HomeMy WebLinkAbout01-0669IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CLAIMS RECOVERY SYSTEMS,
INC., Assignee from
CREDITONE, LLC, Assignee
from DEBTONE, LLC, Assignee
from HOUSEHOLD FINANCE
CORPORATION,
Plaintiff
Vs.
HICK K. RIEGEL,
Defendant
CIVIL DIVISION
No. 01 -
COMPLAINT
Filed on Behalf of:
Plaintiff, CLAIMS RECOVERY
SYSTEMS, INC.
Counsel of Record for This
Party:
JOSEPH COLAVECCHI, ESQUIRE
Pa. I.D. #06810
COLAVECCHI RYAN & COLAVECCHI
221 East Market Street
P.O. Box 131
Clearfield, PA 16830
814/765-1566
LAW OFFICES OF
COLAVECCHI
%N & COLAVECCHI
.AW OFFICES OF
COLAVECCHI
~N & COLAVECCH{
i? E. MARKET s'r,
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COb~TY,
CIVIL DIVISION
CLAIMS RECOVERY SYSTEMS, INC.,
Assignee from CREDITONE, LLC.,
Assignee from DEBTONE, LLC,
Assignee from HOUSEHOLD FINANCE
CORPORATION,
Plaintiff
MICK K. RIEGEL,
Vs.
Defendant
NOTICE
No. 01 - LC~
PE~SYLVANIA
You have been sued in Court. If you wish to defend against
NOT
You are warned that if you fail to
without you and & judgment may be
without further notice for any
for any other claim or relief
may lose money or property or
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
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.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
249-3166
800/990-9108
do so the case may proceed
entered against you by the Court
money claimed in the Complaint or
requested by the Plaintiff. You
other rights important to you.
claims set forth against you.
the claims set forth in the following pages, you must take action
within twenty <20) days 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
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PELrNSYLVANIA
CIVIL DIVISION
CLAIMS RECOVERY SYSTEMS, INC.,:
Assignee from CREDITONE, LLC, :
Assignee from DEBTONE, LLC, :
Assignee from HOUSEHOLD
FINANCE CORPORATION,
Plaintiff
MICK K.
RIEGEL,
Defendant
COMPLAINT
1. Plaintiff is Claims Recovery Systems, a corporation
organized and existing under the laws of the Commonwealth of
Pennsylvania having its principal office 6 1/2 E. Mall Plaza,
Carnegie, Pennsylvania 15106, which is assignee of CreditOne, LLC.
CreditOne, LLC. is assignee from DebtOne, LLC, which is assignee
from Household Finance Corporation.
2. Defendant is Mick K. Riegel, an adult individual, whose
current mailing address is 120 West Green Street, Mechanicsburg,
Pennsylvania 17055-1916.
3. Household Finance Corporation and Defendant entered into
a Personal Credit Line Account Agreement dated October 1, 1997. A
L^WOFF, CSSOF copy of said Agreement is in the possession of the debtor, the
COLAVECCHI
YAN&COLAVECCHI original Loan Agreement has been lost, stolen or destroyed.
221 E. MARKET ST.
(ACROSS FROM
COURTHOUSE) 4. Defendant has defaulted on chis Agreement leaving a
P. O. BOX 131
CLEARF/ELD, PA
balance due and owing to Plaintiff in the amount of Ten Thousand
Six Hundred Sixty-nine Dollars and Forty-seven Cents ($10,669.47),
plus interest in the amount of Nine Hundred Fifty Dollars.
5. Plaintiff has demanded payment of the said amount due
under said Agreement but Defendant has refused and still refuse to
pay the same or any part thereof.
WHEREFORE, Plaintiff demands judgment against Defendant in the
amount of Ten Thousand Six Hundred Sixty-nine Dollars and Forty-
seven Cents ($10,669.47).
Atto~ey for Plaintiff
COLAVECCH]
RYAN & COLAVECCHI
2
VERIFICATION
I verify that
and correct. I understand that
subject to the penalties of 18
unsworn falsification to authorities.
the statements made in this Complaint are true
false statements herein are made
Pa.C.S. Section 4904, relating to
CLAIMS RECOVERY SYSTEMS
~ OFFICES OF
tLAYECt~ttl
I~ COLAVECCHI
· MARKET ST,
ROES FROM
JRTHOUSE)
.). BOX 131
~RFIELD~ PA
3
o ~o
SHERIFF'S RETURN -
CASE NO: 2001-00669 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
CLAIMS RECOVERY SYSTEMS INC
VS
RIEGEL MICK K
REGULAR
CPL. MICHAEL EARRICK ,
Cumberland County~Pennsylvania,
says, the within COMPLAINT & NOTICE
REIGEL MICK K
DEFENDANT , at 0019:02 HOURS,
at 120 WEST GREEN STREET
MECHA/qICBSURG, PA 17055
MICK K. REIGEL
a true and attested copy of COMPLAINT
Sheriff or Deputy Sheriff of
who being duly sworn according to law~
was served upon
the
on the 6th day of February , 2001
by handing to
& NOTICE
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing 18.00
Service 5.58
Affidavit .00
Surcharge 10.00
.00
33.58
Sworn and Subscribed to before
me this /~ ~-- day of
So Answers:
R, Thomas Kline
02/07/2001
JOSEPH COLAVECCHI
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CLAIMS RECOVERY SYSTEMS,
INC., Assignee from
CREDITONE, LLC, Assignee
from DEBTONE, LLC, Assignee
from HOUSEHOLD FINANCE
CORPORATION,
Plaintiff
Vs.
MICK K. RIEGEL,
Defendant
CIVIL DIVISION
No. 01 - 669 Civil Term
PRAECIPE FOR JUDGMENT
Filed on Behalf of:
Plaintiff, CLAIMS RECOVERY
SYSTEMS, INC.
Counsel of Record for This
Party:
JOSEPH COLAVECCHI, ESQUIRE
Pa. I.D. ~06810
COLAVECCHI RYAN & COLAVECCHI
221 East Market Street
P.O. Box 131
Clearfield, PA 16830
814/765-1566
LAW OFFICES OF
COLAVECCHI
[YAN & COLAVECCHt
221 E. MARKET ST.
(ACROSS FROM
COURTHOUSE)
~. O. ROX 131
CLEARFIELD, PA
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CLAIMS RECOVERY SYSTEMS, INC.,
Assignee from CREDITONE, LLC,
Assignee from DEBTONE, LLC,
Assignee from HOUSEHOLD FINANCE
CORPORATION,
Plaintiff
vs.
MICK K. RIEGEL,
Defendant
: No.
01 669 - Civil Term
PRAECIPE FOR JUDGMENT
TO: PROTHONOTARY OF CUMBERLAND COUNTY
LAW OFFICES OF
COLAVECCHI
~'AN & COLAVECCHI
221 E. MARKET ST.
(ACROSS FROM
COURTHOUSE)
P.O. BOX 131
CLEARFIELD~ PA
The Defendant,
6, 2001, and no answer having been filed,
notice was then served on MICK K. RIEGEL
being attached to this Praecipe.
to the Complaint, please assess
1. Amount of Debt:
2. Interest from 2/1/01 to
3/13/01:
3. Costs:
TOTAL AMOUNT OF JUDGMENT:
MICK K. RIEGEL, having been served on February
a further ten (10) day
on February 28, 2001,
No answer still having been filed
damages as follows:
$10,669.47
$ 71.75
$ 79.08
$10,820,30
Attorney for Plaintiff
AFFIDAVIT
JOSEPH COLAVECCHI, ESQUIRE, being duly sworn according to law,
deposes and states as follows:
The last known address of judgment creditor is 6 ~ East Mall
Plaza, Carnegie, Pennsylvania 15106.
The last known address of judgment debtor is 120 West Green
Street, Mechanicsburg, Pennsylvania 17055~1916.
I hereby certify that according to Rule 237.1 et seq., notice
to Defendant was given as indicated by a copy of Important Notice
attached hereto and made a part hereof.
LAW OFFICES OF
COLAVECCHI
RYAN & COLAVECCHI
221 E. MARKET ST.
(ACROSS FROM
COURTHOUSE)
P. O. iSOX 131
CLEARFIELD, PA
IN THE COURT OF COMMON PLEAS OF CUMBERLJkND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CLAIMS RECOVERY SYSTEMS, INC., :
Assignee from CREDITONE, LLC, : No.
Assignee from DEBTONE, LLC, :
Assignee from HOUSEHOLD FINANCE
CORPORATION, :
Plaintiff :
Vs. :
MICK K. RIEGEL, :
Defendant :
01 - 669 Civil Term
LAW OFFICES OF
COLAVECCHI
RYAN & COLAVECCHI
221E. MARKET ST.
TO:
MICK K. RIEGEL
120 West Green Street
Mechanicsburg, PA 17055
DATE OF NOTICE: February 28, 2001
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION
REQUIRED OF YOU IN THIS CASE. UNLESS YOU ACT WITHIN TEN (10) DAYS
FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU
WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT
RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU
DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP:
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle,249-3166 PA 17013 /~%x~%~~
800/990-9108 ~ ~
JOa,E~ COLAVECCHL E~QUIRE
221~East Market Street
P. O. Box 131
Clearfield, PA 16830
o