HomeMy WebLinkAbout04-1303IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CREDIGY RECEIVABLES, INC. SUCCESSOR 1N
INTEREST TO FIRST SELECT, INC.
Plaintiff
VS.
ROBERT K. STAZ
Defendant
COMPLAINT IN CWIL 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 Bldg.
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR#02648026
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CWIL DIVISION
CREDIGY RECEIVABLES, INC. SUCCESSOR IN
iNTEREST TO FIRST SELECT, INC.
Plaintiff
VS.
ROBERT K. STAZ
Defendant
Civil Action No. Oq -- l.~
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 tbllowing 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 Pail 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
iN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CREDIGY RECEIVABLES, INC. SUCCESSOR IN
INTEREST TO FIRST SELECT, INC.
Plaintiff
VS.
ROBERT K. STAZ
Defendant
Civil Action No.
COMPLAINT
AND NOW COMES, Plaintiff, Credigy Receivables, Inc., successor in interest to First Select,
Inc., by and through its counsel, WELTMAN, WE1NBERG & REIS, CO., LPA., and hereby files this
Complaint against Defendant, Robert K. Staz, and, in support thereof, Plaintiff avers as follows:
1. 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. Plaintiff is the owner of this account, which is the subject matter of this action.
3. Defendant is an adult individual residing at 919 Country Club Road, Camp Hill.
Pennsylvania, 17011.
4. Defendant requested the account and made use of said account and has currently a balance
due and owing to Plaintiff, as of January 12, 2004, in the amount of $5,378.71 .
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, Robert K. Staz
individually, in the amount of $5,378.71 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.
· LCZAN/,LrSQUIRE
PA I.D.#47437
Weltman, Weinberg & Reis Co., L.P.A.
2718 Koppers Bldg.
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR#: 02648026
VERIFICATION
The undersigned does hereby verify subject to the penalties of 18 PA,C.S. 14904 relating
to unswom falsifications to authorities, that he/she is
~ ' ~)(~ ~ O}O")X'~ ¢ ~m~n (Name)
~ ~65o. r~C.& -, of f , plaintiff herein, that
(Title) any)
be/sbe is duly authorized to make this Verification, and that the facts set forth in the foregoing
Complaint are tree and correct to the best of his/her knowledge, information and belief.
(Signature)
SHERIFF'S RETURN - REGULAR
CASE NO: 2004-01303 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
CREDIGY RECEIVABLES INC
VS
STAZ ROBERT K
ROBERT BITNER
Cumberland County, Pennsylvania,
says, the within COMPLAINT & NOTICE
STAZ ROBERT K
DEFENDANT , at 1949:00 HOURS,
at 919 COUNTRY CLUB ROAD
CAMP HILL, PA 17011
ROBERT STAZ
a true and attested copy of COMPLAINT & NOTICE
Sheriff or Deputy Sheriff of
who being duly sworn according to law,
was served upon
on the 29th day of March
by handing to
the
, 2004
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing 18.00
Service 10.35
Affidavit .00
Surcharge 10.00
.00
38.35
Sworn and Subscribed to before
me this ~ day of
%o & OO~ A.D.
thonotary '--
So Answers:
R. Thomas Kline
03/30/2004
WELTMAN WEINBERG REIS
)Deputy Sheriff
IN THE COURT Of COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CREDIGY RECEIVABLES, INC.,
Plaintiff
VS.
ROBERT K. STAZ
Defendant
No. 04-1303 CIVIL
PRAECIPE TO SETTLE, DISCONTINUE
AND END WITHOUT PREJUDICE TO REFILE
FILED ON BEHALF OF
Plaintiff
COUNSEL OF RECORD OF
THIS PARTY:
William T. Molczan, Esquire
PA I.D. #47437
WELTMAN, WFINBERG & REIS CO., L.P.A.
2718 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955;
WVVR#02648026
IN THE COURT Of COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CREDIGY RECEIVABLES, INC.,
Plaintiff
VS.
ROBERT K. STAZ
Defendant
Civil Action No. 04-1303 CIVIL
PRAECIPE TO SETTLE, DISCONTINUE
AND END WITHOUT PREJUDICE TO REFILE
TO THE PROTHONOTARY OF CUMBERLAND COUNTY:
SIR:
Settle, Discontinue and End the above-captioned matter upc,n the records of the Court without
prejudice to refile and mark the costs paid.
SWORN TO AND SUBSCRIBED
before r~hi~
of
NOff'~(R~ I~)BLI~.
day
2004
WELTMAN, WEINBERG & REIS CO., L.P.A.
436 Seventh Avenue
Pittsburcjh, PA 15219
(412) 43.4-7955
WWR#02648026