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Home My WebLink About04-4495IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PALISADES COLLECTION, LLC, ASSIGNEE OF PROVIDIAN BANK Plaintiff VS. EDWARD P MCGINNIS Defendant 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#03416564 1N THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PALISADES COLLECTION, LLC, ASSIGNEE OF PROVIDIAN BANK Plaintiff VS. EDWARD P MCGINNIS Defendant Civil Action No. 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 Plaintiffis a corporation with offices at P.O. Box 1244, Englewood Cliffs, NJ 07632. 2. Defendant is an adult individual residing at 570 Saint Johns Drive Camp Hill, PA 17011. 3. Defendant applied for and received a credit card issued by Plaintiff's assignor bearing the account number 4328071200465530. 4. Defendant made use of said credit card and has currently a balance due and owing to Plaintiff, as of August 25, 2004, in the amount ors 9,378.86. 5. Defendant is in default of the terms of the cardholder Agreement having not made monthly payments to Plaintiffthereby 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, EDWARD P MCG1NNIS individually, in the amount of $ 9,378.86 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. M'OLCZ~, 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#:03416564 yERIFICATION The tmdecsig~ed does hereby verify subject to the penalties of 18 PA.C.S. {}4904 relating to unswom falsificafionsto authoritie,, that he/sl~ei~ ~/--,o ~)~'~ /12 ~ k I,O.k'JI~ [Title) ~J (Company) he/she is duly authorized to make this Verification, and lhat the facts set forth in the foregoing Complaint in Civil Action are true and correct to the best of his/her knowledge, information and belie'f. TO TP, L P.02 S]KERIFF'S RETURN CASE NO: 2004-04495 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PALISADES COLLECTION LLC VS MCGINNIS EDWARD P - REGULAR CPL. MICHAEL BARRICK , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon MCGINNIS EDWARD P DEFENDANT at 1421:00 at 570 SAINT JOHNS DRIVE CAMP HILL, PA 17011 NATALIE MCGINNIS, WIFE a true the HOURS, on the 13th day of September, 2004 by handing to and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18 Service 9 Affidavit Surcharge 10 37 00 62 00 00 00 62 Sworn and Subscribed to before me this /~ ~ day of So Answers: R. Thomas Kline 09/14/2004 WELTMAN WEINBERG RE/~57 ~ '~-~"~ By: ~ L~~'~ Deputy Sheriff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PALISADES COLLECTION, LLC., ASSIGNEE OF PROVIDIAN BANK Plaintiff VS. EDWARD P. MCGUINNIS Defendant No. 04-4495 CIVIL PRAECIPE FOR DEFAULT JUDGMENT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan, Esquire PA I.D. 947437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WW R#03416564 Judgment Amount $ 9,378.86 THIS LAW FIRM IS ATTEMPTING TO COLLECT THIS DEBT FOR ITS CLIENT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PALISADES COLLECTION, LLC., ASSIGNEE OF PROVIDIAN BANK Plaintiff VS. EDWARD P. MCGUINNIS Defendant Civil Action No. 04-4495 CIVIL PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter Judgment against the Defendant, Edward P. McGuinnis, default of an Answer, in the amount of $9,378.86 computed as follows: Amount claimed in Complaint $9,378.86 Interest from date of judgment at the legal interest rate of 6.0% per annum above named, in the TOTAL $9,378.86 I hereby certify that appropriate Notices of Default, as attached have been mailed in accordance with PA R.C.P. 237.1 on the dates indicated on the Notices. WELTMAN, WEINBERG & REIS CO., L.P.A. William T. Molczan, Esjil~ire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WW R#03416564 Plaintiff's address is: c/o Weltman, Weinberg & Reis Co., L.P,A., 2718 Koppers Building, 436 7th Avenue, Pittsburgh, PA 15219 And that the last known address of the Defendant is: 570 Saint Johns Drive Camp Hill, PA 17011 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PALISADES COLLECTION, LLC, ASSIGNEE OF PROVlDIAN BANK Plaintiff VS, EDWARD P. MCGUINNIS Defendant TO: Edward P. McGuinnis 570 Saint Johns Drive Camp Hill, PA 17011 Date of Notice: /0/~//'~ ~/'/ YOU ARE IN DEFAULT BECAUSE Civil Action No. 04-4495 CIVIL ENTER A WRITTEN APPEARANCE IMPORTANT NOTICE YOU HAVE FAILED TO PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 WELTMAN, WEINBERG & REIS CO., L.P.A. William T. Molczan ~ PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434°7955 WWR #03416564 VERIFICATION The undersigned does hereby verify subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities, that the parties against whom Judgment is to be entered according to the Praecipe attached are not members of the Armed Forces of the United States or any other military or non-military service covered by the Soldiers and Sailors Civil Relief Act of 1940. The undersigned further states that the information is true and correct to the best of the undersigned's knowledge and belief and upon information received from others. WELTMAN, WEINBERG & REIS CO., LP.A. WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#03416564