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Home My WebLink About04-0753IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CACV OF COLORADO, LLC Plaintiff VS. THOMAS W. REED AND JULIA I. REED Defendant COMPLAINT IN CIVIL ACTION FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan, Esquire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#03224356 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CWIL DIVISION CACV OF COLORADO, LLC Plaintiff VS. THOMAS W. REED AND JULIA I. REED Defendant Civil Action No. ~q- "/'~'.~ 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 dcfenses 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) 249-3166 COMPLAINT Plaintiff is a corporation with offices in 370 17th Street, Suite 5000, Denver, CO 80202. 2. Defendants am adult individuals residing at 1311 High Street, Boiling Springs, PA 17007. 3. Defendants applied for and received a credit card issued by Plaintiff bearing the account number 5437-0003-1199-3051. A true and correct copy of the Application is attached hereto, marked as Exhibit "i" and made a part hereof. 4. Defendants made use of said credit card and has currently a balance due and owing to Plaintiff, as of December 23, 2003, in the amount of $5,138.69. 5. Defendants are in default of the terms of the cardholder Agreement having not made monthly payments to Plaintiff thereby rendering the entire balance immediately due and payable. 6. Plaintiff avers that the Cardholder Agreement between the parties provides that Plaintiff is entitled to the addition of finance charges at the rate of 23.90% per annum on the unpaid balance. 7. Although repeatedly requested to do so by Plaintiff, Defendants have willfully failed and/or refused to pay the principal balance, finance charges or any part thereof to Plaintiff. WHEREFORE, Plaintiff demands Judgment in its favor and against Defendants, Thomas W. Reed and Julia I. Reed jointly and severally, in the amount of $5,138.69 with continuing finance charges thereon at the rate of 23.90% per annum from December 23, 2003 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. William T. Molczan, Es,~/fire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#:03224356 12/11/2003 12:07 FA~ 303 376 2094 COLLECT A~ERICA '( [°~t ~0 947-3300 ' ~ on~-~d ~ ~b~te:f~t~. ~ ~~,,~: $3,000 ~ Inv~$at~oa N~ber: ~ R615966264 . Thomas ~. Reed 1}11 Rt~h St, Boiling Spriz~s, PA 17007-9676 002/002 EXHIBIT VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA. C.S. 4904 relating to unsworn falsifications to authorities, that he/she is (NAME) (TITLE) of o¢' oo~-~,'~o, ~--~, plaintiff herein, that (COMPANY) he/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 his/her knowledge, information and belief. (SIGNATURE) WWR# 03224356 SHERIFF'S RETURN CASE NO: 2004-00753 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CACV OF COLORADO LLC VS REED THOMAS W ET AL - REGULAR GERALD WORTHINGTON Cumberland County, Pennsylvania, says, the within COMPLAINT & NOTICE REED THOMAS W DEFENDANT at 2010:00 HOURS, at 1311 HIGH STREET BOILING SPRINGS, PA 17007 THOMAS W REED 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 26th day of February , __ together with by handing to 2004 and at the same Eime directing His attention to the contents thereof. Sheriff's Costs: Docketing 18 Service 4 Affidavit Surcharge 10 32 So Answers: ~ O0 O0 R. Thomas Kline O0 83 02/27/2004 WELTMAN WEINBERG REIS Sworn and Subscribed to before me this ~/~ day of SHERIFFIS CASE NO: 2004-00753 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CACV OF COLORADO LLC VS REED THOMAS W ET AL RETURN - REGULAR 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 REED JULIA I DEFEND~lqT , at 2010:00 at 1311 HIGH STREET BOILING SPRINGS, PA 17007 THOMAS W REED, HUSBAND a true and attested copy of the HOURS, on the 26th day of February , 2004 by handing to COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service .00 Affidavit .00 Surcharge 10.00 .00 16.00 Sworn and Subscribed to before me this ~,~C day of ~}1~ ~6~3~ A.D. / ! Prothonotary So Answers: R. Thomas Kline 02/27/2004 WELTMAN WEINBERG REIS Deput~~ IN THE C, OURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CACV OF COLORADO, LCC Plaintiff VS. THOMAS W REED AND JULIA F REED Defendant No. 04-753 CWIL PRAECIPE TO SETTLE, DISCONTINUE & END FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molc:zan, Esquire PA. I.D.#47437 WELTMAN, WE1NBERG & REIS CO., L.P.A. 2718 Koppers Bnilding 436 Seventh Aw~nue Pittsburgh, PA 15219 (412) 434-7955 WWR#03224356 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CWIL DIVISION CACV OF COLORADO, LCC Plaintiff vs. Civil Action No. 04-753 CIViL THOMAS W REED AND J UL1A F REED Defendant PRAECIPE TO SETTLE DISCONTINUE AND END TO THEPROTHONOTARY OFCOUNTY: Please kindly Settle Discontinue and End the above captioned matter upon the records of the Court and mark the cost paid. My Commis.,~ E~'~:re,~ duly 15, 20 Sworn to and sub..~ribjed Before me the (-~ f Da~Apr~ NOTARY PUBLIC WELTMAN, WEINBERG & REIS CO., L.P.A. ! William T.VMolczan, Esqu~l~ PA. I.D.g47437 WELTMAN, WE1NBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#03224356 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA CIVIL DIVISION CACV OF COLORADO, LCC Plaintiff VS. THOMAS W REED AND JULIA F REED Defendant No. 04-753 CIVIL PRAECIPE TO SETTLE, DISCONTINUE & END FILED ON BEE[ALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan, Esquire PA. LD.#47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#03224356