CREDIT COLLECTIONS, LLC, prays for judgment in its favor and against Defendant, RACHELLE SYBRANDT, individually, in the amount of Twenty-Seven Thousand Nine Hundred and Seventy-Two Dollars and Fifty Cents ($27,972.50) with continuing interest thereon at the rate of 25.740% per annum from February 19, 2008 plus costs. ~l~E oC,~~k~f~ /~ MarJorle DeSanto Barlow, Esquire PA I.D # 28207 DeSanto & Barlow, P.C. 400 Spruce Street, Suite 301 Scranton, PA 18503 (866) 760-6205 This law firm is a debt collector attempting to collect this debt for our client and any information obtained will be used for that purpose. VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA. C.S. 4904 relating to unsworn falsifications to authorities, that she is MARJORIE DESANTO BARLOW, ESQUIRE authorized agent of AMERICAN CREDIT COLLECTIONS, LLC, Plaintiff herein that she is duly authorized to make this verification, and that the facts set forth in the foregoing Complaint are true and correct to the best of her knowledge, information and belief. MARJ DESANTO BARLOW, ESQUIRE ATTORNEY FOR PLAINTIFF S~ ~. ~. ~. ~ ~ ~ ~ rv ~ ~ r.),~_ .,,` ~' L , °Q ~ o ~a ' ~ ~ -~. 1~- ~ C~ -C ~~ E ~,. T ~-"