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HomeMy WebLinkAbout10-1503A S OF THE PROTHONOTARY 1010 MAR-4 AM 10: 18 CUMBIERL?'-4-D COUNTY PEW'S`flVA:NAA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION, LLC I CIVIL DIVISION assignee of Providian I I Plaintiff(s), I I t I No. 2010 _ rr V. I JENNIFER A. STAHLNECKER, I 1 an individual I Defendant(s), I I I I COMPLAINT I I Code No. I I Filed on Behalf of: I I PLAINTIFF I I I I ATTORNEY OF RECORD FOR THIS PARTY I 1 Louis B. Swartz I I PA. ID # 00242 I I ISWARTZ, LOVEJOY & ASSOCIATES 116th FLOOR LAW AND FINANCE BUILDING (PITTSBURGH, PENNSYLVANIA 15219 I I 1(412) 288-0303 #706159 NOTE: THIS IS AN ATTEMPT TO COL LECT A DEBT AND ANY INF ORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE ^? nq •0? `? Cif -w 97 IL H%06159 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PALISADES COLLECTION, LLC assignee of Providian Plaintiff(s), v. No. 2010 JENNIFER A. STAHLNECKER, an individual Defendant(s), NOTICE TO DEFEND AND CLAIM RIGHTS 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 days (20) after this Complaint and Notice are served, by entering a written appearance personally or by 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 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. 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. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 1-800-990-9108 717-249-3166 P;OTCEF^U.PLE #7nr,l IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PALISADES COLLECTION, LLC assignee of Providian Plaintiff(s), No. 2010 16-63 c,, v. JENNIFER A. STAHLNECKER, an individual Defendant(s), rnM1DT.n TNT 1. Plaintiff(s) is PALISADES COLLECTION, LLC assignee of Providian. Plaintiff's address is c/o 429 Fourth Avenue, Suite 1600, Pittsburgh, PA 15219. 2. Defendant(s) is JENNIFER A. STAHLNECKER, an individual. Defendant's address is 416 WALNUT STREET, BOILING SPRINGS, PA 17007. 3. Plaintiff, at Defendant's special instance and request, opened for the Defendant a credit account which Defendant thereafter used and there is a balance due and unpaid, despite demand, in the amount of $10524.87 plus interest from April 2, 2006. 4. Attached hereto and incorporated by refenced as if set forth at length is Plaintiff's Verification of the amount due. WHEREFORE, Plaintiff demands Judgment against 17? ndant(s) in the amount of $10,524.87 Plus legal interest and costs. Louis B. Swar Attorney for I IFF SWARTZ, LOVEJ &'ASSOCIATES 16th FLOOR LAW AND FINANCE BUILDING PITTSBURGH, PENNSYLVANIA 15219 (412) 288-0303 STATE OF COUNTY F PALISADES COLLECTION, LLC ; Plantiff, vs. STAHLNECKERMENNIFER A Defendant. Docket # I, Ana HemandeZ , being of full age, hereby certify as follows: 1. I am more than 18 years of age and am competent to make this affidavit. 2. I am employed by plaintiff, PALISADES COLLECTION, LLC as a custodian of records for the records and facts at issue. 3. I am familiar with all of the facts and circumstances in connection with this case and have been authorized to make this certification in the above referenced case. 4. In the ordinary course of business and as a regular business practice, PALISADES COLLECTION, LLC employees or representatives with knowledge of the accounts compile business records memorializing account activity and transactions at or near the time they occur. 5. Entries in the files and business records of Plaintiff are made contemporaneously with transactions in order to preserve the accuracy of the transaction. 6. Plaintiffs files and business records are maintained by PALISADES COLLECTION, LLC . 7. I have custody and control of the files and business records relating to this account. 8. There is now due and owing from Defendant to Plaintiff, the amount of $7955.11 plus interest of $2569.76, totaling $10524.87. 9. The documents attached to this affidavit, if any, are true and accurate copies of business records regarding the Defendant's account. 23 10. Upon information and belief, the Defendant is not now, nor has been within 30 days hereof, in the military service of the United States as defined in the Servicemembers Civil Relief Act as amended nor an infant, incompetent, under mental defect or infirm. 11. Defendant is entitled to no known valid defenses, setoffs or counterclaims, and further states that written demand was made upon the Defendant. I affirm under the penalty of perjury that the above facts are true and correct. Affiant Sworn to and Subscribed before a this 9 4 day Of _712141?d 20(_0 Notary Public L' ?? JU1ITH sl;Z3? JOSEPH STONE NOTARY PUBLIC STATE OF NEW JERSEY ,0??EPH• `SMY COMMISSION EXPIRES: JAN 19, 2012 a •? 23 0 M f C` q)avid D. Buell 0 '`9‘4, Renee X Simpson Prothonotary 7' 1S` Deputy Prothonotary 0 - - i z i' v \O•... ±� �,. o 7(irkS. Sohonage, ESQ • ,�:/2h y Irene E. Morrow Solicitor 1750 2" Deputy Prothonotary Office of the Prothonotary Cum6erlancl County, Pennsylvania fO —/SD3 CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 29TH DAY OF OCTOBER, 2013,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 One Courthouse Square • Suite 100 • Carlisle, PA 17013 • (717)240-6195 • rFa. ,(717)240-6573