HomeMy WebLinkAbout04-3858IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
UNIFUND CCR PARTNERS, CIVIL DIVISION
ARBITRATION DIVISION
Plaintiff, No. bq- '?) ?
vs. COMPLAINT IN CIVIL ACTION
DEBRA L. HAKES,
Defendant.
Filed on behalf of Unifund CCR
Partners, Plaintiff
Counsel for Unfund CCR Partners:
Jonathan S. McAnney, Esquire
Pa. I.D. #50041
TUCKER ARENSBERG, P.C.
Firm #287
1500 One PPG Place
Pittsburgh, PA 15222
(412) 566-1212
LIT:330789-1 014636.110872
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
UNIFUND CCR PARTNERS,
Plaintiff, )
vs. ) No.
DEBRA L. HAKES, )
Defendant. )
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 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE
YOU WITH INFORMATION ABOUT HIRING A LAWYER.
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.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
(800) 990-9108
USTED DEBE LLEVAR ESTE PAPEL A SU ABOGADO ENSEGUIDA. SI USTED NO TIENE UN
ABOGADO, VAYA 0 LLAME POR TELEFONE? LA OFICINA FIJADA AQUI ABAJO. ESTA OFICINA
PUEDE PROVEERt CON INFORMAC16N DE COMO CONSEGUIR UN ABOGADO.
SI LISTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEER?
INFORMACION ACERA AGENCIAS. QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS
ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
(800) 990-9108
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
UNIFUND CCR PARTNERS,
vs.
Plaintiff,
DEBRA L. HAKES,
Defendant.
0 41_ 3?sr
No.
COMPLAINT IN CIVIL ACTION
AND NOW, comes the Plaintiff, UNIFUND CCR PARTNERS, by its
counsel, Tucker Arensberg, P.C. and files this Complaint stating as follows:
1. The Plaintiff is Unifund CCR Partners, a Delaware partnership, with
offices located at 10625 Techwoods Circle, Cincinnati, Ohio 45242.
2. The Defendant, Debra L. Hakes is an individual and a resident of
850 Melissa Ct., Enola, PA 17025.
3. On or about November 1, 1990, the Defendant applied for and was
approved to receive a Citibank Credit Card (hereinafter "Account"). Such Account was
issued at Account Number 5424180422604220.
4. The Defendant utilized such Account and incurred a balance due
and owing.
5. As of December 23, 2002, the Defendant owed $2,804.39 in
principal, and $824.78 in interest. The total amount owed is $3,629.17. See the Affidavit
of Indebtedness attached hereto as Exhibit "A" and incorporated by reference as if fully
set forth at length herein.
6. Despite written and oral demands for payment, the Defendant has
failed and refused to pay the amount due and owing.
7. Reasonable attorneys' fees in the amount of 20% of the principal
balance are due and owing.
8. The following amounts are currently due and owing from the
Defendant:
Principal and Interest $ 3,629.17
Reasonable Attorney's Fees (20%) $ 725.83
TOTAL: $ 4,355.00
9. The Account has been assigned by Citibank to the Plaintiff including
all rights to collect the amount due from the Defendant.
-2-
WHEREFORE, the Plaintiff, Unifund CCR Partners demands that judgment
be entered in its behalf and against the Defendant, Debra L. Hakes, in the sum of
$4,355.00 plus costs and interest.
TUCKER ARENSBERG, P.C.
By
Jonath S. cAnnEsquire
Pa. 1. . 50041
Counsel for Unifund CCR Partners:
TUCKER ARENSBERG, P.C.
1500 One PPG Place
Pittsburgh, PA 15222
Attorneys for Plaintiff
-3-
VERIFICATION
The undersigned verifies that the statements made in the foregoing
Complaint are true and correct to the best of her knowledge, information and belief and
understands the statements therein made are made subject to the penalties of 18
Pa.C.S. §4904 relating to unsworn falsification to authorities.
Christina M. ryan
Unifund CCR Partners
AFFIDAVIT OF INDEBTEDNESS
State of Ohio )
County Of Hamilton ) ss.
Jessica Gentry, being sworn, deposes and says that she is Media Supervisor of Unifund CCR Partners herein called
assignor, which is doing business at 10625 Techwoods Circle, Cincinnati, Ohio 45242 and that she is authorized to
make the statements and representations herein.
The defendant is not in any branch of the military.
There is due and payable from DEBRA L HAKES, Account Number 5424180422604220,the amount of $3629.17
(principal balance in the amount of $2804.39 plus interest up through 12/23/2002 in the amount of $824.78). By
the terms of the agreement between the defendant and the original creditor, interest is accruing from the
aforesaid date at the rate of 19.74 percent per annum.
This account was originated with Citibank. Unifund CCR Partners purchased this account from Citibank. Said
account has been assigned, transferred and set over unto, Tucker Arensberg with full power and authority to do
and perform all acts necessary for the collection, settlement, adjustment, compromise or satisfaction of said
claim.
DATED 23 December 2002
UNIFUND CCR PARTNERS
By: Jessica Gentry Media Supervisor
Title
10625 Techwoods Circle Cincinnati, OH 45242
Address
Subscribed and sworn to before me this 23 day of December 12002
Notary Public
Client # 215
My commision expires
AMY E. TREADON
Notary PUW Stet® of Ohio
MY CorotnWW Expires JYna 5, 2007
c
-
SHERIFF'S RETURN - OUT OF COUNTY
CASE NO: 2004-03858 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
UNIFUND CCR PARTNERS
VS
HAKES DEBRA L
R. Thomas Kline
, Sheriff or Deputy Sheriff who being
duly sworn according to law, says, that he made a diligent search and
and inquiry for the within named DEFENDANT to wit:
HAKES DEBRA L
but was unable to locate Her in his bailiwick. He therefore
deputized the sheriff of LANCASTER County, Pennsylvania, to
serve the within COMPLAINT & NOTICE
On September 13th , 2004 , this office was in receipt of the
attached return from LANCASTER ?Y7
Sheriff's Costs: So
Docketing 18.00
Out of County 9.00
Surcharge 10.00 ? R?
Dep Lancaster Co 54.50 ?'
Sh
Mileage 11.84
103.34 J
09/13/2004 I
1/
TUCKER ARENSBERG
Sworn and subscribed to before me
this d/a r day of 1,
?(}{j A.D.
?? .
Protonotary '
d' Kline `
of Cumberland County
SHERIFF'S OFFICE
50 NORTH DUKE STREET, P.O. BOX 83480, LANCASTER, PENNSYLVANIA 17608-3480 a (717) 299-8200
SHERIFF SERVICE I PLEASE TYPE
PROCESS RECEIPT, and AFFIDAVIT OF RETURN DO NOT DETACH ANY COP.JES '9
1. PLAINTIFF/S/ 2 COURT NUMBER
Unifund CCR Partners 04-3858 civil r4 +C,
3. DEFENDANT/S/ 4. TYPE OF WRIT OR COMPLAINT:
Debra L. Hakes Notice & Complaint
SERVE 5 NAME OF INDIVIDUAL, COMPANY. CORPORATION. ETC., TO BE SERVED
0 Debra L. Hakes
CUMBERLAND CO.
6. ADDRESS (Street or RFD, Apartment No., City, 8oro, Twp., Slate and 21P Code)
AT 625 Chatham Way Lititz, PA 17543
7. INDICATE UNUSUAL SERVICE: '& DEPUTIZE O OTHER Cumberland
Now, 8/24 20 04 I, SHERIFF OF COUNTY, PA., do here tize the Sh r
Lancaster County to execute this Writ SHERIFF OF ur r of PW P
to law. This deputation being made at the request and risk of the plaintiff.
' :OUNT1`
S. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE: Cumberland
NOTE ONLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN - Any deputy sheriff levying upon or attaching any property under
within writ may leave same without a watchman, in custody of whomever is found in possession, after notifying person of levy or attachment, without liability on
the part of such deputy or the sheriff to any plaintiff herein for any loss, destruction or removal of any such property before sheriff's sale thereof.
SIGNATURE
of ATTORNEY or other ORIGINATOR
9.. 10. TELEPHONE NUMBER 11. DATE
)t
g
12
SEND NOTIGrE Of SERVICEXCrOPV Yb'NAME AND ADDRESS B
W
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is area must Is c
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to be mailed)
a
TUCKER ARENSBERG, P.C. n
FIRM #287 d
1500 ONE PPG PLACE, PITTSBURGH PA, 15222 y
SPACE BELOW FOR USE OF SHERIFF ONLY - DO NOT WRITE BELOW THIS LINE
13. 1 acknowledge receipt of the writ t A rl+gNNdE Ot9uthoyyplLCSD?eouU??i CIerILM
WAL'1'UN /1/ L`! :Sb(!`
i J 14. Data Received
I 15. Expiration/Hearing data
.
or complaint as indicated above.( 8J29/04 9/704 Cxy
U1
16. 1 hereby CERTIFY and RETURN that have personally served. (D have legal evidence of service as shown in "Remarks". ? have executed as shown in
A
"Remarks", the writ or complaint des
ad on the individual, company, corporation, etc., at the address shown above or on the individual, company, cor-
poration, etc., at the address Inserted below by handing a TRUE and ATTESTED COPY thereof,
17. ? 1 hereby certify and return a NOT FOUND because I am unable to locate the individual, company, corporation, etc., named above. (See remarks below)
18. Name and title of individual served (if not shown above) (Relationship to Defendant) 1 19. cHosarvios
See Remarks Belay (No. 30)
20. Address of where served coin pfete only if different than shown a bove) IS treet or RFD, Apart ment No., CIly, Soro, Twp. 21. Date of Service 22. Time
State and Zip Code)
cy//O?fOq (??t 'aur-
S,So
EDST
23. ATTEMPTS
1 Date
f3 Mile. Dep. Int.
/(o 4N I Djte
4l I Miles
/fo ( Dep. Int. Date
/4 I Miles
1 Dep. Int.
C,3F Dote I Miles f
I I Dep. Int. Date Miles Dep. Int.
24. Advance Costs 25. Service Costs 26. Notary Cert. I
27. Mileage/Postage/N.F. 28, T tat Costs
1 COST DUE OR REFUND
29
i ,57 150.00 '48 5(1
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S.T.A.:
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31. AFFIRMED and subscribed to before me this 91) h) ?Hn ?Sf dp H(j--/'C,O ANSWER. ?n utkr
32. Si nature of
?7r 20 Dso. Sgheritl
ND U181On 7 1QL7
34. day of R
rj 35. Signature of Sheriff (! 36. 'Mp
37 aeOrL 'T T?_?
Pwthonalary/n..q PrLR PC. o.Tpn Co rMV COMMISSION EXPIRES
1W -4
?•VVVi,`O``?`'`1\
1. WHITE - Issuing Authority 2. PINK - Attorney 3. CANARY - Sheriff's Office 4. BLUE - Sheriff's Office
UNIFUND CCR PARTNERS, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW
DEBRA L. HAKES, NO.04-3858 CIVIL
Defendant :
NOTICE TO PLEAD
TO: Unifund CCR Partners
c% Jonathan S. McAnney, Esquire
Tucker Arensberg, P.C.
Attorneys for Plaintiff
1500 One PPG Place
Pittsburgh, PA 15222
You are hereby notified to plead to the New Matter raised herein within twenty (20)
days of service of the attached pleading upon you, or judgment may be entered against
you.
6MVJL" /? ? 20
Mate
Attorney fo fendant
407 North on St., First Floor
Harrisburg, P -K'17101
(717) 238-3686
Supreme Court I.D. # 53729
UNIFUND CCR PARTNERS, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW
DEBRA L. HAKES, NO.04-3858 CIVIL
Defendant :
DEFENDANT'S ANSWER AND NEW MATTER
1. Admitted in part and denied in part. It is admitted that Unifund CCR Partners
identifies itself as the Plaintiff; as to its form of entity and address, Defendant, after
reasonable investigation, lacks information to determine the truthfulness of same. If
material, strict proof thereof is demanded.
2. Admitted in part and denied in part. Plaintiff has correctly identified the Defendant
it seeks to be held liable, but the residence address is incorrect. Defendant resides at 625
Chatham Way, Lititz, Lancaster County, Pennsylvania 171543.
3. Admitted in part and denied in part. It is admitted that Defendant at one time held
the credit card described herein. As to her precise application date, Defendant does not
recall.
4. Denied as stated. While it is admitted that Defendant used the account from time
to time, it is specifically denied that there is a balance due and owing. Alternatively, even
if a balance is due and owing, Plaintiffs claim may be barred by the Statute of Limitation,
as will be set forth in New Matter.
5. Denied in all respects. There is no balance due, as will be revealed in New Matter.
Even if there is a purported balance due, it is possible, in !fact probable, that the claim is
barred by the applicable Statute of Limitation.
6. Denied as stated. While demands may or may not have been made, Defendant has
no liability. Accordingly, any statement or implication to the! effect that she has any amount
due or owing is expressly denied.
7. Denied. This averment is a conclusion of law to which no response is required.
8. Denied. Defendant does not owe Plaintiff any money for any reason.
9. Denied. After reasonable investigation, Defendant lacks information necessary to
determine the truthfulness of this averment. If material, strict proof thereof is demanded.
WHEREFORE, Defendant requests this Honorable Court to enter judgment in her
favor and against the Plaintiff, to tax the costs of this action against the Plaintiff including
a reasonable attorney's fee, and to provide any other relielf the Court deems appropriate.
NEW MATTER
10. The responses set forth in paragraphs one through nine are incorporated herein by
reference.
11. Plaintiffs claim is barred by the applicable Statute of Limitation.
12. Any debt purportedly due to Citibank, the original creditor on this claim was paid to,
and accepted in full satisfaction by, Citibank, MC, in 2001, as will be stated in more detail
below.
13. On or about September 24, 2001, Defendant obtained a home equity loan, part of
the purpose of which was to pay off Citibank, the original creditor on the claim that is the
subject of this action.
14. Citibank was in fact paid as part of that transaction; a copy of the settlement sheet,
2
reflecting payment to Citibank, is attached hereto, marked Exhibit "A" and incorporated
herein by reference.
15. Even if the amount paid to Citibank (which appears to be $2,804.00) was not the
full balance then due as of September 24, 2001 (a proposition which Defendant denies),
Citibank, the original creditor, has waived or is estopped from asserting any further claim
in that Citibank accepted that payment as full satisfaction.
16. Plaintiff in the captioned action, as Citibank's purported assignee, has no greater
rights than Citibank ever had and is therefore subject to the defenses raised herein, and
additional defenses as may become apparent through further investigation.
WHEREFORE, Defendant requests this Honorable! Court to enter judgment in her
favor and against the Plaintiff, to tax the costs of this action against the Plaintiff including
a reasonable attorney's fee, and to provide any other relief the Court deems appropriate.
ot*v 4
ate
Anthony T. Beth, Esq.
Attorney fo PI 'ntiff
407 North ont t., First Floor
Harrisburg, 101
(717)238.3686
Supreme Court I.D. # 53729
iii rzun9 115:12 FAX 7173021852
Settlement Statement
Name & Address of Borrower
DEBRA L RAKES
850 MELISSA CT
ENOLA PA 17025
Property Locetlon, III different From above)
850 MELISSA CT
ENOLA PA 17025
804. Credit report to
TRANS UNIO
805. InsoacNo f t
608. Mortgage Broker
809. Points Paid to M
rrocaed. to
to
to
to
to
1101, Settlement or closing fee to
1102. Abstract or title search to
1
to
28.zO5 Wool
to
ees [oto
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S
. HICHMARK EDI SERVICES
U.S. Department of Housing
and Urban Davebpment
aur'1NANCIAL, INC.
Q003
OMB AwrOvrl No. 25
01 HARTZDALE DRIVE SUITE 126
MP RILL PA 17011
gent:
1CIAL INC_
amenY
)1 RARTZDALE DRIVE SUITS 126
7P HTT.T. nn -, I
29.70 7601
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1603.
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7 526
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.TOTAL DISBURSED(anter on line 1603)
N. Net SatBemenl
3 , 573. C
1800. Lioen Amount
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1601. Plos Cash/Check from Bo
rrower q
1602. Minue Total Settlement Charges
One 1400) $ 351.6E
1603. Minus Total Disbursements to Oth
ers
_ (line 1626) $
3, S73. Ot
78D4. Equals Dlsburaements to Borrower
(after expiration of any applicable
re scieslon period required by law) S 3, 927.2°
rev_
0r193na1(Branch) Copy(Cust:omar)
EXHIBIT "A"
VERIFICATION
I, Anthony T. McBeth, am attorney for the Defendant in the captioned action. I am
verifying the attached document for the Defendant in that she is outside the jurisdiction of
this Court and her verification cannot be obtained by the time this complaint needs to be
filed. I verify that the facts set forth in the attached document are true and correct to the
best of my knowledge, information and belief. I so state subject to the penalties of 18
Pa.C.S. § 4904 (relating to unswom falsification to authorities).
Da Fe
UNIFUND CCR PARTNERS,
Plaintiff
V.
DEBRA L. HAKES,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO.04-3858 CIVIL
CERTIFICATE OF SERVICE:
1, Anthony T. McBeth, Attorney for Defendant, hereby certify that I have served the
attached document by placing same in the United States mail, first class, postage pre-paid
addressed as follows:
Jonathan S. McAnney, Esquire
Tucker Arensberg, P.C.
Attorneys for Plaintiff
1500 One PPG Place
Pittsburgh, PA 15222
Nate
Esq.
Attorney for efend t
407 North Fr t.. irst Floor
Harrisburg, PA 17101
(717) 238-3686
Supreme Court I.D. # 53729
-r7
I Tl
Gil
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
UNIFUND CCR PARTNERS, CIVIL DIVISION
ARBITRATION DIVISION
Plaintiff,
No. 04-3858 Civil
vs. REPLY TO NEW MATTER
DEBRA L. HAKES,
Defendant.
Filed on behalf of Unifund CCR
Partners, Plaintiff
Counsel for Unifund CCR Partners:
Jonathan S. McAnney, Esquire
Pa. I.D. #50041
TUCKER ARENSBERG, P.C.
Firm #287
1500 One PPG Place
Pittsburgh, PA 15222
(412) 566-1212
L IT:339203-1 014636-110872
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
UNIFUND CCR PARTNERS,
Plaintiff,
vs.
DEBRA L. HAKES,
Defendant.
CIVIL DIVISION
ARBITRATION DIVISION
No. 04-3858 Civil
REPLY TO NEW MATTER
AND NOW COMES the Plaintiff, Unifund CCR Partners, by and through
its attorneys, Tucker Arensberg, P.C., and files the following Reply to New Matter:
11. The allegation contained in Paragraph 11 constitute a legal
conclusion to which no response is required. To the extent that a response is required,
said allegation is denied and proof thereof is demanded.
12. The allegations contained in Paragraph 12 are denied. To the
contrary, the Defendant has not made all payments required on this account.
13. After reasonable investigation, the Plaintiff is without knowledge or
information sufficient to form a belief as to the truth of the allegations contained in
Paragraph 13. Therefore, said allegations are denied and proof thereof is demanded.
14-16. The allegations contained in Paragraphs 14 through 16 constitute
legal conclusions to which no responses are required. To the extent that any responses
are required, said allegations are denied and proof thereof is demanded.
WHEREFORE, the Plaintiff, Unifund CCR Partners demands that
judgment be entered in its behalf and against the Defendant, Debra L. Hakes, in the
sum of $4,355.00 plus costs and interest.
TUCKER ARENSBERG, P.C.
n&.?,
Jonath r S. McAnneyEsquire
Pa. I. 150041
Counsel for Plaintiff
TUCKER ARENSBERG, P.C.
1500 One PPG Place
Pittsburgh, PA 15222
2
VERIFICATION
The undersigned verifies that the statements made in the foregoing Reply
to New Matter are true and correct to the best of her knowledge, information and belief
and understands the statements therein made are made subject to the penalties of
18 Pa.C.S. §4904 relating to unsworn falsification to authorities.
Dated: 10//? ?044
Chris M. Biyan
Un fund CC:R Partners
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the within Reply to New
Matter was served on the following by first class mail, postage pre-paid on this & day
of October, 2004:
Anthony T. McBeth, Esquire
407 North Front Street
First Floor
Harrisburg, PA 17101
Jonath McAnney, Esquire
? ?
r
e ,.
G
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
UNIFUND CCR PARTNERS,
Plaintiff,
vs.
DEBRA L. HAKES,
Defendant.
No. 043858 Civil
PETITIpN FOR APPOI_fNITiNT 9F ARalTRATQRS
TO THE HONORABLE, THE JUDGES OF SAID COURT:
Jonathan S. McAnney, counsel for the plaintiff in the above action, respectfully represents that:
1. The above-captioned action is at issue.
2. The claim of plaintiff in the action is $4,355.00.
The counterclaim of the defendant in the action is costs and attorneys' fees.
The following attorneys are interested in the case) as counsel or are otherwise disqualified to sit as
arbitrators: Anthony T. McBeth
WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the
case shall be submitted.
Respectfully
AND NOW,
Esq., and
captioned action (or actions) as prayed for.
#50 1
Counsel for taint
TUCKER A EN ERG, P.C.
1500 One PP lace
Pittsburgh, PA 15222
ORDER OF COURT
Esq., and
2005, in consideration of the foregoing petition,
Esq., are appointed arbitrators in the above
By the Court,
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
UNIFUND CCR PARTNERS,
Plaintiff,
vs.
DEBRA L. HAKES,
Defendant.
No. 043858 Civil
PETITION FOR APPOINTMENT OF ARBITRATOR$
TO THE HONORABLE, THE JUDGES OF SAID COURT:
Jonathan S. McAnney, counsel for the plaintiff in the above action, respectfully represents that:
1. The above-captioned action is at issue.
2. The claim of plaintiff in the action is $4,355.00.
The counterclaim of the defendant in the action is costs and attorneys' fees.
The following attorneys are interested in the case) as counsel or are otherwise disqualified to sit as
arbitrators: Anthony T. McBeth
WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the
case shall be submitted.
Respectfully
Jonathan S. eyEsquire
Pa. Lf?. #50 .1
Counsel for faint
TUCKER A EN ERG, P.C.
1500 One PP lace
Pittsburgh, PA 15222
ORDER OF COURT
AND NOW, , 2005, in consideration pf the foregoing petition,
? Esq., and j
A, en 101?1 A
Esq., and C aiJllk/ Esq., , a ar ' ators in the above
captioned action (or actions) as prayed for.
By the Court,
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
UNIFUND CCR PARTNERS, CIVIL DIVISION
ARBITRATION DIVISION
Plaintiff,
No. 04-3858 Civil
vs. NOTICE OF APPEAL FROM
BOARD OF ARBITRATORS
DEBRA L. HAKES,
Defendant.
Filed on behalf of Unifund CCR
Partners, Plaintiff
Counsel for Unifund CCR Partners:
Jonathan S. McAnney, Esquire
Pa. I.D. #50041
TUCKER ARENSBERG, P.C.
Firm #287
1500 One PPG Place
Pittsburgh, PA 15222
(412) 566-1212
LIT:357740-1 014636-110872
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
UNIFUND CCR PARTNERS,
Plaintiff,
vs.
DEBRA L. HAKES,
Defendant.
CIVIL DIVISION
ARBITRATION DIVISION
No. 04-3858 Civil
NOTICE OF APPEAL FROM AWARD OF BOARD OF ARBITRATORS
TO: PROTHONOTARY
NOTICE is given that the Plaintiff, Unifund CCR Partners, appeals
from the Award of the Board of Arbitrators entered in this case on April 5, 2005.
I hereby certify that the compensation of the Arbitrators has been paid.
RG, P.C.
Jonath McAnn squire
1500 e PG Place
Pittsbu gh, PA 15222
(412) 5 -1212
Counsel for Plaintiff
Unifund CCR Partners
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the within NOTICE OF
APPEAL FROM AWARD OF BOARD OF ARBITRATORS has been served upon
all counsel by first class mail, postage prepaid, this 18th day of April, 2005:
Anthony T. McBeth, Esquire
407 North Front Street
First Floor
Harrisburg, PA 17101
Jonathan , McAnney, Esquire
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PRAECIPE FOR LISTING CASE FOR TRIAL
(Must be typewritten and submitted in duplicate)
TO THE PROTHONOTARY OF CUMBERLAND COUNTY
Please list the following case:
? for JURY trial at the next term of civil court.
? for trial without a jury.
---------------------------------------------
CAPTION OF CASE
(entire caption must be stated in full)
U11TFUM GCR PARTNERS
vs.
DEBRA L. HAKES
vs.
(Plaintiff)
(Defendant)
(check one)
? Civil Action - Law
Appeal from arbitration
(other)
The trial list will be called on March 4, 2008
and n a
Trials commence on March. 31, 2008
Pretrials will be held on March 12, 2008
(Briefs are due S days before pretrals
No. 04-3858 , Term
Indicate the attorney who will try case for the party who files this praecipe:
JONATHAN S. mCAN"'EY
Indicate trial counsel for other parties if known:
- ANTHONY T_ MCBETu
This case is ready for trial. Signed:
Print Name:
Date: January 14, 2008 Attorney foi
Jon4than S. McAnney, Esq.
FUnJund CCR Partners
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
UNIFUND CCR PARTNERS, CIVIL DIVISION
ARBITRATION DIVISION
Plaintiff, No. 04-3858 Civil
PRAECIPE FOR TRIAL
vs.
DEBRA L. HAKES,
Defendant.
Filed on behalf of Unifund CCR
Partners, Plaintiff
Counsel for Unifund CCR Partners:
Jonathan S. McAnney, Esquire
Pa. I.D. #50041
TUCKER ARENSBERG, P.C.
Firm #287
1500 One PPG Place
Pittsburgh, PA 15222
(412) 566-1212
LIT:431499-1 014636-110827
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
UNIFUND CCR PARTNERS,
Plaintiff,
No. 04-3858 Civil
vs.
DEBRA L. HAKES,
Defendant.
PRAECIPE FOR TRIAL
To Prothonotary:
Kindly place the above-captioned case on the next available trial list.
TUCKER ARENSBERG, P.C.
NSBERG, P.C.
Firm #287
1500 One PPG Place
Pittsburgh, PA 15222
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CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing Praecipe for Trial
was sent this 14th day of January, 2008, via first class U.S. Mail, postage prepaid, to the
following:
Anthony T. McBeth, Esquire
407 North Front Street
Cameron Mansion
Harrisburg, PA 17101
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UNIFUND CCR PARTNERS IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
CIVIL ACTION - LAW
DEBRA L. HAKES,
Defendant 04-3858 CIVIL TERM
ORDER OF COURT
AND NOW, this 4th day of March, 2008, upon
consideration of the call of the Civil Trial List and no person
having called the above-captioned case for trial, it is stricken
from the trial list.
By the Court,
- Jonathan S. McAnney, Esquire
Anthony T. McBeth, Esquire
Court Admin.
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3/10/08
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