HomeMy WebLinkAbout04-34731N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PALISADES COLLECTION, LLC, ASSIGNEE
OF PROVDIAN BANK
Plaintiff
VS.
LINDA K KOSER
Defendant
COMPLAINT IN CIVIL ACTION
FILED ON BEHALF OF
Plaintiff
COUNSEL OF RECORD OF
THIS PARTY:
Sofia Kokkini, Esquire
PA I.D. #91535
WELTMAN, WEINBERG & REIS CO., L.P.A.
2718 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR#03416857
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CWIL DIVISION
PALISADES COLLECTION, LLC, ASSIGNEE
OF PROV1DIAN BANK
Plaintiff
VS.
LINDA K KOSER
Defendant
Civil Action No.
COMPLAINT IN CIVIL ACTION AND NOTICE TO DEFEND
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 (20) days after this complaint and notice are served, by
entering a written appearance personally or by an 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 other 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE
YOU WITH iNFORMATION ON AGENICES 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
(717) 249-3166
COMPLAINT
Plaintiff is a corporation with offices at P.O. Box 1244, Englewood Cliffs, NJ 07632.
17257.
Defendant is an adult individual residing at 123 Mainsville Road, Shippensburg, PA
3. Defendant applied for and received a credit card issued by Plaintiffs assignor bearing the
account number 4361451000549667. A true and correct copy of Plaintiff's Statement of Account is
attached hereto, marked as Exhibit "1" and made a part hereofi
4. Defendant made use of said credit card and has currently a balance due and owing to
Plaintiff, as of June 23, 2004, in the amount of $1,959.30.
5. Defendant is in default of the terms of the cardholder Agreement having not made monthly
payments to Plaintiff thereby rendering the entire balance immediately due and payable.
6. Plaintiff avers that the Cardholder Agreement between the parties provides that Plaintiff is
entitled to the addition of finance charges at the rate of 6.0% per annum on the unpaid balance.
7. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed and/or
refused to pay the principal balance, finance charges or any part thereof to Plaintiff.
WHEREFORE, Plaintiff demands Judgment in its favor and against Defendant, Linda K. Koser
individually, in the amount of $1,959.30 with continuing finance charges thereon at the rate of 6.0% per
annum from date of judgment plus costs.
THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED
SHALL BE USED FOR THAT PURPOSE.
WELTMAN, WEINBERG & REIS, CO., L.P.A.
Sofia Kokkini, Esquire
PA I.D. #91535
WELTMAN, WEINBERG & REIS CO., L.P.A.
2718 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR#:03416857
PALISADES COLLECTION, LLC,
LINDA K KOSER
123 MAINSVILLE RD
SHIPPENSBURG, PA 17257
PALISADES FILE NUMBER
8885974PA
NEW BALANCE
$1959.3
IF ADDRESS AS SHOWN ABOVE IS INCORRECT. PLEASE INDICATE CHANGE BELOW.
ADDRESS
PAYMENT DUE DATE
6/22/2004
PLEASE WRITE IN AMOUNT OF
PAYMENT ENCLOSED
MINIMUM PAYMENT
$1959.3
PLEASE DETACH AND TOP PORTION WITH YOUR PAYMENT
ACCOUNTNUMBER
4361451000549667
DATE REFERENCENUMBER
6/22/2004
CREDIT LIMIT
0
CREDIT AVAIABLE
0
NEW TRANSACTIONS
BALANCE DUE 6/22/2004
PALISADES COLLECTION, L,L.C,
DELAWARE LIMITED LIABILITY CORP,
ASSIGNEE OF PROVIDIAN BANK
P.O. BOX 1244
ENGLEWOOD CLIFFS, NJ 07632
PAST DUE
$1959.3
STATEMENTCLOSING OATE
6/22/2004
AMOUNT
$1959.3
SUMMARY OF TRANSACTIONS
PREVIOUS BALANCE
$1959.3
PROMPT CREDmNG OF PAYMENTS: TO RECEIVE CREDIT FOR PAYMENT AB OF THE DATE OF RECEIPT. WE
MUST RECEIVE THE TOP PORTION OF THE STATEMENT AND YOUR CHECK OF MONEY ORDER BY 3:0(1 PM AT:
PAUSADE$ COLLECTION, L.L.C.
P.O* BOX 1244
ENGLEWOOD CUFFS, NJ 07632
PAYMENTS RECEIVED AT THE ABOVE ADDRESS IN THE MANNER SPECIFIED AFTER THAT TIME WILL BE
CREDffED TO YOUR ACCOUNT AS OF OUR NEXT BUSINESS DAY. THE CREDITING FO YOUR ACCOUNT OF
PAYMENTS RECEIVED AT ANY LOCATION OTHER THEN THE ABOVE ADDRESS MAY BE DELAYED UP TO 5 DAYS
FROM OATE OF RECEIPT
PAYMENTS AND CREDITS
PAYMENT DUE DATE
6/22/2004
SEND INQUIRIES TO:
PALISADES COLLECTION, L.L.C.
P,O. BOX 1244
ENGLEWOOD CLIFFS, NJ 07632
NEW BALANCE
$1959.3
MINIMUM PAYMENT
$1959.3
WWR - File # 3416857
VERIFICATION
The undersigned does hereby verify subject to the penalties of 18 PA. C.S. 4904 relating
isCZ~
to unswom falsifications to authorities, that he/she ~
(NAME)
(TITLE) (COMPANY)
he/she is duly authorized to make this verification, and that the facts set forth in the foregoing Complaint
are tree and correct to the best of his/her knowledge, information and belief.
(SIGNATURE)
Stepl~en Schlicht
Legal Operations Manager
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PALISADES COLLECTION,LLC, ASSIGNEE
OF PROVIDIAN BANK
Plaintiff
No. 43473 CIVIL
VS.
LINDA K KOSER
PRAECIPE TO SETTLE, DISCONTINUE
AND END WITHOUT PREJUDICE TO REFILE
Defendant
FILED ON BEHALF OF
Plaintiff
COUNSEL OF RECORD OF
THIS PARTY:
William T. Molczan, Esquire
PA I.D. fi47437
WELTMAN, WEINBERG & REIS CO., L.P.A.
2718 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR#03416857
iN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PALISADES COLLECTION,LLC, ASSIGNEE
OF PROVIDIAN BANK
Plaintiff
VS.
LINDA K KOSER
Civil Action No. 434%z. CIViL
Defendant
.P.RAECIPE TO SETTLE, DISCONTINUF
AND END WITHOUT PREJUDICE TO REFII r'
TO THE PROTHONOTARY OF CUMBERLAND COUNTY:
SIR:
Settle, Discontinue and End the above-captioned matter upon the records of the Court without
prejudice to refile and mark the costs paid.
SWORN TO AND SUBSCRIBED
before me this ~.~ day
of ~, 2004
WELTMAN, WEINBERG & REIS CO., L.P.A.
Atto-rne) for Plaintiff /
2718 Koppers Buildin~
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR#03416857