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Home My WebLink About04-1107IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION ASSETS ADVANTAGE, INC., ASSIGNEE OF FLEET BANK Plaintiff VS. GARY L. BUPP Defendant - its? COMPLAINT IN CIVIL ACTION FILED ON BEHALF OF Plaimiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan, Esquire PA I.D. #47437 WELTMAN, WE1NBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434~7955 WWR#03039110 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION ASSETS ADVANTAGE, INC., ASSIGNEE OF FLEET BANK Plaintiff VS. GARY L. BUPP Defendant Civil Action No. (2)1.4 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 cottrt 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) 249-3166 TX 77074. COMPLAINT Plaintiff is a corporation with offices in 7322 Southwest Freeway, Suite 1600, Houston, 2. Defendant is an adult individual residing at 348 Maple Lane, Carlisle, PA 17013. 3. Defendant applied for and received a credit card issued by Plaintiffs assignor bearing the account number 4326820000008722. 4. Defendant made use of said credit card and has currently a balance due and owing to Plaintiff, as of September 10, 2001, in the amount of $6,376.94. A true and correct copy of Plaintiff's Statement of Account is attached hereto, marked as Exhibit "1" and made a part hereof. 5. Defendant is in default oft. he 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 28.82% per annum on the unpaid balance. 7. Although repeatedly requested to do so by Plaintiff, Defendant has 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 Defendant, Gary L. Bupp individually, in the amount of $6,376.94 with continuing finance charges thereon at the rate of 28.82% per anmm~ from September 10, 2001 plus costs. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED SHALL BE USED FOR THAT PURPOSE. WELTMAN, WE1NBERG & REIS, CO., L.P.A. WELTMAN, WEINBERG & REIS CO., 2718 Koppers Building L.P.A. 436 Seventh Avenue Pittsburgh, PA 1-5219 (412) 434-7955 WWR#:03039110 Fleet FLEET CREDIT CARD SERVrCE POBOX15368 WILMINGTON DE 19886-5368 GARY L BUPP 348 MAPLE LANE CARLISLE PA 17013-7822 !170137922487t 4326820000008722 0637694 0357394 ACCOUNTSUMMARYFOR GARY L BUPP ^~=o~t.=b.,= 4326 8200 0000 8722 Fleet PAYMENT INFORMATION pLEASE CALL US IMMEDIATELY AT 1-8~C-544-2028 YOUR ACCOUNT IS PAST DUE yOUR ACCOUNT IS CURRENTLY CLOSED 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) b)('l~F~)r {~- ~2>~J"E~5';0¢~ of [ ~'~-~ '~l'fl0,J'~(~ i~],~J"l/l~j~, plaintiff herein, that (TITLE~ (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. WWR# 03039110 SHERIFF'S RETURN - CASE NO: 2004-01107 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ASSETS ADVANTAGE INC VS BUPP GARY L REGULAR BRYAN WARD , Cumberland County, Pennsylvania, says, the within NOTICE BUPP GARY L DEFENDANT at 0009:23 HOURS, at 348 MAPLE LANE CARLISLE, PA 17013 GARY L. BUPP a true and attested copy of NOTICE COMPLAINT Sheriff or Deputy Sheriff of who being duly sworn according to law, was served upon the on the 25th day of March , 2004 by handing to together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 3.45 Affidavit .00 Surcharge 10.00 .00 31.45 Sworn and Subscribed to before me this /~ ~ day of a~,~ A.D. Prothonotary ' So Answers: R. Thomas Kline 03/26/2004 WELTMAN, WEINBERG & REIS By: Sheriff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION ASSET ADVANTAGE, INC. ASSIGNEE OF FLEET BANK Plaintiff VS. GARY L. BUPP Defendant No. 04-1107 CIVIL PRAECIPE FOR DEFAULT JUDGMENT 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#03039110 THIS LAW FIRM IS ATTEMPTING TO COLLECT THIS DEBT FOR ITS CLIENT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION ASSET ADVANTAGE, INC. ASSIGNEE OF FLEET BANK Plaintiff VS. GARY L. BUPP Defendant Civil Action No. 04-1107 CIVIL PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter Judgment against the Defendant, Gary L. Bupp, above named, in the default of an Answer, in the amount of $7,570.27 computed as follows: Amount claimed in Complaint $6,376.94 Interest from September 10, 2001 to May 4, 2004 at the contract interest rate of 28.82% per annum $1,193.33 TOTAL $7,570.27 I hereby certify that appropriate Notices of Default, as attached have been mailed in accordance with PA R.C.P. 237.1 on the dates indicated on the Notices. WELTMAN, WEINBERG & REIS CO., L.P.A. WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#03039110 Plaintiff's address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7~' Avenue, Pittsburgh, PA 15219 And that the last known address of the Defendant is: 348 Maple Lane, Carlisle, PA 17013. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION ASSETS ADVANTAGE, INC., ASSIGNEE OF FLEET BANK Plaintiff VS. GARY L. BUPP Defendant TO: GARY b BUPP 348 MAPLE LANE CARLISLE, PA 17013 Civil Action No. 04-1107 CIVIL IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TQ A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 WELTMAN, WEINBERG & REIS CO., LP.A. William T. Molczan PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., LP.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR #03039110 VERIFICATION The undersigned does hereby verify subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities, that the parties against whom Judgment is to be entered according to the Praecipe attached are not members of the Armed Forces of the United States or any other military or non-military service covered by the Soldiers and Sailors Civil Relief Act of 1940. The undersigned further states that the information is true and correct to the best of the undersigned's knowledge and belief and upon information received from others. WELTMAN, W EiN B,~ERG~ PA I.D. ~-7437 WELTMAN, WEINBERG & RI.~IS CO., L,P.A. 2716 koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#03039110 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION ASSET ADVANTAGE, INC. ASSIGNEE OF FLEET BANK Plaintiff VS, GARY L. BUPP Defendant Gary L Bupp 348 Maple Lane Carlisle, PA 17013 Civil Action No. 04-1107 CIVIL NOTICE OFJUDGMENTOR ORDER TO: ( ) Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the following Order 9rJa~dgmept was entered against you on "t ~-~ /(2, ~.-C. JO~ (xx) Assumpsit Judgment in the amount of $7,570.27 plus costs. ( ) Trespass Judgment in the amount of $ plus costs. ( ) If not satisfied within sixty (60) days, your motor vehicle operator's license and/or registration will be suspended by the Department of Transportation. Bureau of Traffic Safety, Harrisburg, PA. (xx) Entry of Judgment of ( ) Court Order ( ) Non-Pros ( ) Confession (xx) Default ( ) Verdict ( ) Arbitration Award Prothon. qtary - ,-~ PROTHONOTARY (OR DEPUTY)