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Home My WebLink About10-2586 FILED-?)?HGE ,Af?Y r,.. j, '-W . 2010 APR "40 PM 2: 50 CUMPE, , wSYLWO-,'IA EN" P IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA EQUABLE ASCENT FINANCIAL, LLC I CIVIL DIVISION f/k/a HILCO RECEIVABLES, LLC, I assignee of Chase Bank USA,N.A.1 Plaintiff (s) I V. I ROBERT ROMBERGER, I No. 2010 an individual 1 I Defendant(s)1 I I I I I I COMPLAINT I I Code No. ( 0 - a258(o aivliTerm I I Filed on Behalf of: I PLAINTIFF I I I I ATTORNEY OF RECORD FOR THIS PARTY I I Louis B. Swartz I PA. ID # 00242 I I ISWARTZ, LOVEJOY & ASSOCIATES 116th FLOOR LAW AND FINANCE BUILDING (PITTSBURGH, PENNSYLVANIA 15219 I I 1(412) 288-0303 #705920 NOTE: THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE *9a.00 PD A`nM co µr-45 04 ayoslq 47n5970 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION EQUABLE ASCENT FINANCIAL, LLC f/k/a HILCO RECEIVABLES, LLC, assignee of Chase Bank USA,N.A. Plaintiff (s) v. ROBERT ROMBERGER, an individual Defendant(s) No. 2010 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 NOTDEFCD.PLE 4? i( I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION EQUABLE ASCENT FINANCIAL, LLC f/k/a HILCO RECEIVABLES, LLC, assignee of Chase Bank USA,N.A. Plaintiff(s) V. ROBERT ROMBERGER, an individual No. 2010 Defendant(s) COMPLAINT 1. Plaintiff(s) is EQUABLE ASCENT FINANCIAL, LLC f/k/a HILCO RECEIVABLES, LLC, assignee of Chase Bank USA,N.A.. Plaintiff's address is c/o 429 Fourth Avenue, Suite 1600, Pittsburgh, PA 15219. 2. Defendant(s) is WALTER PASKO. Defendant's address is 15 LILAC DRIVE, MECHANICSBURG PA 17050. 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 .he amount of $6263.82 plus interest from September 16, 2008. 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 g inst Defendant(s) in the amount of $6,263.82 Plus legal i er st and costs. Louis S z Attorney for PLAINTIFF SWARTZ, LOVEJOY & ASSOCIATES 16th FLOOR LAW AND FINANCE BUILDING PITTSBURGH, PENNSYLVANIA 15219 (412) 288-0303 STATE OF ILLINOIS COUNTY OF COOK Equable Ascent Financial, LLC f/k/a Hi'lco Receivables, LLC Plaintiff, vs. ROMBERGER/ROBERT Defendant Docket 4 1, Jeff D. Hasenmiller.. being of full age, hereby certify as follows: I am more than 18 years of age and am competent to make this affidavit. 2. 1 am employed by plaintiff, Equable Ascent Financial, LLC f/k/a Hilco Receivables, LLC as a. Legal Agency Network Manager 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, Equable Ascent Financial, LLC Wa Hilco Receivables, 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 Equable Ascent Financial, LLC f/k/a Hilco Receivables, 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 $18328.27 plus interest of $0.00, totaling $18328.27. y. The documents attached to this affidavit, if any, are true and accurate copies of business records regarding the Defendant's account. 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. It. Defendant is entitled to no known valid defenses, setoffs or counterclaims, and further states that written demand was made upon the Defendant. 79 I affirm under the penalty of perjury that the above facts are true and correct. EQUABLE ASCENT FINANCIAL, LLC f/k/a I-tilc Na o Receivable , C Bv: enmiller Its: Legal Agency Network Manager Sworn to and Subscribed before me this _e day of ---- Notary Public xuzux? 'OFFICIAL SEAI* NANCY COHEN areas C0m5 enr 05/09/10 79 <' n --4 LTI!, r r rn j r-n IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA EQUABLE ASCENT FINANCIAL, LLC ( CIVIL DIVISION f/k/a HILCO RECEIVABLES, LLC, I assignee of Chase Bank US.A,N.A.I Plaintiff(s)I V. I ROBERT ROMBERGER, No. 10-2586 CIVIL an individual I I Defendant(s)I I I I I I ( PETITION FOR LEAVE TO FILE ( AMENDED COMPLAINT I Code No. I ( Filed on Behalf of: I PLAINTIFF' I I I ( ATTORNEY 07 RECORD FOR THIS PARTY I Louis B. Swartz I ( PA. ID # 00242 I I ISWARTZ, LOVEJOY & ASSOCIATES 116th FLOOR LAW AND FINANCE BUILDING (PITTSBURGH, PENNSYLVANIA 1521.9 I I 1(412) 288-0303 *705920 NOTE: THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE t?os9zo IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION EQUABLE ASCENT FINANCIAL, LLC f/k/a HILCO RECEIVABLES, LLC, assignee of Chase Bank USA,N.A. Plaintiff (s) V. ROBERT ROMBERGER, an individual No. 10--2586 CIVIL Defendant(s) PETITION FOR LEAVE TO FILE AMENDED COMPLAINT TO: THE HONORABLE, THE JUDGES OF SAID COURT The Petition of EQUABLE ASCENT FINANCIAL LLC, the Plaintiff in the captioned proceedings respectfully represents that: 1. On April 20, 2010 Plaintiff commenced this action by filing a complaint stating a claim in the amount of $6263.82. 2. On April 26, 2010 the Complaint was served. 3. Since filing the Complaint Plaintiff has determined that its claim is in the amount of $18,328.27. 4. Plaintiff therefore desires to file an Amended Complaint in the form attached hereto. 5. The statute of limitations has not run on Plaintiff's claim and it would be in the interest of justice and judicial economy to allow the amendment. WHEREFORE, Plaintiff requests this Honorab e Court to enter its Order, Judgment or Decree granting Plaintiff 1 av to file the amended pleading as requested and granting such of ei relief that is appropriate. LOUIS B. SWARTZ, EIRE ATTORNEY FOR. PLAIN FF AM ENDPE PLE IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA EQUABLE ASCENT FINANCIAL, LLC I CIVIL DIVISION f/k/a HILCO RECEIVABLES, LLC, I assignee of Chase Bank USA,N.A.I Plaintiff(s) I V. I ROBERT ROMBERGER, I No. 10-2586 CIVIL an individual 1 I Def endant (s) I I i I i I I AMENDED COMPLAINT i Code No. I I Filed on Behalf of: I PLAINTIFF I I I ATTORNEY OF RECORD FOR THIS PARTY Louis B. Swartz I PA. ID # 00242 f I ISWARTZ, LOVEJOY & ASSOCIATES 116th FLOOR LAW AND FINANCE BUILDING (PITTSBURGH, PENNSYLVANIA 15219 I I 1(412) 288-0303 #705920 NOTE: THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE 0705920 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION EQUABLE ASCENT FINANCIAL, LLC f/k/a HILCO RECEIVABLES, LLC, assignee of Chase Bank USA,N.A. Plaintiff (s) V. ROBERT ROMBERGER, an individual No. 10-2586 CIVIL Defendant(s) AMENDED COMPLAINT 1. Plaintiff(s) is EQUABLE ASCENT FINANCIAL, LLC f/k/a HILCO RECEIVABLES, LLC, assignee of Chase Bank USA,N.A.. Plaintiff's address is c/o 429 Fourth Avenue, Suite 1600, Pittsburgh, PA 15219. 2. Defendant(s) is ROBERT ROMBERGER. Defendant's address is 15 LILAC DRIVE, MECHANICSBURG PA 17050. 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 $18328.27 plus interest from September 26, 2008. 4. Attached hereto and incorporated by refenced as if set forth at length is Plaintiff's Verifica--ion of the amount due. WHEREFORE, Plaintiff demands Judgment against Defendant(s) in the amount of $18,328.27 P,--us legal interest and costs. Louis B. Swartz Attorney for PLAINTIFF SWARTZ, LOVEJOY & ASSOCIATES 16th FLOOR LAW AND FINANCE BUILDING PITTSBURGH, PENNSYLVANIA :1521.9 (412) 288-0303 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION EQUABLE ASCENT FINANCIAL,, LLC f/k/a HILCO RECEIVABLES, LLC, assignee of Chase Bank USA,N.A. Plaint=iff (s) v. ROBERT ROMBERGER, an individual No. 10-2586 CIVIL Defendant(s) ORDER AND NOW, this day of 2010, after notice to Defendant and due consideration of Plaintiff's Petition for Leave to File an Amended Complaint, it is hereby ORDERED, ADJUDGED AND DECREED that Plaintiff be and is hereby granted leave to file an Amended Complaint in the form attached to the foregoing Petition. AMENDORD.PLE IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION EQUABLE ASCENT FINANCIAL, LLC f/k/a HILCO RECEIVABLES, LLC, assignee of Chase Bank USA,N.A. Plaintiff(s) v. ROBERT ROMBERGER, an individual No. 10-2586 CIVIL Defendant(s) CERTIFICATE OF SERVICE I certify that I served a true and correct copy of the foregoing pleading by ordinary first class mail, postage paid, to the following person(s) on the date indicated below: Robert Romberger 15 Lilac Drive Mechanicsburg, PA 17050 Dare mailed: September 10, 2010 r N? LUUiS B. SWARTZ,,E QUIRE SWARTZ, LOVEJOY &i A OCIATES, LLP 1600 LAW AND FINA CE BUILDING PITTSBURGH, PA 15219 412/288-0303 EQUABLE ASCENT IN THE COURT OF COMMON PLEAS OF FINANCIAL, LLC CUMBERLAND COUNTY, PENNSYLVAN IA f/k/a HILCO RECEIVABLES, LLC,: assignee of Chase Bank USA, N.A., Plaintiffs C-) Q V. -vim = -+ Z ? Z r ROBERT ROMBERGER, NO. 2010 - 2586 CIVIL TERM use N -°?rn Defendant X-n W ?.?f?T1 ORDER OF COURT - w AND NOW, this 20TH day of JANUARY, 2011, a Rule is issued upon the Defendant to Show Cause why the Petition for Leave to File Amended Complaint should not be granted. Rule returnable twenty (20) days after service. By the--Court, Edward E. Guido, J. 'Louis B. Swartz, Esquire ?Robert Romberger :sld 1 DO ('' _ FILED-OFFICE O " THE PRQT# ONO ARl 2011 JAN 31 AM 11: 59 CUMBERLAND COUNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA EQUABLE ASCENT FINANCIAL, LLC I CIVIL DIVISION f/k/a HILCO RECEIVABLES, LLC, assignee of Chase Bank USA,N.A.I Plaintiff(s)( V. I ROBERT ROMBERGER, I No. 10-2586 CIVIL an individual I I Defendant (s) I I I I I I I CERTIFICATE OF SERVICE I I 1 Code No. I I Filed on Behalf of: I 1 PLAINTIFF I I I 1 ATTORNEY OF RECORD FOR THIS PARTY I 1 David A. Lovejoy I 1 PA. ID # 19829 I I 1SWARTZ, LOVEJOY & ASSOCIATES 116th FLOOR LAW AND FINANCE BUILDING (PITTSBURGH, PENNSYLVANIA 15219 I I 1(412) 288-0303 0705920 NOTE: THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE os9zo IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION EQUABLE ASCENT FINANCIAL, LLC f/k/a HILCO RECEIVABLES, LLC, assignee of Chase Bank USA,N.A. Plaintiff(s) V. ROBERT ROMBERGER, an individual No. 10-2586 CIVIL Defendant(s) CERTIFICATE OF SERVICE I certify that I served a true and correct copy of the January 20, 2011 Order of Court by ordinary first class mail, postage paid, to the following person(s) on the date indicated below: Robert Romberger 15 Lilac Drive Mechanicsburg, PA 17050 Date mailed: January 27, 2011 David A.` L el SWARTZ, LO JO 1600 LAW AND is PITTSBURGH, PA 412/288-0303 ESQUIRE & ASSOCIATES, LLP ANCE BUILDING 15219 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA EQUABLE ASCENT FINANCIAL LLC CIVIL ACTION C= Plaintiff M NO: 10-2586 CIVIL G-) i e .� ROBERT ROMBERGER :.CD CD Defendant PRAECIPE FOR ENTRY OF APPEARANCE To the Prothonotary of CUMBERLAND County: Kindly enter my appearance on behalf of EQUABLE ASCENT FINANCIAL LLC in the above-captioned matter. Date: August 1, 2013 Signat re: Print Name: Michael F. Ratch rd Esquire Supreme Court ID No: 8628 Address: 120 North Ke se Avenue Scranton, PA 18504 Telephone No: (570) 558-5510 1 EQUABLE ASCENT FINANCIAL LLC In the Court of Common Pleas of CUMBERLAND County,Pennsylvania Plaintiff Civil Division VS. a NO: 10-2586 CIVIL ZZ r-n Cn P1 ROBERT ROMBERGER Praecipe to Withdraw Civil Complant Defendant 1?C) _ C:_- C'-7 > cry PRAECIPE TO WITHDRAW To the Prothonotary of CUMBERLAND County Pennsylvania: Please enter the above Praecipe to Withdraw the Civil Complaint. Thank you, /Michael F. Ratchf rEsaquire, Edwin A. Abr sen&Associates, P.C. Lawyer ID # 8 285 120 N. Keyse Avenue Scranton, PA 18504