HomeMy WebLinkAbout10-1021
NO: 10 - 10411 0,4,4111'Orm
Defendant
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 to
Defend 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 ON AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT REDUCED FEE OR NO FEE.
IN THE COURT OF COMMON PLEAS OF FILED-Qrri E
CUMBERLAND COUNTY, PENNSYLVANIA ?Nr
PALISADES COLLECTION, LLC 10FE -9 AM g; p
210 SYLVAN AVENUE CIVIL ACTION
ENGLEWOOD CLIFF 07632
Plaintiff +1_Vl?i''4?A,
vs.
BRIAN F SHEPARD
37 RIDGE AVE
CARLISLE PA 17013-8127
MIDPENN LEGAL SERVICES
401 EAST LOUTHER STREET
CARLISLE, PA 17013
717-243-9400
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
PALISADES COLLECTION, LLC
210 SYLVAN AVENUE CIVIL ACTION
ENGLEWOOD CLIFF 07632
Plaintiff
vs.
NO: Ga ?? ?t ?1v; l ?ct?
BRIAN F SHEPARD
37 RIDGE AVE
CARLISLE PA 17013-8127 :
Defendant
COMPLAINT
Plaintiff, PALISADES COLLECTION, LLC , by and through its attorneys, Edwin A.
Abrahamsen & Associates, P.C., complains of the Defendant as follows:
1. Plaintiff, PALISADES COLLECTION, LLC , (hereinafter "Plaintiff") is a
corporation with a principal place of business located at 210 SYLVAN AVENUE ENGLEWOOD
CLIFF 07632.
2. The Defendant BRIAN F SHEPARD (hereinafter "Defendant") is an adult
individual residing at 37 RIDGE AVE CARLISLE PA 17013-8127.
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 PALISADES
COLLECTION, LLC with the account number 5260365920002095.
5. Use of the PALISADES COLLECTION, LLC credit card was subject to the terms
and considerations of the Cardmember Agreement (hereinafter "Agreement"), a copy of which
was sent to the Defendant along with the credit card.
6. Defendant used the PALISADES COLLECTION, LLC credit card account
number5260365920002095, for purchases, cash advances and/or balance transfers.
7. The Defendant was mailed account statements relative to the Defendant's use of the
subject credit card.
8. The Defendant defaulted under the terms of the Agreement by failing and refusing
to make monthly payments on the account as they became due.
9. The account became delinquent April 23, 2007.
10. The total amount due and owing the Plaintiff including interest, is $13,856.81.
11. Pursuant to the terms of the Agreement, Defendant is liable to Plaintiff for court
costs.
WHEREFORE, Plaintiff requests judgment in its favor and against Defendant in the amount of
$13,856.81 plus costs of suit and any other relief as the Court deems just and appropriate.
Edwin A. r sen & Assoc.
Michael at ford, Esquire
Atto Y, D. os.: 86285
120 rth Keyser Ave.
Sc ton, PA 18504
mratchford@eaa-law.com
Phone: 570-558-5510
Fax: 570-558-5511
VERIFICATION
I, Michael F. Ratchford, attorney for Plaintiff, PALISADES COLLECTION, LLC , 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.
EUMNA ABRAHA1,1SE1I
I.UCHAEL F. RAT%:HFC,RU
HEATHER' k:..i OODRUFF'
ALSO A 11EIABER OF FL BAR
THE LAW OFFICE OF
RM INA. A13RkHAHf3SN & A `+OCLAXM1 . PC
WWWJEAA-LAW.COM
November 17, 2009
Cumberland County Sheriffs
1 Court House Sq.
Carlisle, PA 17013
Re: PALISADES COLLECTION, LLC vs. BRIAN F SHEPARD
Our file Nos.: N09-9475
Dear Sheriff:
In regard to the above-noted matter, enclosed please find the following:
1. A true and correct copy of the Complaint;
2. The completed form for service;
3. A check for service;
4. A self-addressed return envelope for the return of service.
Please serve the named defendant in accordance with the County Rules of Civil
Procedure. If you should have any questions or concerns, please do not hesitate to call me at
(570) 558-5510.
The defendants address is : BRIAN F SHEPARD 37 RIDGE AVE CARLISLE PA
17013-8127
Thank you for your attention to this matter.
Enclosures
mfr/MR
E in AAbr en
ael F. Ratchford,
mratchford@eaa-1
120 N KEYSER AVE SCRANTON, PA 18504 (P) 570.558.5510 (F) 570.558.5511
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff FILEC t t y
Jody S Smith
Chief Deputytff'59 22=(? L?+
Edward L Schorpp
Solicitor OFF C jGF-
?4,^fl'I ,pis
Palisades Collection, LLC
vs.
Brian F. Shepard
Case Number
2010-1021
SHERIFF'S RETURN OF SERVICE
02/17/2010 09:25 AM - Jason Vioral, Sergeant, who being duly sworn according to law, states that on February 17,
2010 at 0925 hours, he served a true copy of the within Complaint and Notice, upon the within named
defendant, to wit: Brian F. Shepard, by making known unto himself personally, at The Cumberland County
Sheriffs Office, 1 Courthouse Square Room 303, 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: $28.00
February 17, 2010
SO ANSWERS,
;6(4. oa???
O Y R ANDERSON, SHERIFF
Serg n
ci Gounryguit? Sh=.tft, Tei^oo`t. Irv:.
PALISADES COLLECTION
LLC
, In the Court of Common Pleas of
Plaintiff CUMBERLAND County, Pennsylva jii rya
Civil Division -- ?c
vs.
NO: 10-1021 --
BRIAN F SHEPARD
37 RIDGE AVE Praecipe to Settle, Discontinue and End
CARLISLE PA 17013-8127
Defendant
PRAECIPE TO SETTLE DISCONTINUE and END
To the Prothonotary of CUMBERLAND County Pennsylvania:
Please enter the above Praecipe to Settle, Discontinue and End.
Thank you,
Michael F. Ratchford,
Edwin A. Abrahamsen
Lawyer ID # 86285
120 N. Keyser Ave ue
s, P.C.
Scranton, PA 185,