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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Commonwealth Financial Systems, Inc
245 Main St CIVIL ACTION
Dickson City PA 18519
Plaintiff
vs.
JOHN B MOCK NO: ( - 7l04?
33 W RIDGE ST
CARLISLE PA 17013
Defendant
COMPLAINT
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Plaintiff, Commonwealth Financial Systems, Inc, by and through its attorneys, Edwin A.
Abrahamsen & Associates, P.C., complains of the Defendant as follows:
1. Plaintiff, Commonwealth Financial Systems, Inc, (hereinafter "Plaintiff") is a
Pennsylvania corporation with a principal place of business located at 245 Main Street Dickson
City, PA 18519
2. The Defendant JOHN B MOCK (hereinafter "Defendant") is an adult individual
residing at 33 W RIDGE ST CARLISLE PA 17013.
3. At all relevant times herein, Plaintiff was engaged in the business of debt purchase
and collection.
4. Defendant applied for and received a credit card issued by AUC SILVER with the
account number 5398829178839669.
5. The within account was sold by AUC SILVER to Unifund for valuable
consideration and all rights under said accounts were assigned to Unifund.
6. On or about December 4, 2007 Plaintiff was assigned all rights to certain credit
card accounts from Unifund, including the account opened by Defendant with account number
5398829178839669.
7. Use of the AUC SILVER credit card was subject to the terms of the Cardmember
Agreement, a copy of which was sent to the Defendant along with the credit card.
8. Defendant used the AUC SILVER credit card account number
5398829178839669, for purchases, cash advances and/or balance transfers.
9. The Defendant was mailed account statements relative to the Defendant's use of the
subject credit card.
10. The Defendant defaulted under the terms of the Agreement by failing and refusing
to make monthly payments on the account as they became due.
11. The account became delinquent on November 10, 2005.
12. The principal amount was $4,958.61 at the time it was received by Plaintiff.
13. Pursuant to the account agreement, any unpaid balance accrues interest at the rate
of 32.24%.
14. The total amount due and owing the Plaintiff including interest, is $10,288.26.
WHEREFORE, Plaintiff requests judgment in its favor and against Defendant in the
amount of $10,288.26 plus costs of suit and any other relief as the Court deems just and
appropriate.
Respectfully submitted,
Edwin A. Abr
Michael F. Ra
Heather K. Wood squire
Attorney I.D. N s. 6285/207805
120 North Ke s Ave.
Scranton, P 504
mratchford@eaa-law.com
hwoodruff@eaa-law.com
Phone: 570-558-5510
Fax: 570-558-5511
VERIFICATION
I, Michael F. Ratchford, attorney for Plaintiff,Commonwealth Financial Systems, Inc, am
fully familiar with the facts set forth in the within Complaint and am authorized to make this
Verification on behalf of Plaintiff. I Verify that the facts set forth in the within allegations are
true and correct to the best of my knowledge, knowing that any false statements are punishable
by law pursuant to 18 C.S.A. 4904.
FILE D-,,.-r J'E
OF THE
2009 NOV -5 Pil 3: 08
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SHERIFF'S OFFICE OF CUMBERLAND COUNTY
R Thomas Kline
Sheriff
utr atubrrl
OF M t
Ronny R Anderson g
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Chief Deputy F } 2019 NOY 17 AN 82' 40`
Jody S Smith
Civil Process Sergeant OFFICE(11' THE S"ERIPF a ma&'L 1 LM
Edward L Schorpp
Solicitor
Commonwealth Financial Systems, Inc.
vs. Case Number
John B. Mock 2009-7690
SHERIFF'S RETURN OF SERVICE
11/13/2009 03:40 PM - Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on Novembei
13, 2009 at 1540 hours, he served a true copy of the within Complaint and Notice, upon the within named
defendant, to wit: John B. Mock, by making known unto himself personally, at 33 W. Ridge Street Carlisle,
Cumberland County, Pennsylvania 17013 its contents and at the same time handing to him personally the
said true and correct copy of the same.
SHERIFF COST: $33.40
November 16, 2009
SO ANSWERS,
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;111? We; 49!!t*
R THOMAS KLINE, SHERIFF
By
Deputy S eri f
(CI CouotySuite Sheriff. Teleosoft Inc.
David 1D. Bueff
Prothonotary
T,irkS. Sohonage, E SQ,
Soricitor
Rsnee X Simpson
F' Deputy Prothonotary
Irene E. W orrow
2nd Deputy Prothonotary
office of the 1tothonotary
Cumberfand County, Pennsy(vania
09 0. Iwo CIVIL TERM
ORDER OF TERMINATION OF COURT CASES
AND NOW THIS 30TH DAY OF OCTOBER, 2012, AFTER MAILING NOTICE OF
INTENTION TO PROCEED AND RECEIVING NO RESPONSE -THE ABOVE
CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA
R.C.P. 230.2.
BY THE COURT,
DAVID D. BUELL
PROTHONOTARY