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Home My WebLink About11-3326r FILED-OFFICE Gr THE PROTHONOTARY 2611 MAR 28 PP! 3: 06 CUMBERLAND COUNT` PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHASE BANK USA, N.A. Plaintiff vs. SCOTT FAIR Defendant No : //_ . E)3, (u P /'O 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 08800498 C A Pit KMJ ?`I ? ?? OCR ?` 5 GGG ?-/??J ,&C"# ? S 71 -7 ? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHASE BANK USA, N.A. Plaintiff vs. Civil Action No SCOTT FAIR 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: SCOTT FAIR 609 W SHADY LN # 393666 ENOLA, PA 17025 3. Defendant applied for and received a credit card issued by Plaintiff bearing the account number 4185863714499274 . 4. Defendant made use of said credit card and has a current balance due of $2621.49 . 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 , SCOTT FAIR , individually , the amount of $2621.49 with continuing interest thereon at the statutory rate of 6.000. per annum from January 05, 2011 , plus attorneys fees of $300.00 and costs. ames 436 S 08800498 C A Pit KMJ Pitts (412) FAX: This law firm is a debt collector attempt n our client and any information obtained wil WEINBERG & REIS CO., L.P.A. h Avenue, Suite 1400 t , PA 15219 -7955 -338-7130 to collect this debt for be used for that purpose. 8800498 Payment Due Date New Balance Past Due Amount Minimum Payment 10/15/70 Ez.sz1.49 Esss oo f634.00 AccourM number: 4185 0637 14118 9274 ,w Mania yev cheek payable tit: YW. Chase Card Services. Paasa ar es amount enclosed rear address a e-mail Print on bade. 41858637144992740006340000262149000000000000001 10D SCOTT FAIR TT FAIR SCO I.rIILLJ,d,I.,I..IL„I.I,,,,IIJ.I.rIb,LI.,.ILJI„I 6 00 W SHADY LN a 393666 ENOLA PA 17025-2064 CARDMEMBER SERVICE PO BOX 15153 WILMINGTON DE 19886-5153 1:50001,60281; 0 1,8 3 7 1,44 99 2 749sa CHASE O Marietta your account mom Addlsanl settled Wormartlen water chase namWdIdUKchk Canvangantty located on reverse ado ACCOUNT SUMMARY AmouNNtrnbr 41 68 6637 1449 9274 Previous Balance $2.56797 Fees Charged 425.00 Interest Charged .128.52 New Balance $2.621.49 OpergrlgrClostng Date 03/1,1`10 - 09/13/10 Total Credit Line $2.300 Available Credit $0 Cash Access Line $460 Available for Cash $0 PAYMENT INFORMATION New Balance $2,621.49 Payment Due Date 10116/10 M4nnnm Paymonl Due $634.00 Lna PaymulM Warming It we do not receive your minimum Payment by the dale hated above, you may have 10 pay a late lee of UP to $35.00 and you AP Ws wit be Subject to incresas to a maturnum Penalty APR of 29 90%. 18nlmum Pay. am Warning: if you rmke orgy the mirvrnum Payment each period. YOU wit pay more in interest and it will take you longer to pay oft your balance for eaampe: If you would like information about credit counseling services, call 1-866-797-2885 If you make no You will pay off the And you wit and up additional charges balance shown on paying an estimated using his card and this statement in 1018101 each month you about. Pay Orgy the minimum 20 years $5.195 Payment 588 3 years 1 $3.183 (Savuge-S2.012) The outstanding balance on your credit card amount is scheduled io be written o8 as a bed deb shorty AS a result. your crept bureau call be updated with a negative rating that could last for up 10 seven years. We can still help, but you need 10 call us now at 1-888-792-7547(colect 1-302-584.8200) Important Message You Are Ovenirntl Your balance under statement fiance exceeds your credit line. You should make a payment that includes the overlmii amount to bnng he you credit line. This account 99 dosed and no longer available lor use s you have a balance remaining on the amount, please continue to make monhly payments 4 the due dale. Thank you AC U IV Date 01 Transacton Merchant Name or Transaction Descnpton E Amount Mftowaw 09/15 LATE FEE 25 00 TOTAL FEES FOR THIS PERIOD ............................. $2500 III o 09177 PURCHASE INTEREST CHARGE 2852 TOTAL INTEREST FOR THIS PERIOD $2852 :....................: Total tees charged in 2010 $288.00 Total intereat Char ed 1n 2010 $20702 Year-to-dale 101815 reflect all c hargeS minus any reknds applied to your account on or after January 31. 2010. This Statement Is a Facsimile - Not an original 0000001 F13333196D 10 000 N Z is f owns P40.1 02 05696 MAMA 93013 2s01000010000a301301 R EXHIBIT I 2 of 5 Statement Date. 08/19/10 - 09/18/10 Account Number 4185 8637 1449 92 74 Page 2 of 2 iINTEREST CHARGES Your Annual Percentage Rata (APR) is the annual interest rate on your account. Annual Balance Percarttige Raft (APR) Balance Subject To Interest Accrued Type 31 Days In Cycle Interese Rate Charges Interleaf Charges Purchases 1299% $2.594 95 $28.52 $000 Cash Advances 28.99%(v) $0.00 $0.00 $0 00 Balance transfer 1299% $0 00 $0.00 . $0.00 (v) - Variable Rate Please a" htormation About Your Account section for the Calculation of Balance Bugect b Interest Rate. Annual Renewal Notice How to Avoid Interest on Purchases, and other important information, as applicable 8800498 X oooDm, M83=11010 This Statement Is a Facsimile - Not an original 000 N 2 1e toroane Piy2a2 050aa MU MN ISM 2eM000D100009301307 4of5 Batch Header Request Request Date and Time : 12-02-2010 11:11:56 Print Date and Time : 12-02-2010 11:18:20 Dept Code : OCC Requested By: FirstAssist Item Details : 4185873390934833 2010-10-17 Y 8800498 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. l? (Signature) WWR# 08800498 C A Pit KMJ Client Account # 4185863714499274 Name SCOTT FAIR