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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