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HomeMy WebLinkAbout04-4442IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PALISADES COLLECTION, LLC, ASSIGNEE OF PROVIDIAN BANK Plaintiff VS. BETTY NEGLEY Defendant No. ©14 - 4WA, COMPLAINT IN CIVIL ACTION FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: WILLIAM T. MOLCZAN, ESQUIRE PA I.D.#47437 Weltman, Weinberg & Reis Co., L.P.A. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#03426657 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PALISADES COLLECTION, LLC, ASSIGNEE OF PROVIDIAN BANK Plaintiff vs. Civil Action No. ?U - U4y? (.., l L t - BETTY NEGLEY Defendant COMPLAINT IN CIVIL ACTION 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 ON AGENICES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3161 COMPLAINT Plaintiff is a corporation with offices at P.O. Box 1244, Englewood Cliffs, NJ 07632. 2. Defendant is an adult individual residing at 189 Conodoguinet Moble Estates, Newville, PA 17241. 3. Defendant applied for and received a credit card issued by Plaintiffs assignor bearing the account number : 5409792700515370. 4. Defendant made use of said credit card and has currently a balance due and owing to Plaintiff, as of August 18, 2004, in the amount of $ 1,610.23. 5. Defendant is in default of the terms of the cardholder Agreement having not made monthly payments to Plaintiff thereby rendering the entire balance immediately due and payable. 6. Plaintiff avers that the Cardholder Agreement between the parties provides that Plaintiff is entitled to the addition of finance charges at the rate of 6% per annum on the unpaid balance. 7. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed and/or refused to pay the principal balance, finance charges or any part thereof to Plaintiff. WHEREFORE, Plaintiff demands Judgment in its favor and against Defendant, BETTY NEGLEY individually, in the amount of $ 1,610.23 with continuing finance charges thereon at the rate of 6% per annum from date of judgment plus costs. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED SHALL BE USED FOR THAT PURPOSE. WELTMAN, WEINBERG & REIS, CO., L.P.A. WILLIAM T. MOLCZAN, ESQ E PA I.D.#47437 Weltman, Weinberg & Reis Co., L.P.A. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 W WR#:03426657 PAISADESWON,LLG BETTY NEGLEY 189 CONODOGUINET MOBILE NEWVILLE, PA 17241 IF ADDRESS AS SHOWN ABOVE IS INCORRECT. PLEASE INDICATE CHANGE BELOW. NAME _ ADDRESS ACCOUNT NUMBER 5409792700515370 DATE REFERENCE NUMBER 7/27/2004 SUMMARY OF TRANSACTIONS PALISADES FILE NUMBER 8944192 PA NEW BALANCE $1610.23 PAYMENT DUE DATE 7/27/2004 J C PLEASE WRITE IN AMOUNT OF PAYMENT ENCLOSED $ PLEASE DETACH AND TOP PORTION WITH YOUR PAYMENT CREDIT LIMIT I CREDITAVAIABLE 0 ? 0 NEW TRANSACTIONS BALANCE DUE 7/27/2004 PALISADES COLLECTION, L.L.C. DELAWARE LIMITED LIABILITY CORP. ASSIGNEE OF PROVIDIAN BANK P.O. BOX 1244 ENGLEWOOD CLIFFS, NJ 07632 PREVIOUS BALANCE $1610.23 PROMPT CREDITING OF PAYMENTS: TO RECEIVE CREDIT FOR PAYMENT AS OF THE DATE OF RECEIPT. WE MUST RECEIVE THE TOP PORTION OF THE STATEMENT AND YOUR CHECK OF MONEY ORDER BY 3:00 P. M. AT: PALISADES COLLECTION. LL.C. P.O. BOX 12" ENGLEWOOD CUFFS NJ 07672 PAYMENTS RECEIVED AT THE ABOVE ADDRESS IN THE MANNER SPECIFIED AFTER THAT TIME WILL BE CREDITED TO YOUR ACCOUNT AS OF OUR NEXT BUSINESS DAY THE CREDITING TO YOUR ACCOUNT OF PAYMENTS RECEIVED AT ANY LOCATION OTHER THEN THE ABOVE ADDRESS MAY BE DELAYED UP TO S DAYS FROM DATE OF RECEIPT. W WR - File # 3426657 PAST DUE $1610.23 MINIMUM PAYMENT $1610.23 STATEMENT CLOSING DATE 7/27/2004 AMOUNT $1610.23 PAYMENTS AND CREDITS NEW BALANCE $1610.23 PAYMENT DUE DATE MINIMUM PAYMENT 712 7120 0 4 $1610.23 SEND INQUIRIES TO: PALISADES COLLECTION, L.L.C. P.O. BOX 12" ENGLEWOOD CLIFFS, NJ 07632 VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA. C.S. 4904 relating to unworn falsifications to authorities, that he/she is s O?? -? ?? C? ^_ v C (NAME) 41 ?I of PO h SL S ?d) 0) plaintiff herein, that v (TITLE) (COMPANY) he/she is duly authorized to make this verification, and that the facts set forth in the foregoing Complaint are true and correct to the best of his/her knowledge, information and belief. (SIGNATURE) i N °p u1 r -ri nl 1 GV3 Curtis R. Long Prothonotary Office of the Protbonotarp Cumberiarlb Countp Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor 044- CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 5TH DAY OF NOVEMBER 2007 AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R C P 230.2. BY THE COURT, CURTIS R. LONG PROTHONOTARY One Courthouse Square • Carlisle, Pennsylvania 17013 • (717) 240-6195 • Fax (717) 240-6573