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Home My WebLink About11-1037I t FILED-OFFICE rI F PRO:urttTi,n y 2#?I 1 JAN 31 AM I I: cp, CUMBERLAND COUNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHASE BANK USA, N.A. Plaintiff No: ??- ?G?>? C?? ?f vs. COMPLAINT IN CIVIL ACTION SUSAN P COOL Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: 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 08547684 C A Pit KMJ t'k?q LI k?? LIED IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHASE BANK USA, N.A. Plaintiff vs. Civil Action No SUSAN P COOL 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 F 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 an adult individual(s) residing at the address listed below: SUSAN P COOL 80 HERSHEY RD SHIPPENSBURG, PA 17257 3. Defendant applied for and received a credit card issued by Plaintiff bearing the account number 5187484240073221. 4. Defendant made use of said credit card and has currently a balance due of $14649.03. 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 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, Plaintiff prays for judgment against Defendant, SUSAN P COOL individually, in the amount of $14649.03 with continuing interest thereon at the statutory rate of 6° per annum from November 26, 2010, plus attorneys' fees of $300.00 and costs. WELTMAN, WEINBERG & REIS, CO., L.P.A. James C Warmbrodt, 42524 436 Sev n h Avenue, Suite 1400 Pittsb , PA 15219 (412) 7955 Fax ( 338-7130 WWR#: 5)446684 THIS IS AN ATTEMPT TO COLLECT A AND ANY INFORMATION OBTAINED SHALL BE USED FOR THAT PURPOSE. I Payment Due Dale New Balance Peel Due Amount Miniature Payment 07101110 514,649.03 32,951.00 $3,07400 AeoatbM tltnttba: 81.7 41!41 41007 3 21 . miles VON aftell "Mile"; chase Cad servtus. PMaeshwes snood Widow. New address a e•nsi9 Print on o". 51674842400732210030740001464403000000000000001 SHA?N z?L SSIAREBYURG PA 172574407 1,..111...1..1.1.1.1.1...161...1..111...1...11..1. n...ll l..i I...11111..1.J.I..L.IL..I.I....u.l.l...n.a,6..11..n..1 CAROMEMBER SERVICE PO BOX 15153 WILMINGTON DE 19/1666153 tl: 5000 i60 28tl: 4 104 2400? 3 2 2 i8r slate- u 8 R ng s yew aacaatemm* AddW6wW contest lotomnWn loco 04ASEO tlRtetr.A w.aomtsudoeeatlt Corms wfyiocuw rwwneds ACCOUNT SUMMARY PAYMENT INFORMATION Aceaan Number: 5107 JIM 4007 3441 Now Balance $14,649.03 Previous Balance 514,372.45 Payment Due Date 07001110 Fees Charged 439.00 Mrimum Payrna t Due $3,074.00 Inleresl Charged ?S237.58 Lao, payrrnan Waning: Itwe do not rodiw your minim yin New Balance 0149 $14 03 past by the dots baled above, you may have to pay up 10 a , . $39.00 IoM %a and your APRs sell be subject 101 IQ too OpeninylClosing Date 051owlo - 06104110 maximum Pauly APR 0129.09% To1si Credit tins $13 600 Mlnltolnn Payment Warning: It you make only the minimum , payment each pwk4 you will pay more in intent and 111WR tale Avalatle Credit 3o you longer to pay dl your balance. For a wvj3W Cash Access Line 310,880 Available for Cash 50 It you make no additional charges You will pay off Me balance shown an And you will end up paying on estimated using this cord and 1111 otg*n nit in total of ... each month you about.. Pay... Orly the mnimum 36 yew 342.356 payment 5541 3 Yeare $19,469 (SaNngs4U.697) It you would like information a0cul credit counseling serhltces, call 1-666797.20115. The outstanding balance on you oradh cord account Is sc hedulad to be written oil as a bad debt shortly. As a result your credit bureau will be updated teM a negaaw rating the could IW to up to swan yews. We con still help, but you need 10 CON us now at 1-896-792.7547 (ooted 1-302-594.8200). Important Meeesgs: You Are Overiniti Your alalsment balance exceeds your credit ine. You should make a Payment that includes the overlimd amount to bring his, balance under you Credit line. IACCOUNT ACTH" 1 Date d Transaction Merchant Names Transaction Deacriplon SAmount :;i; \? •;1\ti:. \\\w>..'\?:., •:?"t: •,;:ti?:;3 :`So i;• ;&%?:. '•ii?:£R ?.iu•,?;,'; \ > t\:w . ..KM. -I?t':INMR.+4.•'.x,\\\.\ 06%Ut LATE FEE 3900 TOTAL FEES FOR THIS PERIOD $39.00 :::?:s:>??>yk:>:.?.z?s,:?ti'•,a?w,?.,?-:`?,y?,\ ???1?}.,,`y,, ,?' R? .. ? ... ? '?<`:1?`i?:;::>r:s;>z':\??:?;?;;'.. ?:fi"v`.,Z:' ..^:'•:\ 06/04 ,...?, PURCHASE INTEREST CHARGE .17 17 8 06104 PURCHASE INTEREST CHARGE 8660 06104 CASH ADVANCE INTEREST CHARGE 166.01 TOTAL INTEREST FOR THIS PERIOD $23758 7", FF [Tovilintared al lose Charged In 2010 $156.00 charged in 2010 $1,112.99 Year-to-dole lolals felled all charges mime any rolunds applied 10 your account on or attar Janus" 31, 2010. 8547684 Thus Statement Is a Facslmlle - Not an original 0000001 FM3139e O e area N Z 01 100=4 Poe l 02 ona MAMA am? 155100000aDOD$3wol X INS110fa 2of5 Statement Dale: 06!06/10 - 08104110 Aomm Number: 61874842 4007 3221 Page 2 of 2 INTERIMT CHMG Your Annual PeroonaW RaN (APigh 9n annual Imerew mu on your account 8547684 Annual Balance Memel Balance PeroentsBe Raba (APR) Subject To IrnIN" hlNrast Typo 31 Days In Cycle In IN Role Charges Charges Purchases 19.24%M $4,196.06 $8860 20.00 Purchases 29.99%(v) $66.17 $2.17 $0.00 Cash Advances 19.Z4%(v) $70,208.66 11168.81 $0.00 Cash Advances 29.99%M 110.00 $0.00 $0.00 M • vanade Fate Pines "a hlomwaon About Your Account section for to Calculation of Balance Subied ID Inbrew Ran, Annual Rene" Notice, How to Avoid Internal on Purctases, and outer important i dortrstion, as applicable. This Statement Is a Facsimile - Not an o111ghul x 0000M RsameDe 000 N Z a 10'0a06 PW2d2 00tH YW AM MW 153taoa00s0o a9s87o2 4 of 5 F 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 Plaintiff's account in this matter. Based upon my review of the Plaintiff's 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 Plaintiff's business and it is the regular course of Plaintiff's 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. (Signature) WWR#8547684 Client Account 45187484240073221 Name SUSAN P COOL SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor +a .? pi c,.f,x l 't t, ! FED' -8 PM I?: f '. r' kgdC' ;}I. Chase Bank USA, N.A. Case Number vs. Susan P. Cool 2011-1037 SHERIFF'S RETURN OF SERVICE 02/02/2011 12:30 PM - Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on February 2, 2011 at 1230 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Susan P. Cool, by making known unto herself personally, at 80 Hershey Road, Shippensburg, Cumberland County, Pennsylvania 17257 its contents and at the same time handing to her personally the said true and correct copy of the same. TIM BLACK, DEPUTY SHERIFF COST: $46.00 February 03, 2011 SO ANSWERS, RONW R ANDERSON, SHERIFF WELTMAN, WEINBERG & REIS CO., L.P.A. BY: Sarah Ehasz, Esquire I.D. No. 86469 436 Seventh Ave, 1400 Koppers Bldg Pittsburgh, PA 15219 Phone: 412.434.7955 Fax: 412.434.7959 File # 8547684 CHI Attorney for Plaintiff(s) CHASE BANK USA, N.A. vs. SUSAN P COOL CUMBERLAND County Court of Common Pleas No.: 11-1037 CIVIL PRAECIPE TO DISMISS WITH PREJUDICE TO THE PROTHONOTARY: Kindly dismiss the above matter with prejudice. G"1 rV C^ rn CD =-n z? r -am °° r-X sa ? = = ? >= w °m WELTMAN, WEINBERG & REIS O., L.P.A. By Sarah Ehasz, Esquire Attorney for Plaintiff