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Home My WebLink About04-1817IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CACV OF COLORADO, LLC Plaintiff VS. BRUCE ALEXANDER, JR., 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#03313656 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CACV OF COLORADO, LLC Plaintiff VS. BRUCE ALEXANDER, JR., Defendant Civil Action No. oq COMPLAINT IN CIVIL ACTION AND NOTICE TO DEFEND You have been sued in court. If you wish to defend against thc claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice arc served, by entering a written appearance personally or by an attorney and filing in writing with thc court your defenses or objections to the claims set forth against you. You arc 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 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 COMPLAINT Plaintiffis a corporation with offices in Wilmington, DE 19850. 2. Defendant is residing at 156 CHAMBERLIN ROAD, SHIPPENSBURG, PA 17257.. 3. Defendant applied for and received a credit card issued by Plaintiffs assignor bearing the account number 5483411720006240. 4. Defendant made use of said credit card and has currently a balance due and owing to Plaintiff, as of April 4, 2004, in the amount of $8,404.54. 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 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 24.99% 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, Bruce Alexander, Jr., individually, in the amount of $8,404.54 with continuing finance charges thereon at the rate of 24.99% per annum from April 4, 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. Willian~ T. Mo~:zan, Es~[uire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avcmue Pittsbur~t, PA 15219 (412) 434-7955 WWR#:03313656 Page: 1 ~lease indicate Name, or address~ Telephone changes 8134 4100 AX Z X i 7 07 .00 BRUCE ALEXANDER JR ~OBox 465 SHIP~ENSBURG PA 17'257-0465 3O Off /07/2002 REFERENCE NUMBER DESCRIPTION OF TRANSACTIONS F813400HK00999990 CHA~ OFF ACCOUNT-PRINCIPALS F813400HK00999990 CHAR~ OFffACCOONT *FII~ANC~ ENROLL IN CHASE PAY14ENT PROTECTOR P~N TODAY. THE PLAN THAT HELPS ~ROTECT YOUR CREDIT RATING. DUE 4900 .. 1272.62- · 00 ~ AN AMOONT FOLLOWED BY A MINUS SIGN(-) IS A CREDIT OR A CREDIT BALANCE UNLESS OTHERWISE I~)ICATED 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) /~'-~'w'~=~'-~5 ~"~- of ~,J ~ O;2,L:~('-~k0o, LL~, plaintiff herein, that (TITLE) (COMPANY) he/she is duly authorized to make this verification, and that th(; facts set forth in the foregoing Complaint are true and correct to the best of his/her knowledge, information and belief. ~ (SIGNAT~-~E) 03313656 SHERIFF'S CASE NO: 2004-01817 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CAVC OF COLORADO LLC VS ALEXANDER BRUCE JR RETURN - REGULAR RONALD HOOVER , Cumberland County, Pennsylvania, says, the within COMPLAINT & NOTICE was served upon ALEXANDER BRUCE JR DEFEND~aNT , at 2011:00 HOURS, on the 29th day of April at 156 CHAMBERLIN ROAD SHIPPENSBURG, PA 17257 by handing to BRUCE ALEXANDER JR a true and attested copy of COMPLAINT & NOTICE Sheriff or Deputy Sheriff of who being duly sworn according to the together with law, , 2004 and at the same time directing His attention to the contents thereof, Sheriff's Costs: Docketing 18.00 Service 13.80 Affidavit .00 Surcharge 10.00 .00 41.80 Sworn and Subscribed to before me this ~3~ day of ~ R. Thomas Kline 04/30/2004 WELTMAN WEINBERG REIS Deputy Sheriff So Answers: Prothonotary