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Home My WebLink About09-4779 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NATIONAL CITY BANK K-AI16-2J Plaintiff No: C - y779 0 v?l IF1'1tq vs. TERRY E NAUGLE COMPLAINT IN CIVIL ACTION Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt,42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 (412) 434-7955 FAX: 412-338-7130 07148545 C A Pit TIC IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NATIONAL CITY BANK K-AI16-2J Plaintiff vs. Civil Action No TERRY E NAUGLE Defendant COMPLAINT 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 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 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. 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. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 COMPLAINT 1. Plaintiff, NATIONAL CITY BANK is a corporatioK-AI16-2Jfices at 1 NATIONAL CITY PARKWAY KALAMAZOO , MI 49009 . 2. Defendant is adult individual(s) residing at the address listed below: TERRY E NAUGLE 77 TIPTOP CIR CARLISLE, PA 17015 3. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXX1700 . 4. Defendant made use of said credit card and has a current balance due of $8297.53 , as of June 12, 2009 . 5. Defendant is in default by failing to make monthly payments when due. As such, the entire balance is immediately due and payable to Plaintiff. 6. Plaintiff is entitled to the addition of interest at the rate of 10.000% per annum on the unpaid balance from June 12, 2009 . A copy of Plaintiff's STATEMENT is attached hereto, marked as Exhibit "1" and made a part hereof. 7. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed and/or refused to pay the balance due to Plaintiff. Wherefore, the Plaintiff prays for judgment in its favor and against Defendant , TERRY E NAUGLE , INDIVIDUALLY , in the amount of $8297.53 with continuing interest thereon at the rate of 10.000 per annum from June 12, 2009 plus costs. fames c. armnroat,42524 WELTMAN, EINBERG & REIS CO., L.P.A. 436 Sev n h Avenue, Suite 1400 Pittsb rg , PA 15219 (412) 3 -7955 FAX: 1 -338-7130 0714 5 C A Pit TIC This law firm is a debt collector attempVing to collect this debt for our client and any information obtained will be used for that purpose. { . 4 PO BOX 2349 #KA16F5 KALAMAZOO MI 49003-2349 4311966047201700000851953000164800 PLEASE MAKE CHECK PAYABLE TO: NATIONAL CITY P.O. BOX 856176 LOUISVILLE, KY 40285-6176 x?xr???nnx?x??n?xx?x?xx??nnx???nx?x??xxxn?) New Balance $8,519.53 Total Amount Due $1,648.00 Due Date 09/21/08 Account Number 4311 9660 4720 1700 Total Enclosed $ Address or Email change? Print new address on back of statement. By mail, your payment may take 5-7 days to reach us. TERRY E NAUGLE 77 TIPTOP CIR CARLISLE PA 17015-7779 3189 nx???nx???xnnx??x?x?x?nx??nx??xxx??x?n?nx??nx?n?x? ECHib,I 1114 3 1 n' S000 0080 1 9 6 60 4 1 1 0 1 100110 00 1 Credit Card Account NationalCity.com/CardServices p oints 4311 9660 4720 1700 Make payments, review transactions and more! At Your Service 24/7: 800-282-7541 Mail payments to: National City P.O. BOX 856176, LOUISVILLE, KY 40285-6176 Account Summary Previous Balance $8,302.38 Credit Limit $11,750.00 Payments/Credits $0.00 Available Credit $0.00 Purchases/Debits + $39.00 Available for Cash Advance $0.00 Cash Advances + $0.00 Statement Closing Date 08/25/08 Finance Charges + $178.15 Payment Due Date 09/21/08 New Balance = $8,519.53 Past Due Amount $1,346.00 Minimum Payment Due $1,648.00 Total Amount Due = $1,648.00 CONTINUED DELINQUENCY MAY ADVERSELY AFFECT YOUR CREDIT RATING. TO AVOID FURTHER COLLECTION ACTION, PAY THE TOTAL AMOUNT DUE. Transactions TranDate PostDate Reference Number Description Debits Credits 08/25 08/25 LATE FEE 39.00 08/25 08/25 'FINANCE CHARGE" 178.15 Finance Charae Summa Corresponding Annual Daily Avg. Daily Balance Finance Percentage Periodic Rate X Days in X Subject to = Charge for Rate (APR) (may vary) Billing Period Finance Charge This Period Purchases Previous Cycle Purchases 24.99% .06847% x 31 x $0.00 = $0.00 Current Cycle Purchases 24.99% .06847% x 31 x $8,393.25 = $178.15 Cash Advances Cash Advances 24.99% .06847% x 31 x $0.00 - $0.00 Annual Percentage Rate = 24.99% Total Finance Charge $178.15 5170 0004 9FD 1 7 17 080825 ED Pagel oft 5624 9600 U366 01A15170 3189 VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA. C.S. 4904 relating to unworn falsifications to authorities, that he/she is Kristy Me Kenna (NAME) y of Nebo C , plaintiff (TITLE) (COMPANY) herein, that he/she is duly authorized to make this verification, and that the facts set forth in the foregoing Complaint in Civil Action are true and correct to the best of his/her knowledge, information and belief. ?Af ?Ufl ( NATU ) WWR#7148545 Q OF 2099 J ' 17 i`,'i 12: IS *'78.5o PA ATT'( Cr.`s` 88` 1413`1 2&,u% 131 Sheriff s Office of Cumberland County R Thomas Kline Sheriff Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant ~~,~rtitr ~i ~u~rrb~p~~~~ ~1 ,~ r ~.t ~?~ CSffIG~CiF'H; j.ryRIFF _ f=~f L ,E _ r }' -' r ~'i ~r1~~ L.Uu! f``~e~ 1 C' , LLB, r Edward L Schorpp Solicitor National City Bank Case Number vs. 2009-4779 Terry E. Naugle SHERIFF'S RETURN OF SERVICE 08/03/2009 11:36 AM -Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on August 3, 2009 at 1136 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Terry E. Naugle, by making known unto herself personally, defendant at 77 Tip Top Circle Carlisle, Cumberland County, Pennsylvania 17015 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $33.40 August 04, 2009 SO ANSWERS, R THOMAS KLINE, SHERIFF ~ry Deputy Sheriff