HomeMy WebLinkAbout09-5923
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
KAY JEWELERS
Plaintiff No. N/ - -S-q ?3 U 1 T rm
vs.
ROBERT B SHEAFFER
Defendant
COMPLAINT IN CIVIL ACTION
FILED ON BEHALF OF
Plaintiff
COUNSEL OF RECORD OF
THIS PARTY:
JAMES C. WARMBRODT, Esquire
PA I.D. #42524
WELTMAN, WEINBERG & REIS CO., L.P.A.
1400 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR#7696681
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
KAY JEWELERS
Plaintiff
VS. Civil Action No.
ROBERT B SHEAFFER
Defendant
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 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
LAWYER REFERRAL SERVICE
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
(717) 249-3166
COMPLAINT
1. Plaintiff is a corporation with offices in PO BOX 1799 AKRON, OH 44309-0000.
2. Defendant is an adult individual residing at 337 WOLF BRIDGE ROAD
CARLISLE,PA 17013
3. Defendant applied for and received a credit card issued by Plaintiff bearing the account
number 3098521390 . A true and correct copy of the Application is attached hereto, marked as Exhibit
"1" and made a part hereof.
4. Defendant made use of said credit card and has currently a balance due and owing to
Plaintiff, as of AUGUST 5, 2009, in the amount of $ 1,326.74.
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 0.00% 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, ROBERT B
SHEAFFER individually, in the amount of $ 1,326.74 with continuing finance charges thereon at the rate
of 0.00% per annum from DATE OF JUDGMENT 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.
JAMES C. BP
PA I.D. #42 24
WELTMA EINB
1400 Kop er uildin
436 Seve t Avenue
Pittsbur PA 15219
(412) -7955
, Esquire
ERG & REIS CO., L.P.A.
WWR#:7696681
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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? Y\ a?
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of Le.'U Z?n , plaintiff herein, that
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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.
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(Signature)
WWR#7696681
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Sheriff s Office of Cumberland County
R Thomas Kline ~_~~{J_" ~,4,,:
Sheriff
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Ronny R Anderson ,
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Chief Deputy ~ •~}• ~~~~ ~ ~i' _ ~ N ~= • J
Jody S Smith ''`
Civil Process Sergeant oe cE F ~^` ~"~R~F~ ~U~J~_„ ! "~~F~~%
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Edward L Schorpp ~ '" '"' ~ "
Solicitor
Kay Jewelers
vs. Case Number
Robert B. Sheaffer 2009-5923
SHERIFF'S RETURN OF SERVICE
08/31/2009 05:06 PM -Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on
August 31, 2009 at 1706 hours, he served a true copy of the within Complaint and Notice, upon the within
named defendant, to wit: Robert B. Sheaffer, by making known unto himself personally, at 337 Wolfs
Bridge Road Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handinc
to him personally the said true and correct copy of the same.
SHERIFF COST: $33.40
SO ANSWERS
~~
September 01, 2009 R THOMAS KLINE, SHERIFF
Deput Sheriff