The URL can be used to link to this page

Home My WebLink About10-7379 ~~ r~ ~~wRa Novo ~- 201Q IdOy 30 AM 9: ~ ~ ~~MBERt,gND C~UNT~~ PEHNSYLVAR}~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA EQUABLE ASCENT FINANCIAL, LLC I CIVIL DIVISION f/k/a Hilco Receivables, LLC 1 assignee of Chase Bank USA,N.A.1 I Plaintiff (s) , 1 ~~~~ I No. 2010 ~. v. 1 I DONALD J. HARTMAN, 1 an individual 1 I I Defendant(s), 1 I I COMPLAINT I I I Code No. I I Filed on Behalf of: I I PLAINTIFF I I I I ATTORNEY OF RECORD FOR THIS PARTY I I Louis B. Swartz I I PA. ID # 00242 I I ISWARTZ, LOVEJOY & ASSOCIATES 116th FLOOR LAW AND FINANCE BUILDING (PITTSBURGH, PENNSYLVANIA 15219 I I ((412) 288-0303 #706722 NOTE: THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE s cum' ~ ~ ~a' ~O o c,~',~ ~~ c~ ~~ as #706722 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), No. 2010 v. DONALD J. HARTMAN, 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 NOTDEFCU.PLE i d?'c7=_ 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), No. 2010 - 7 3 79 c~~~ v. DONALD J. HARTMAN, an individual 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 DONALD J. HARTMAN, an individual. Defendant's address is 228 EWE ROAD, MECHANICSBURG PA 17055. 3. On or about January 31, 2000, Defendant entered into an agreement with Plaintiff's assignor for the purpose of obtaining a credit card account, which Plaintiff's assignor granted to Defendant. The application may have been written, taken by telephone or over the internet. True and correct copies of the documents of Defendant's account with Plaintiff and/or Plaintiff's assignor are attached hereto as Exhibit "A". 4. Defendant thereafter used the account and made the charges thereto for which there is a balance remaining of $13244.81 which, despite repeated demands, has been overdue, owing and unpaid ever since June 24, 2009. Alternatively, Defendant obtained the benefit of the use of the account and was unjustly enriched thereby. Alternatively, Plaintiff presented Defendant with an account stated for the balance due based upon the running credit account, which Defendant accepted. WHEREFORE, Plaintiff demands Judgment against ~ndant(s) in the amount of $13,244.81 Plus legal interest and costs. Louis B. Swart z Attorney for PLAINTIFF SWARTZ, LOVEJOY & ASSOCIATES 16th FLOOR LAW AND FINANCE BUILDING PITTSBURGH, PENNSYLVANIA 15219 (412) 288-0303 k~0E~2_ 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), No. 2010 v. DONALD J. HARTMAN, 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 I~1C'~`_~F?~D. PLE STATE OF ILLINOIS COUNTY OF LAKE Equable Ascent Financial, LLC f/k/a Hilco Receivables, LLC Plaintiff, vs. HARTMAN/DONALD J Defendant Docket # I, 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. I 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 f/k/a 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. 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 $13244.81 plus interest of $0.00, totaling $13244.81. 9. 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. 11. 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 Hilco Receivables, LLC . By: _ Name: It ~ egal gency Network Manager Sworn to and Subscri ed before me ~s day of , 20 ~~ Notary Public / , ~~~~~V ~~~L ~~-- J ~_\\ - OFFICIAL SEAL NANCY COHEN NOTARY PUBLIC -STATE OF ILLINOIS MY COMMISSION EXPIRES:p5109114 79 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff FILED-OFFICE OF' THE PROTHONOTARY Jody S Smith Chief Deputy Richard W Stewart Solicitor 2010 DEC -9 PM 4: 20 tCUMBERLAND COUNTY PENNSMIAN1A Equable Ascent Financial, LLC vs. Donald J. Hartman Case Number 2010-7379 SHERIFF'S RETURN OF SERVICE 12/02/2010 05:49 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on December 2, 2010 at 1749 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Donald J. Hartman, by making known unto Suzanne Hartman, Wife of defendant at 228 Ewe Road, Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $37.00 December 03, 2010 RYAN BURGETT, DEPUTY SO ANSWERS, RON R ANDERSON, SHERIFF (Ci t.;Ctl^;fr 5?i(C $h:;r.'f. (E'le Us0!t. I.''.i.