The URL can be used to link to this page

Home My WebLink About09-6204II IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION OSEETAH CAPITAL LLC Plaintiff No. 04 v i l Ter Vq VS. GERALDINE K RICHMOND COMPLAINT IN CIVIL ACTION Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: JAMES C. WARMBRODT, Esquire PA I.D. #42524 WELTMAN WEINBERG & REIS CO., L.I.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#7513199 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION OSEETAH CAPITAL LLC Plaintiff VS. Civil Action No. GERALDINE K. RICHMOND Defendant DEFEND COMPLAINT IN CIVIL ACTION AND NOTICE TO You have been sued in court. If you wish to defend against the claims set forth in th@ ollowing pages, you must take action within twenty (20) days after this complaint and notice are Iserved, by entering a written appearance personally or by an attorney and filing in writing with the ' urt your defenses or objections to the claims set forth against you. You are warned that if you fail to do Is the case may proceed without you and a judgment may be entered against you by the court without er notice for any money claimed in the complaint or for any other claim or relief requested by the p1q'i tiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOIJ IIDO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OF';I, ICE 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 Plaintiff is a corporation with offices in PO BOX 831 NEWBURGH, NY 12550-6831. i 2. Defendant is an adult individual residing at 132 AMY DR CARLISLE,PA 17011 3. Defendant applied for and received a credit card bearing the account number II 08338018401. 4. Contract was subsequently assigned to Plaintiff. 5. Defendant made use of said credit card and has currently a balance due and owing to i Plaintiff, as of AUGUST 19, 2009, in the amount of $ 5,677.12. A true and correct copy of laintiff s I Statement of Account is attached hereto, marked as Exhibit "1" and made a part hereof. 6. Defendant is in default of the terms of the cardholder Agreement having not mad monthly payments to Plaintiff thereby rendering the entire balance immediately due and payable. I 7. Plaintiff avers that the Cardholder Agreement between the parties provides that ?laintiff is i entitled to the addition of finance charges at the rate of 5.00% per annum on the unpaid balance.; I 8. Although repeatedly requested to do so by Plaintiff, Defendant has willfully fdi?ed and/or refused to pay the principal balance, finance charges or any part thereof to Plaintiff. I II WHEREFORE, Plaintiff demands Judgment in its favor and against Defendant, GER' LDINE K RICHMOND individually, in the amount of $ 5,677.12 with continuing finance charges the?eon at the rate of 5.00% per annum from AUGUST 19, 2009 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.?.A. JAMES C. A BRc PA LD. #42 WELTMA EINBE 1400 Kop Building 436 Seve Avenue Pittsbur PA 15219 (412) 43 -7955 )T, Esquire G & REIS CO., L4? .A. WWR#:7513199 PAGE 01 OF 01 mary ACCOUNT NUMBER 8140010001139393 GERALDINE K RICHMOND A minimum payment of $1424.00 is due by 08/10/2008. Previous Balance $5,476.84 Payrrients I Credits $0.00 Purchases & Other Charges $29.00 Finance Charges $92.29 Days in Cyrle 30 New Balance $5,598.13 For account inquiries and to report cards lost or stolen call: 1-800-252-2551 Refer to the brick side for more information and remittance instructions. EXHIBIT i Send billing inquiries to: PO BOX 731 MAHWAH NJ 07430 CREDIT CARD TRANSACTIONS TRANSACTION POST CREDIT DATE DATE PLAN DESCRIPTION OF TRANSACTION 05/11 05/11 44444-02 LATE CHARGE ASSESSMENT 05/15 05/15 00138-01 BILLED FINANCE CHARGES I AMOUNT $29.00 j $92.29 ************* FINAL NOTICE ************* FULL PAYMENT ON YOUR ACCOUNT IS DUE IMMEDIATELY! AVERAGE MONTHLY PERIODIC ANNUAL STATEMENT CRLDII PLAN DESCRIPTION DAILY BALANCE RATE(S) % RATE CLOSING DATE I 00138-01 02 LATE TFEES N/$OTHER FEES $5,2$0.00 0.00000% 20.0000 05/15 --' )FINANCE (+)PURCHASES & (=)NEW MINIMUM PREVIOUS NCE (-)PAYMENTS & CREDITS (+ CHARGES OTHER DEBITS BALANCE PAYMENT CREDIT PLAN BALA 00138-01 $5,273.84 $0.00 $92.29 $0.00 $5,366.13 $1,192.00 00 00 $232 44444-02 $203.00 ma h $0.00 be higher than $0.00 the calculation $29.00 above if your . $232. initial purchase was y arges Finance c not paid in full by the end of the grace period. Please include detached portion with payment. Account No. 8140010001 139393 Payment Due Date 06/10/08 Past Due Amount $1,246.00 New Balance $5,598.13 Minimum Payment Due $1,424.00 Enter Amount Enclosed in Boxes Below Please make check or money order payable to DEPARTMENT OF ACCOUNTS • -_.-_ _ 100 0008140010001139393 06102008 00559813 00142400 02 0 9 '#BWNJXVP 814000001 IrrILlrJrrrrllllrrrrrrllllrrrJlrJlrrrLLJI?rrLlrrrrlLl GERALDINE K RICHMOND 132 AMY DR COMFORT MOBILITY CREDIT LINE CARLISLE PA 17013 P.O. BOX 609 MEMPHIS TN 38101-0609 VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA.C.S. §4904 relating to i unsworn falsifications to authorities, that he/she is (Name) of P e Z ,plaintiff herein, that (T' le) (Compan36 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. WWR#7513199 O OF THE ZQi;R S'I- ? 14 FH 2: 12 GUIY ?q,g , Sto Po AT"N OX-* 89 l 7 3c, 1 at 013055S Sheriffs Office of Cumberland County R Thomas Kline Sheriff Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor 4??ttitr at 4uEhbr????? i ? .. - Oseetah Capital LLC Case Number vs. 2009-6204 Geraldine K. Richmond SHERIFF'S RETURN OF SERVICE 09/28/2009 R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Geraldine K. Richmond, but was unable to locate her in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant Geraldine K. Richmond. The request for service at 132 Amy Drive Carlisle, PA 17013 appears vacant. A neighbor advised Deputy's the defendant has health issues and has moved out. The Carlisle Postmaster confirmed the defendant's mail is delivered to address given. An exact address is not available. SHERIFF COST: $38.40 September 28, 2009 SO ANSWERS, R THOMAS KLINE, SHERIFF