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Home My WebLink About11-2903? Y i1M1111-9 !111• NW??IYt\?1 ?1?r. 6ko IN THE COURT OF COMMON PL i EAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHASE BANK USA, N.A. Plaintiff No : I I - yl/ P I 'VI vs DANELLE L MCCANN Defendant COMPLAINT IN CIVIL ACTION 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 08799613 C A Pit SJS ?r # ?SZ F 3c13 IN THE COURT OF COMMON PL?EAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION i I CHASE BANK USA, N.A. Plaintiff vs. DANELLE L MCCANN Defendant Civil Action No AND NOTICE TO DEFEND You have been sued i claims set forth in the f twenty (20) days after th a written appearance pers with the court your defen against you. You are war proceed without you and a court without further not for any other claim or re money or property or othe z court. If you wish to defend against the Dllowing pages, you must take action within is complaint and notice are served, by entering Dnally or by an attorney and filing in writing 3es or objections to the claims set forth aed that if you fail to do so the case may judgment may be entered against you by the ice for any money claimed in the complaint or lief requested by the plaintiff. You may lose r rights important to you. YOU SHOULD TAKE THIERE APER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT ORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT 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 RLMD 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. DANELLE L MCCANN 1296 ASPER DR BOILING SPRINGS, PA 170071 3. Defendant applied forland received a credit card issued by Plaintiff bearing the account number 5466042010552337 4. Defendant made use ofsaid credit card and has a current balance due of $2341.67 I 5. Defendant is in defau?t by having not made monthly payments to Plaintiff thereby render#ig the entire balance immediately due and payable. 6. Plaintiff avers that ?he Agreement between the parties provides that Defendant will pay Plaintiff's attorneys' fees. l 7. Plaintiff avers that ?uch attorneys' fees will amount to $300.00 I . 8. Although repeatedly r'quested to do so by Plaintiff, Defendant has willfully failed and/or r fused to pay the principal balance, and accrued interest or any pkrt thereof to Plaintiff. Wherefore, the Plaintiff prays for judgment against Defendant , DANELLE L MCCANN , INDIVI ;ALLY , the amount of $2341.67 with continuing interest ther from January 10, 2011 , 08799613 C A Pit SJS at the statutory rate of 6.0006 per annum lus attorneys fees of $300.00 and costs. fames u. WELTMAN, 436 SeVE Pittsbu (412) 4 FAX: 4 2 This law firm is a debt c llector attempt'ng our client and any information obtained 11 I i NBERG & REIS CO., L.P.A. venue, Suite 1400 A 15219 55 -7130 collect this debt for used for that purpose. t Payment Due Date New Balance Past Due Amount MlMmum Payment 1418110 $2,361 67 $508 00 $633.87 Account number: 5466 0420 1055 2337 . Make your ¢?rod peyaae to: CheeSeew Crd 9ervkd. Pwre encb New addres or ore-rn ?mei'+ P-mt t on bed 546604201055233700063367001341670000DOOODOO0009 I ,0W88(92aoo L..IILLJ..LL.L.IL..LLa..Ild.ir..Ii..IJ...ILrIL.1 DANIELLE L MCCANN 1296 ASPER DR CARDMEMBER SERVICE BOILING SPRINGS PA 17007-9617 PO BOX 15153 WILMINGTON DE 19866-5153 1:5000 L6028t: 071' 201055 23376110 ? CHASE O ? /11/7'1° -- ge year sii 0 rN Onthro: Additional oontect ifdonmadon ,,/•VV// // // Cmwniantly located on favelsa side PAYMENT INFORMATION Account Number 5086 0420 1055 2337 Previous Balance $2.280 1 Fees Charged 4250 Interest Charged .$36.5 New Balance -_52.361-6 Openng)Cbsing Date OB@v10 - 0921/1 Credt Access Line $2,70 Available Credit Cash Access Line $4i Available to Cash New Balance $2.34167 Payment Due Dale 10118/10 Mirdmum Payment Due $66.00 Balance Over Credit Access Line S4167 Past Due Amount $50800 To tat Minimum Peymerd Due $633 67 Late Payment Warning It we do not m®ive your minimum psymeM by the dab listed above. you may have to pay a late ice of up to $35.00 and your APR's will be subject to Increase to a maximum Penalty APR of 29.99%. Minimum Payment Warning; It you make only the mtrumum payrnere each period you will pay more in interest and it will lake you longer io pay off your balance For example If you make no You will pay off the And you will and up .1iunal charges balance shown on paying an estimated using this card and this statement to total of each month you about. Pay Only the minimum 21 years $5.767 payment $86 3 years $3,083 (Savings=$2.684) If you would like information about credit counseling services, call 1.866-797.2885 The ouisl andmg balanw on your credit card account is dined to be writian of me bad debt shorty Asa resull, your credit bureau will be updated with a negative raling that could last to up to seven years. We can still help, but you need to call us now at 1-888-792-7547(colea 1-302.594-8200) This account is closed and no longer available for use If ytlu have a balance remaining on 1he account, please continue to make monthly paymems by tae due date Thank you Previous points balance 0 Eam art unlimited t% cash tech on all your Points earned on purchases 0 purchases You'll earn a total of 5% Cash Back Bones points from Ultimate Rewards Travel 0 in quarterly, bonus categones that change Bonus poems earned at Ultimate Rewards Mail 0 Signing up is tree and easy! 5% Cash Back Current points balance 0 categories are subject to a quarterly maximurm See full details at chase convtreedom Get 51/6 Cash Back on up to $1500 spent between July 1 a September 30 2010 on Gas, Airlines, Auto Rentals, and Hotels See full details and sign up today at chase comAreedom' Data of Transaction Mercham Nam or Transaction Description $ Amount ... ................... 09/19 LATE FEE 2500 TOTAL FEES FOR THIS P ERIOD $2500 0981 PURCHASE INTEREST CHARGE 1958 09121 CASH ADVANCE INTEREST CHARGE 1693 8799613 TOTAL INTEREST FORT IS PERIOD S3651 00 ao0m Flsst33e be 600 Y 9 21 to t Paget 02 056515 MAMA 10097 2641000DOBOe3106e701 X oaa EXHIBIT 2 of 5 Slatemerd Date 08/22110 - 09/21110 Account Number 5466 0420 1055 2337 Page 2 01 2 T01e1 Is" charged n 2010 $311 13 Total interest cha sd in 2010 $163.94 Year-to-dale total reflect all charges minus any refunds applied to your *count on or attar January 31, 2010 8799613 Your Annual Percentage Rale (APR)is the annual inn at rate on your account. Annual Balance Accrued Balance Percentage Rate (APR) Subjecl To Interest tntmom Type 31 Days in Cycle Interest Rate Charges Charges Purchases 1824%(v) $1.264.04 $lose $000 Cash Advances 19.24%(v) I Sl03614 $16.93 $000 Balance transfer 18.241. (v) 1 $000 $000 $000 (v) = Vanable Rate Please see Inbrmation About Your Account section fort Calalation o1 Balance Suhjea to Interest Rate Annual Renewal Notice. Pow to Avoid Interest on Purdtasee, ant offer irrlpoman irrlormalion, as applicable X 0000001 FlSS3 81)9 coo Y 9 21 1G*Z Paa.2 d2 05166 MA 6N 1067 264100o009000105VM2 4 of 5 t VERIFICATION The undersigned is an O icer of Chase Bankcard Services, Inc., which is a subsidiary and agent of the Plaintiff that maintai is 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 fam liar with Plaintiffs account in this matter. Based upon my review of the Plaintiffs books an records of Defendant's account(s), I have personal knowledge of the facts set forth the regular course of the Plainti maintain these records, These re occurrence in question by, or frc the account. This verification is unsworn falsification to the attached pleading. Records such as these are kept in business and it is the regular course of Plaintiffs business to rds and the entries thereon are made at or near the information transmitted by, a person with knowledge of ide subject to the penalties of 18 Pa.C.S.A. §4904 relating to (Signature), WWR# 08799613 C A Pit SJS Client Account # 54660420 0552337 Name DANELLE L MCCANN SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson m r Shenff 4????tr Qi 4a,uZf;?4/1 1M ' Jody S Smith ,- Chief Deputy ' Richard W Stewart _. Solicitor OFF ..: .. _ _ . f.J'1 Chase Bank USA, N.A. Case Number vs. Danelle L. McCann 2011-2903 SHERIFF'S RETURN OF SERVICE 03/14/2011 04:55 PM - Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on March 14, 2011 at 1655 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Danelle L. McCann, by making known unto James Watson, Husband of defendant at 1296 Asper Drive, Boiling Springs, Cumberland County, Pennsylvania 17007 its contents and at the same time handing to him personally the said true and correct copy of the same. MICHAEL BARRICK, UTY SHERIFF COST: $34.00 March 15, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF Couw.ySuite She,itf. Teleo o t. In.;. ? O T HONOTAR i? WE TMAN, WEINBERG & REIS CO., L.P.A. 2311 P 25 PM 3: 22 BY: Sarah E. Ehasz Attorney for Plaintiff(s) `S I.D. o. 86469 CUMBERLAND COUNT 436 eventh Avenue, 1400 Koppers Bldg PENNSYLVANIA Pitts urgh, PA 15219 Pho e: 412.434.7955 Fax: 12.434.7959 File 8799613 CHI BANK USA, N.A. Plaintiff VS. CUMBERLAND County Court of Common Pleas No.: 11-2903 CIVIL LE L MCCANN Defendant(s) PRAECIPE TO DISMISS WITHOUT PREJUDICE TO REFILE TO THE PROTHONOTARY: dismiss the above matter without prejudice to refile. WELTMAN, WEINBERG & REIS CO- L.P.A. By Sarah E. Ehasz Attorney for Plaintiff