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Home My WebLink About08-6315 A IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CREDIGY RECEIVABLES, INC., 1 CIVIL DIVISION a corporation, assignee of 1 _. MBNA I Plaintiff(s)( V. I ? GNP ?t?M BOYD L. MYERS, I No. 2008 ?p 3 an individual I I Defendant(s)( I I I I I COMPLAINT I I Code No. I I Filed on Behalf of: I PLAINTIFF I I I ATTORNEY OF RECORD FOR THIS PARTY I Louis B. Swartz I PA. ID # 00242 I I ISWARTZ, LOVEJOY & ASSOCIATES 116th FLOOR LAW AND FINANCE BUILDING (PITTSBURGH, PENNSYLVANIA 15219 I I 1(412) 288-0300 #37550 NOTE: THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE J, #37550 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CREDIGY RECEIVABLES, INC., a corporation, assignee of MBNA Plaintiff (s) BOYD L. MYERS, an individual v. No. 2 0 0 8- (o'3 1 l 'C' /+-L4^ Defendant(s) NO?UEtCU.PLE NOTICE TO DEFEND AND CLAIM RIGHTS 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 days (20) after this Complaint and Notice are served, by entering a written appearance personally or by 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 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. 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. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 1-800-990-9108 717-249-3166 #37550 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CREDIGY RECEIVABLES, INC., a corporation, assignee of MBNA Plaintiff (s) BOYD L. MYERS, an individual v. No. 2008 - 43!S ,1,, 1 1er^. Defendant(s) (" eW"T.& TNT 1. Plaintiff(s) is CREDIGY RECEIVABLES, INC., a corporation, assignee of MBNA. Plaintiff's address is 429 Fourth Avenue, Suite 1600, Pittsburgh, PA 15219. 2. Defendant(s) is BOYD L. MYERS. Defendant's address is 37 E MAIN ST, MECHANICSBURG PA 17055. 3. Plaintiff's assignor, at Defendant's special instance and request, opened for the Defendant a credit account which Defendant thereafter used and there is a balance due and unpaid, despite demand, in the amount of $36179.69 plus interest from August 25, 2008. The account was assigned to Plaintiff for value. WHEREFORE, Plaintiff demands Judgment against De ndant(s) in the amount of $36,179.69 plus interest from Augu t25, 2008 and costs. Louis B. Swartz ` Attorney for PL TIFF SWARTZ, LOVEJOY & ASSOCIATES 16th FLOOR LAW AND FINANCE BUILDING PITTSBURGH, PENNSYLVANIA 15219 (412) 288-0300 RECD ?- Fp GJ s A- ?c Pl-a m Q Q . W 0 r D N SHERIFF'S RETURN - REGULAR CASE NO: 2008-06315 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CREDIGY RECEIVABLES INC VS MYERS BOYD L MICHAEL BARRICK Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon MYERS BOYD L the DEFENDANT , at 0008:52 HOURS, on the 28th day of October , 2008 at 37 E MAIN STREET MECHANICSBURG, PA 17055 JACK DAFFNER by handing to EMPLOYEE OF DEFENDANT a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge /0/60/0-r `,.` 18.00 10.00 .00 10.00 .00 X38.00 Sworn and Subscibed to before me this day So Answers: R. Thomas Kline 10/29/2008 LOUIS B. SWARTZ By: eputy Sheriff of A. D. .r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CREDIGY RECEIVABLES, INC., I CIVIL DIVISION a corporation, assignee of 1 MBNA Plaintiff (s) I V. I BOYD L. MYERS, I No. 08-06315 an individual I I Defendant(s)) I I l I I PRAECIPE FOR DEFAULT JUDGMENT I I Code No. i Filed on Behalf of: I PLAINTIFF I I I ATTORNEY OF RECORD FOR THIS PARTY I Louis B. Swartz I PA. ID # 00242 I I ISWARTZ, LOVEJOY & ASSOCIATES 116th FLOOR LAW AND FINANCE BUILDING (PITTSBURGH, PENNSYLVANIA 15219 I I 1(412) 288-0300 %37550 NOTE: THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE %37550 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CREDIGY RECEIVABLES, INC., a corporation, assignee of MBNA Plaintiff(s) BOYD L. MYERS, an individual v. No. 08-06315 Defendant(s) PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Enter judgment against Defendant(s) and in favor of Plaintiff in Default of an Answer or a Notice of Intention to Appear as follows: AMOUNT CLAIMED IN COMPLAINT $ 36,179.69 PLUS INTEREST FROM 08-25-2008 TO: 12-15-2008 $ 666.10 TOTAL $ 36,845.79 I certify that I mailed a notice of default to the defendant(s) in the form attached hereto on the date stated thereon which was more that ten (10) days bhf/re filing this praeci.pe. Louis B. S rJP Attorney fo AINTIFF SWARTZ, LO J & ASSOCIATES 16th FLOOR LAW AND FINANCE BUILDING PITTSBURGH, PENNSYLVANIA 15219 (412) 288-0300 r 3550 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CREDIGY RECEIVABLES, INC., a corporation, assignee of MBNA Plaintiff(s) BOYD L. MYERS, an individual v. Defendant(s) No. 08-06315 DEFAULT NOTICE TO THE DEFENDANT: BOYD L. MYERS, an individual 37 E MAIN ST MECHANICSBURG PA 17055 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 (10) 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 PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. 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. Pennsylvania Lawyer Referral Service 100 South Street, P.O. Box 186 Harrisburg, PA 17108 1-800-692-7375 e?. ±,.. Date Aff 11 Louis B. Swartz Attorney for PLAINTIFF SWARTZ, LOVEJOY & ASSOCIATES 16th FLOOR LAW AND FINANCE BUILDING PITTSBURGH, PENNSYLVANIA 15219 (412) 288-0300 NOTE: THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE defnote/defnotex A~' `?J J 5 r .? l 'F _.r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CREDIGY RECEIVABLES, INC., I CIVIL DIVISION a corporation, assignee of MBNA Plaintiff(s)( V. BOYD L. MYERS, I No. 08-06315 an individual 1 I De f endant (s) I I I I I I AFFIDAVIT OF NON-MILITARY SERVICE I I Code No. I Filed on Behalf of: I PLAINTIFF I I I ATTORNEY OF RECORD FOR THIS PARTY I Louis B. Swartz I I PA. ID # 00242 I I ISWARTZ, LOVEJOY & ASSOCIATES 116th FLOOR LAW AND FINANCE BUILDING (PITTSBURGH, PENNSYLVANIA 15219 I I 1(412) 288-0300 %37550 NOTE: THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE X37550 r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CREDIGY RECEIVABLES, INC., a corporation, assignee of MBNA Plaintiff (s) BOYD L. MYERS, an individual v. Defendant(s) No. 08-06315 AFFIDAVIT OF NON-MILITARY SERVICE I, LOUIS B. SWARTZ, do depose and say that the above-named defendant(s) Boyd L. Myers are not currently in the naval or military services of the United States, either directly or indirectly. These statements are made subject to the penalties of 18 Pa. Cons. Stat. Ann. Section 4904 relating to unsworn falsification to authorities. ? " ? ?? . ? 4 ? 1 ? ^ ?? 1 ti ?' ???. ?\ . ? ? J -r_ Lr r ,? / a+' ..L