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HomeMy WebLinkAbout11-0779 41_E0-0j r Icy. TFc U??DOTAt, s ITY 14 cGUI 1 1,. 1 V? Y a! E a IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION WORLD FINANCIAL NETWORK NATIONAL BANK Plaintiff vs. ROBERT E WELCH Defendant No. a.D11- 7?q 0,vl, I IP-rPA COMPLAINT IN CIVIL ACTION FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan, Esquire PA I.D. #47437 Weltman, Weinberg & Reis, CO L.P.A 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#7355370 39D8 ga IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION WORLD FINANCIAL NETWORK NATIONAL BANK Plaintiff vs. Civil Action No. ROBERT E WELCH Defendant 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 CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 COMPLAINT 1. Plaintiff is a corporation with offices in 220 W SCHROCK RD, WESTERVILLE, OH 43081. 2. Defendant, is an adult individual residing at 73 GASOLINE ALY, CARLISLE, PA 17013. 3. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXX8127. 4. Defendant made use of said credit card and currently has a balance due and owing to Plaintiff, as of June 15, 2010, in the amount of $8,110.15. A true and correct copy of Plaintiff s Statement of Account is attached hereto, marked as Exhibit "1" and made a part hereof. 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. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed and/or refused to pay the principal balance, or any part thereof to Plaintiff. WHEREFORE, Plaintiff demands Judgment in its favor and against Defendant, Robert E Welch individually, in the amount of $8,110.15 with continuing finance charges thereon at the statutory rate of 6.00% per annum from the 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. 4zl- ?-)' William T. Molc?eln, Esquire PA I.D. #47437 Weltman, Weinberg & Reis, CO L.P.A 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR4;7355370 EXHIBIT Page 1 of 1 This Month's Activity: Tran Dab Reference No Plen/t3eq Transaction Description Amount 0112912009 0000000 001 LATE FEE $39.00 a a?'r We are attempting to work with you. If payment in not received your account will be turned over to our Recovery Division. To make a payment by phone using your bank account, or to discuss payment arrangements, please call 1.866-256.6643. How can you take charge against ID Theft? Visit www.idthett.gov to find out. NOT1CE: S¦e fnVere@ side fbr Important fnformatfon t Pleasetear e-rforationobove I Account Payment must reach Numbs 8127 us by 2 pm ET on: New Balanos Minanum Payment Today 7 934.39 $1,783.00 i Yes, I have moved or updated Please make checks payable to: E-M¦U-See Reverse WFNNB - GANDER MASTERCARD Amount Enclosed 'IIIIIIIII„Illlrrl?'Il???rl?lltllll?ll?ll?"1?'1i1illl?l?ll???"?a?? ?? ROBERT E WELCH ¦ 73 GASOLINE ALY CARLISLE PA 17013-8819 Please return this portion with your payment to: PO BOX 659569 SAN ANTONIO TX 78265-9569 19505004 00006789 1? 8127 00178300 00793439 , I VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA. C.S. 4904 relating to unsworn falsifications to authorities, that he/she is m u?4, "ZA (NAME " (TITLEL ? of ,Q1lj ?,„ ?t t7 ?-} , ) ,plaintiff herein, that he/she is duly authorized to make this verification, and that the facts set forth in the foregoing Complaint in Civil Action are true and correct to the best of his/her knowledge, information and belief. - t, ?-- ? (SIGNATURE) WWR# 7355370 WELT AN, WEINBERG & REIS CO., L.P.A. c c?a BY: Sar h E. Ehasz, Esquire Attorney for Plaintiff(s) _0= I.D. No.8 469 z? rte- z © 436 Seve th Avenue, Suite 1400 vr" Pittsburg , PA 15219 D CD 4 - Phone: 4 2.434.795 0 rn o- Fax: 412. 34.7959 zo xo File # 73" 5370 )> WORLD FINANCIAL NETWORK NATIONAL BANK Cumberland County Court of Common Pleas ROBERT 'E WELCH NO. 2011-779 CIVIL TERM PRAECIPE FOR SATISFACTION OF JUDGMENT TO THE Court ARY: kindly Satisfy the Judgment of the above-captioned matter upon the records of the mark the cost paid. WELTMAN, WEINBERG & REIS CO., L.P.A. By Sarah E. Ehasz, Esquire Attorney for Plaintiff Sworn td and subscribed Before I NOT the ,2 y "' day of June, 2011 PUBLIC SYi ANIA COMMONWEALTH @F PENN Notarial Seal Sheila G. Bevan, Notary Public Ross Twp., Allegheny County My Commission Expires Nov. 15, 2014 MEMBER, PENNSYLVANIA ASSOCIATION O -NOTARIES am? *9A ?a 10 1? Ck)W sai 9s50 ?2, 4 44W3b`t