The URL can be used to link to this page

Home My WebLink About11-2120 Ft 22 n r- ? } s ??v? ?. ? F IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHASE BANK USA, N.A. Plaintiff No: /1-.2/20 VS. COMPLAINT IN CIVIL ACTION JONI M RAUDABAUGH Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt,42524 WELTMAN, WEI:NBERG & REIS CO., L.P.A. 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 (412) 434-7955 FAX: 412-338-7130 08799502 C A. Pit KMJ o/- 'O?U all 16%,'dlw!?ke l i l IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHASE BANK USA, N.A. Plaintiff vs. Civil Action No JONI M RAUDABAUGH 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 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: JONI M RAUDABAUGH 800 UPLAND ST MECHANICSBURG, PA 17055 3. Defendant applied for and received a credit card issued by Plaintiff bearing the account number 5183377560126443 . 4. Defendant made use of said credit card and has a current balance due of $2719.77 . 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 , JONI M RAUDABAUGH , individually , the amount of $2719.77 with continuing interest thereon at the statutory rate of 6.0006 per annum from January 12, 2011 , plus attorneys fees of $300.00 and costs. ames 436 08799502 C A Pit KMJ Pitt (412 FAX: This law firm is a debt collector atte our client and any information obtaine WEINBERG & REIS CO., L.P.A. nth Avenue, Suite 1400 gh, PA 15219 4-7955 -3,38-7130 to collect this debt for be used for that purpose. Payment Due Date New Balance Past Due Amount Minimum Payment 08/07/10 $2.71 a T7 $906 ho $937 DO Accotitrlt roan der: 51a9 3775 6012 6443 . in year check payable to 7 Chase Card Services. Phase _40 amount enclosed Now address a ?me01 Print on bad 51833775601264430009370000271977000000000000003 ssem M z tattoo JONI M Ft11UDABAUGH 800 UPLAND ST MECHANICSBURG PA 1 7055 43 55 1:50001,60 281: 1.06756D L 261.1.30os slate. 8 Mana9s year aeeaure aallea: Addltlonal contest Information h- atwse0 wow dW mmrmed"eam. cmweliently Imeted on reverse ado 8799502 ACCOUNT SUMMARY Aoeoun Number 5103377560126443 Previous Balance $2.615.40 Fees Charged +$39.00 Interest Charged .$65.37 New Balance $29719977 Opening/Closing Date 06111/10 - 07/10/10 Total Credit Une $2.400 Available Credit $0 Cash Access Line $2.400 Available for Cash $0 CARDMEMBER SERVICE PO BOX 15153 WILMINGTON DE 19886-5153 PAYMENT INFORMATION New Balance $2.719.77 Payment Due Date 08/07/10 Mlnmum Payment Due $937.00 Late Payment Wamino It we do not receive your minlrnum payment by the date listed above. you may have to pay up to a $39.00 lap tae and your APRs will be Subject to increase to a maximum Penalty APR of 29.99%. Wnimurtt Payment ylhrnlny: 11 you make only the mint mum payment each period. you will pay more in interest and it will take you longer to payoff your balance For example. If you make no You will pay oft the Arid you wild and up additional charges balance Shown on paying an estimated using his cord and this Statement in tots] cl each month you about. pay Only the minimum 24 years $9,134 payment fl you Would like Infomlation about credit counseling services, call 1-866-797-2885 The outstanding balance on you credit card aeeourd is scheduled to be written o8 as a bad deb Shortly As a result, your credit bureau will be updated with a negative rating that could last for up to seven yews. We ern Still help. but you need fo call us now at 1-888-792.7547 (collect 1-302-5948200) Imponam Message You Are Ovedimit Your Statement balance exceeds you credit line. You should make a payment that ndudas he overlmli amount to bring he balance Linder you credit line. TMs account is closed and not evadable for new trensections. If there 1,S a balance please continue to make payments by the due dale ACCOUNT ACTIVITY Date of Transaction Merchant None or Transaction Descnpbon $ Amount "0: 07107 LATE FEE 39.00 TOTAL FEES FOR THIS PERIOD $39.00 MFl:Gll#!t# 07/09 PURCHASE INTEREST CHARGE 65 37 TOTAL INTEREST FORTHIS PERIOD $65.37 #Cf •Y?NY?f01i1111: Total lees charged in 2010 $234.00 TotahrilereslTOla1 charged in 2010 $357282010 $35728 Yew-to-dale total$ reflect all charges minus any refunds applied to your account on or alter January 31, 2010 This Statemelr>rt Is a Facsimile - Not an original ODODDDt F1 33M DO 000 N 2 to 10WA a Pao* i d2 0096 MAMA 52961 160100000aD0052eet Ot R 2 of 5 slatemem Dale 06111/10 - 07110110 Account Nurnoer 5183 3775 6012 6443 Page 2 o1 2 INTEREST CHARGES Your Annual Percerttaga Rate (APR) is the amual interest rate on your account. Annual Balance Accrued Balance Percenthge Rate(APR) Subject To lnteraat Interest Type 30 Days In Cycle Interoat Rats Charges Charges Purchaaee 20. Da%(v) $2.66200 $65.37 $000 Cash Advancee 29.00%(V) $000 $000 $o 00 (v) = Yenabe Rate Please cues Mormauon About Your Account section for the Calculation of 8alnoe Sutiecl to Interest Rate. Annual Renewal Notice How to Avoid Interest on Purchases, and other important ellonnation, as appkcaWe 8799502 This Statement Is a Facsimile - Not an original x OD00001 RS33MODe ow N z 10 1010?110 Fes202 Mass 1N1M WWI 1001000CCRODOSM102 4 of 5 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. "--? -Z (Signature) Rwoe& toe& WWR# 08799502 C A Pit KMJ Client Account # 5183377560126443 Name JONI M RAUDABAUGH