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Home My WebLink About09-2967 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NCO Portfolio Management I CIVIL DIVISION ASSIGNEE OF HOUSEHOLD AUTO 1 FINANCE I Plaintiff(s), 1 No. 2009 - lu91. ?J'?'? V. I l I LORETTA D WASHINGTON 1 an individual i Defendant(s), 1 I I COMPLAINT I 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 1PITTSBURGH, PENNSYLVANIA 15219 I I 1(412) 288-0300 #701311 NOTE: THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE 001311 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NCO Portfolio Management ASSIGNEE OF HOUSEHOLD AUTO FINANCE Plaintiff(s), No. 2009 V. LORETTA D WASHINGTON an individual Defendant(s), 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. MONROE COUNTY BAR ASSOCIATION 913 Main Street Stroudsburg, PA 18360 570-424-7288 notdefmo.ple #701311 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NCO Portfolio Management ASSIGNEE OF HOUSEHOLD AUTO FINANCE Plaintiff(s), No. 2009 - A9&7+?-? V. LORETTA D WASHINGTON an individual Defendant(s), CCMPLAINT 1. Plaintiff(s) is NCO Portfolio Management ASSIGNEE OF HOUSEHOLD AUTO FINANCE. Plaintiff's address is 429 FOURTH AVE SUITE 1600, PITTSBURGH PA 15219. 2. Defendant(s) is LORETTA D WASHINGTON an individual. Defendant's address is 500 GENEVA DR APT Al, MECHANICSBURG PA 17055. 3. Plaintiff, 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 $10834.88 plus interest from January 31, 2007. WHEREFORE, Plaintiff demands Judgment inst Defendant(s) in the amount of $10,834.88 Plus legal in est and costs. Louis BW Swartz Attorney for PLAINTIFF SWARTZ, LOVEJOY & ASSOCIATES 16th FLOOR LAW AND FINANCE BUILDING PITTSBURGH, PENNSYLVANIA 15219 (412) 288-0300 t•r7.si r IN THE COURT OF COLON PLEAS Ox CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NCO Portfolio Management y ASSIGNEE OF HOUSEHOLD AUTO FINANCE Plai.nti:ff {s) , I No. 2009 V. LORETTA D WASHINGTON an individual 1 1 Defendant(s). I The undersigned, that he/she is the is authorized to make avers of Plaintiff, verification on behalf of plaintiff, the statements of fact contained in the attached complaint are true and correct to the best of bis/her information, knowledge and belief, and are made subject to the penalties of 18 Pa. Cons. Staff. Ann. Section 9909 relating to unsworn falsifnation to authorities. Date ?0 ??C._£COFS. PT..B Cis FILED OF THE emu`,. 2009 MAY I I P?: 0 2 ??+++? ?pp ,r, ti!1 V i PEN ? ys. so ?CJL A4 / Cy,-:d yaze S hZ ''?` a•?Y48?' Sheriffs Office of Cumberland County R Thomas Kline of Cnjr1hrr/? Edward L Schorpp Sheriff Solicitor Ronny R Anderson Jody S Smith era r ; E ERiFF Civil Process Sergeant Chief Deputy SHERIFF'S RETURN OF SERVICE 05/12/2009 07:51 PM - Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on May 12, 2009 at 1951 hours, he served a true copy of the within Complaint and Notice, upon the within named to wit: Loretta D. Washington, by making known unto herself personally, defendant at 500 defendant , Geneva Drive, Apt. Al Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $37.90 SO ANSWERS, K FF May 13, 2009 R THOMAS KLINE, 2009-2967 BY NCO Portfolio Management Deputy eriff VS Loretta D. Washington '' ? w IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NCO Portfolio Management I CIVIL DIVISION ASSIGNEE OF HOUSEHOLD AUTO I FINANCE 1 I Plaintiff(s), 1 I No. 2009-2967 V. 1 LORETTA D WASHINGTON I an individual 1 I I Defendant(s), I I PRAECIPE FOR DEFAULT JUDGMENT I I Code No. I I Filed on Behalf of: I 1 PLAINTIFF I I I I ATTORNEY OF RECORD FOR THIS PARTY I I Louis B. Swartz 1 PA. ID # 00242 I I ISWARTZ, LOVEJOY & ASSOCIATES 116th FLOOR LAW AND FINANCE BUILDING (PITTSBURGH, PENNSYLVANIA 15219 I I 1(412) 288-0303 %701311 NOTE: THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE '701311 1" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NCO Portfolio Management ASSIGNEE OF HOUSEHOLD AUTO FINANCE Plaintiff(s), V. LORETTA D WASHINGTON an individual Defendant(s), No. 2009-2967 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 $ 10,834.88 PLUS INTEREST FROM 01-31-2007 TO: 06-29-2009 $ 1,567.35 TOTAL $ 12,402.23 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 beforMAiling this praecipe. Louis B. Swart Attorney for P INTIFF SWARTZ, LOVEJOY & ASSOCIATES 16th FLOOR LAW AND FINANCE BUILDING PITTSBURGH, PENNSYLVANIA 15219 (412) 288-0303 4 #701311 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NCO Portfolio Management ASSIGNEE OF HOUSEHOLD AUTO FINANCE Plaintiff(s), v. LORETTA D WASHINGTON an individual Defendant(s), No. 2009-2967 DEFAULT NOTICE TO THE DEFENDANT: LORETTA D WASHINGTON an individual 500 GENEVA DR APT Al MECHANICSBURG PA 17055 IMPORTANT NOTICE 1-800-692-7375 Date ws , 3wa 'MYOU 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.?P 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 Louis B. Swartz Attorney for PLAINTIFF SWARTZ, LOVEJOY & ASSOCIATES 16th FLOOR LAW AND FINANCE BUILDING PITTSBURGH, PENNSYLVANIA 15219 (412) 288-0303 NOTE: THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE defnote/defnotex IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NCO Portfolio Management I CIVIL DIVISION ASSIGNEE OF HOUSEHOLD AUTO I FINANCE Plaintiff(s), I No. 2009-2967 V. I I LORETTA D WASHINGTON I an individual I I I Defendant(s), I I AFFIDAVIT OF NON-MILITARY SERVICE 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) 288-0303 %701311 NOTE: THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE 7 V, 701311 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NCO Portfolio Management ASSIGNEE OF HOUSEHOLD AUTO FINANCE V. Plaintiff(s), No. 200.9-,29.67 LORETTA D WASHINGTON an individual Defendant(s), AFFIDAVIT OF NON-MILITARY SERVICE I, LOUIS B. SWARTZ, do depose and say that the above-named defendant(s) LORETTA D WASHINGTON 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. Fll.?FILE OF THE MT NARY 2009 JUN 29 PM 2= 59 PENNSl'LVAJ,i fit. 4t4.00 r0 N-V*H .? ,?o5't3 ? # ?a•?3 to 3 R? I .) 3701311 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NCO Portfolio Management ASSIGNEE OF HOUSEHOLD AUTO FINANCE Plaintiff(s), No. 2009-2967 V. LORETTA D WASHINGTON an individual Defendant(s), NOTICE OF JUDGMENT TO: LORETTA D WASHINGTON an individual 500 GENEVA DR APT Al MECHANICSBURG PA 17055 You, the above named Defendant(s) take notice that Judgment has been entered with the Court of Common Pleas of CUMBERLAND County, Civil Division in the sum of $ 1a l?Qa,,Z3 plus costs and Interest. 6 Louis B. Swartz d4e-0 OTHONOTA el-t? Attorney for PLAINTIFF (0029/0 SWARTZ, LOVEJOY & ASSOCIATES / 16th FLOOR LAW AND FINANCE BUILDING PITTSBURGH, PENNSYLVANIA 15219 (412) 288-0303 NOTE: THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE