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Home My WebLink About11-0591c OF THELPR07NONOTARY 1011 JAN 20 PM 2: 43 CUMgERLANOCOUNTY PENNSYLyAN1A IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHASE BANK USA, N.A. Plaintiff vs. REXFORD HUTZELL Defendant No: /)-?? ( 1U?1 COMPLAINT IN CIVIL ACTION FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: Oqa -GG Aq y (,a V*t h6d-?' James C. Warmbrodt,42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 (412) 434-7955 FAX: 412-338-7130 08468489 C A Pit KMJ I I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHASE BANK USA, N.A. Plaintiff vs. Civil Action No REXFORD HUTZELL Defendant COMPLAINT 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 ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 l COMPLAINT 1. Plaintiff, CHASE BANK USA, N.A. is a corporation with offices at 200 WHITE CLAY CENTER DR NEWARK , DE 19711 . 2. Defendant , is adult individual(s) residing at the address listed below: REXFORD HUTZELL 1058 HEMLOCK LN ENOLA, PA 17025 3. Defendant applied for and received a credit card issued by Plaintiff bearing the account number 5466042007514373 . 4. Defendant made use of said credit card and has a current balance due of $12922.31 . 5. Defendant is in default by having not made monthly payments to Plaintiff thereby rendering the entire balance immediately due and payable. 6. Plaintiff avers that the Agreement between the parties provides that Defendant will pay Plaintiff's attorneys' fees. 7. Plaintiff avers that such attorneys' fees will amount to $300.00 . 8. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed and/or refused to pay the principal balance, and accrued interest or any part thereof to Plaintiff. Wherefore, the Plaintiff prays for judgment against Defendant , REXFORD HUTZELL , individually , the amount of $12922.31 with continuing interest thereon at the statutory rate of 6.00001 per annum from December 02, 2010 , plus attorneys fees of $300.00 and costs. James C. WELTMAN) 436 Sev 08468489 C A Pit KMJ Pittsb (412) 3 FAX: 2 This law firm is a debt collector attemp our client and any information obtained armbrodt,42524 EINBERG & REIS CO., L.P.A. Avenue, Suite 1400 PA 15219 7955 38-7130 to collect this debt for be used for that purpose. 8468489 SMINVI $It for aooowd Malabar: BOSS 0420 07514373 Near Bslutw Pay, w. Due Dar Pesl DuaAmount Aarlmum Payrnarn $12,92231 12/25!08 $2,666.78 $6,036,09 wryelr Oswvio 7tlhe r: (abbe Cana r Semle PfeaNle/es /Ilalelt endpeed. Nw/ address or a-eh/i? Print on bade 546604200751437300503909012922310000007 2imm z3on o REXFORD HUTZELL 140 MT HOPE RD SOUTH FORK PA 160664000 CHASE() 1111111.1.111III N 11.11111111111111111 J. N 811111.11111111111 CAROMEMBER SERV ICE PO BOX 15153 WILMINGTON DE 105054153 1...1111.1.1111111.1.16161111111111111.11.11.1.111111..11 1:5000 i60 281: 077 20075 ;4373 218 CHASE 0 °?rhn P Due oar °?MOa"'0 D.I.: 11!08818.1206100 CUSTOMER SERVICE 12115818 I U S i Peyrssnt Dus: n . . -800-045.2000 $6.030.00 Espe tel 13911448.3308 TDO 1-900.065.0060 Pay birch" 13004367058 Outside U.S. call aollecl Mnmun Payment Due for Credl Access Una $485.90 1-302-604.0200 Payment Due for Balance Over Credit Access Une $1.922.31 ACCOUWINr2U1RIES Pest Due Amount $2,656.78 15298 P.O. Box Total Minimum Payment Due 1Mlrmrglon. n, DE DE 19050.6209 PAYMENT ADDRESS P.O. Box 15153 WORLD NASTERCARD SUMMARY Asa, - Nnttbar: S49912Q007Sf 4373 VWrNWn, DE 198W-61S3 Previous Balance $14590.03 Creels Access Line $11,000 VOT US AT: Purchases, Cash. Debts «$30.00 Available C1sd'n $0 Finance Charges +5292 45 Cash Access Une $2,200 New Balance l-ZS22.3 AveOabfe for Cash so The outstanding balance on your credit card accoum is scheduled 10 be written o9 as a bad debt Shw#Y• AS • remit. your radt bttresu Will be updated WM a reprise refng OBI could had for up 10 sewn yeas. We tan eM help, but you reed to cW us now al 1386702-7547 (collect 1302.6949200). FLEY?LF pEW?pp6 C1lYe!ARV' To redsom yaw Fieldale Rawarda pont4 lady Preliws pour halnc?e 0 1-0003034265, or log on to Points esnedon plrChOM Ma period 0 wow.chesa.OmNvadicards for 244MM -com New Was point faW+ee 0 a you rawaida program. TRANSACTIONS Trans Amount Date Reference Number Merchant Nana or Trrhea lion Dow"on Credit Debit 00 FINANCE CHA Finance Charge Deily Periodic Rats CwsW Average Daily DueTb Transaction Aomrnlawd FINANCE Caagwy 30 days in cede APR Balance Periodic !ere Fee Fin Charge CHARGES Purchases V .0760% 27.09% $7.886.05 $10143 $0.00 $0.00 $101 43 Cash adva an V .07688% 27.00% 5370.31 $8.52 $0.00 $000 $8.62 CorwsnMhce dm* V .078w% 27.00% $2.141.10 $0.25 $0.00 50.00 $40.25 Balancatrrhror V .07600% 27.90% $2,310.27 58320 50.00 5000 $63.20 Total Inane changes, $292.40 EtraOhre Annual pMOardage Rare (APR): 27.$86 Rsaas on nlormeroan About Your Accourl section for fh/Ierh, computation method. pace period, and other Imporrr,l information The ConaepwhdNg APR isffe rme of interest you pay when you cerrya bWwwo on arty vssesmon cwnwy. The EBnllve APR repressna your lose! finance charges - ncudi g frnaas0on sea such r cash advance and balance transfer fees - expressed as a priamep. This Statement In a Fecstmlle - Not an adgkol eDoom fee3asoe me N Z es GMZM Mirldh MM MAMA 2dM$ 31010 rest 1( DDes EXH1IBIT 2Of3 VERIFICATION The undersigned is an Officer of Chase Bankcard Services, Inc., which is a subsidiary and agent of the Plaintiff that maintains the records and services the credit card accounts owned by the Plaintiff. The undersigned is authorized to make this verification for and on behalf of the Plaintiff and is familiar with Plaintiffs account in this matter. Based upon my review of the Plaintiffs books and records of Defendant's account(s), I have personal knowledge of the facts set forth in the attached pleading. Records such as these are kept in the regular course of the Plaintiffs business and it is the regular course of Plaintiffs business to maintain these records, These records and the entries thereon are made at or near the occurrence in question by, or from information transmitted by, a person with knowledge of the account. This verification is made subject to the penalties of 18 Pa.C.S.A. §4904 relating to unsworn falsification to authorities. (' ature) CM& WWR# 08468489 C A Pit KMJ Client Account # 5466042007514373 Name REXFORD HUTZELL SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ?o,?y?1r of ?urrrGrfifa?b r ILEO-OFFICE ("F TFE PROTHONOTARY 2311 JAN 27 PM 12* 41 CUMBERLAND COUNT PENNSYLVANIA Chase Bank USA, N.A. vs. Rexford Hutzell Case Number 2011-591 SHERIFF'S RETURN OF SERVICE 01/25/2011 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Rexford Hutzell, but was unable to locate him in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant Rexford Hutzell. Request for service at 1058 Hemlock Lane, Enola, Pennsylvania 17025 the defendant was not found. Current residents advised Deputies, the defendant has not resided at this address in the past 5 years. SHERIFF COST: $41.50 January 25, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF s: `ou Ito Sh e ; t m:: ;HOP OTW WE TMAN, WEINBERG & REIS CO., L.P.A. 3, BY: Sarah E. Ehasz Attorney for Plaintifol ?n 25 PM I.D. No. 86469 436 Seventh Avenue, 1400 Koppers Bldg CUMBERLAND COUHTv Pitts urgh, PA 15219 PENN5YLVAHIA Phone: 412.434.7955 Fax: 412.434.7959 File 8468489 CHI SE BANK USA, N.A. Plaintiff CUMBERLAND County Court of Common Pleas vs. RD HUTZELL Defendant(s) No.: 11-591 CIVIL PRAECIPE TO DISMISS WITHOUT PREJUDICE TO REFILE TO THE PROTHONOTARY: ndly dismiss the above matter without prejudice to refile. WELTMAN, WEINBERG & REIS CO., L.P.A. By f .11 Sarah E. Ehasz Attorney for Plaintiff