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Home My WebLink About04-4499 o IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PALISADES COLLECTION, LLC, ASSIGNEE OF PROVIDIAN BANK Plaintiff No. ()If- Lf 'f q 1 ~ vs. COMPLAINT IN CIVIL ACTION JODI I. MELOY, Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: WILLIAM T. MOLCZAN, ESQUIRE PAI.D.#47437 Weltman, Weinberg & Reis Co., L.P.A. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, P A 15219 (412) 434-7955 WWR#034I4908 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PALISADES COLLECTION, LLC, ASSIGNEE OF PROVIDIAN BANK Plainti ff vs. Civil Action No. 0 '/~ 4'-/ 9Cf JODI I. MELOY, 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 notiee 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. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 COMPLAINT 1. Plaintiff is a corporation with offices at P.O. Box 1244, Englewood Cliffs, NJ 07632. 2. Defendant is an adult individual residing at 341 S SPORTING HILL RD MECHANICSBURG,P A 17050. 3. Defendant applied for and received a credit card issued by Plaintiffs assignor bearing the account number 4031150500498827. 4. Defendant made use of said credit card and has currently a balance due and owing to Plaintiff, as of August 31, 2004, in the amount of$3,143.00. 5. Defendant is in default of the ternlS 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, JODI I. MELOY, individually, in the amount of $3,143.00 with continuing finance charges thereon at the rate of 6% per annum from date of judgment plus costs. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED SHALL BE USED FOR THAT PURPOSE. WELTMAN, WEINBERG & REIS. CO.. L.P.A. ~,// 0 /fA WILL~:-~6LCZA , ESQUIRE PA LD.#47437 Weltman, Weinberg & Reis Co., L.P.A. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#:03414908 VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA. C.S. 4904 relating to unsworn falsifications to authorities, fuat he/she is Ste-.rhen Sc.hl,d"t- (NAME) LeC\CtI (h>m,hOVlS M~r1aO\e.1 of pcditjadeJ? CoIlec.:fIDt1, Li..C,plaintiffherein, that J "I - (TITLE) 0 (COMPANY) he/she is duly aufuorized to make this verification, and fuat the facts set forth in the foregoing Complaint are true and eorrect to the best of his /her knowledge, information and belief. (SIGNATURE) Stephen Schlicht Legal Operations Manager ~~ - 23J <:;><l - I ~ r ~. --- '0. --- i:" -..... ~\J ;$' 0' I U' C)J!oCJ ~.l ,.J V' c! 0-. c. c) c.~) , " t~o '.0 t~;i I ..../ 0)\ ~ ~::: r'".:) /"1 :2 /i',:,-' r<.: ,~,"ff? , j ;~::) ).:) - "j '-"j SHERIFF'S RETURN - REGULAR CASE NO: 2004-0H99 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PALISADES COLLECTION LLC VC' c, MELOY JODI I KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon MELOY JODI I the DEFENDANT , at 1727:00 HOURS, on the 16th day of September, 2004 at 341 S SPORTING HILL ROAD MECHANICSBURG, PA 17050 by handing to JODI MELOY a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 9.62 .00 10.00 .00 37.62 ?P>:;j&~~~ R. Thomas Kline 09/17/2004 WELTMAN WEINBERG REIS Sworn and Subscribed to before By: u.. / DrU me this .l:J~ day of ~ ;}..07.)<{ A.D. n ,_ n ~-<jf", ~ ~rott~nota:t:y , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PALISADES COLLECTION, LLC ASSIGNEE OF PROVIDIAN BANK Plaintiff NO.04-4499-Civil vs. PRAECIPE FOR DEFAULT JUDGMENT JODI!. MELOY Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan, Esquire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.PA 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WW R#03414908 Judgment Amount $ 3,227.00 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. Civil Action No. 04-4499-Civil JODI!. MELOY Defendant PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter Judgment against the Defendant, Jodi I. Meloy, above named, in the default of an Answer, in the amount of $3,227.00 computed as follows: Amount claimed in Complaint $3,227.00 Interest from date of judgment at the legal interest rate of 6.0% per annum TOTAL $3,227.00 I hereby certify that appropriate Notices of Default, as attached have been mailed in accordance with PA R.C.P. 237.1 on the dates indicated on the Notices. WELTMAN, WEINBERG & REIS CO., L.P.A. By LvI,-I/ r:) William ~~~l E uire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.PA 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#03414908 Plaintiff's address is: clo Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 ih Avenue, Pittsburgh, P A 15219 And that the last known address of the Defendant is: 341 S. Sportinghill Road, Mechanicsburg, PA 17050 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PALISADES COLLECTION LLC ASSIGNEE OF PROVIDIAN BANK Plaintiff vs. Civil Action No. 04-4499 CIVIL JODI I. MELOY Defendant IMPORTANT NOTICE TO: Jodi I. Meloy 341 S Sporting Hill Road Mechanicsburg, PA 17050 Date of Notice: /t' - //'-' ~Lj YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR SY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR '~,-,~--;"f~~'~~OB-J€~NSc~iQ~II:lE;~iM$'~~~I~AGNt!i~~YQ~~~~d'qlJ-,~SI~.lJ~'"i"'!:~2~~t~9M", c~~'" ~i"~,'-- .~?Tkff"'~~~ Qf-,,~~~~q!~~~" E~+=Mbf ~E::_~~!~f&f'~A~~~I .Y.,9~' WlTJ;!9YLA_~Lti~_~~--:- _~~f.",!;.~, 'L , .,," - lJ'\;.,t;. ,-,.,," -: '.~""'l.~ - - . -~.~P~.~~~, ....l" '~~~~..,:"'~: ,.~... ~--l':""':.r'-;:-' _.~...."", ~-~\-,,-,~ -"'-ir~-;"':"~.-f"'~",~'It:~-'.[,"" "w...-"" ......~.,...7r.J;::LH,~'1 r~'I -- 'If ~--::t -l_~ <..~_.l '.)t,.:ff ~-=-~:-::'?":-"7-~Yo(FMA?~l5sEcVOtJFfpffOPE~R HER IMPORTAN t-~t~l.h'ii~~tf~S -' Irf -: f~~~===' 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 ~yELT~Jl1- 4E'S CO. LPA William T. Molczan PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.PA 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR #03414908 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., LPA ~:i((I!!5: PA 1.0. #47437 WELTMAN, WEINBERG & REIS CO., L.PA 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WW R#03414908 t ~ 0 """s i :..0 - 0 ~ ......... ~~ " ) .J S F ~ QJ CA.J ~ .-0 ~~ ~ --L. I~~~~ t (~-: ;.' .1..... " 17 C) r"~ ",.1' 1'''';> ~; ~'- ;;1,':# c5 o --n ~J jCi i :'J " ::om (;:;9 :)~: :j ~:~ =i;,' :-:::J -< '-' ." - I co :0. ",",.:... ~.? Cl \".0 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PALISADES COLLECTION,LLC,ASSIGNEE OF PROVIDIAN BANK Plaintiff No. 04-4499 CIVIL vs. PRAECIPE FOR SATISFACTION OF JUDGMENT JODI I MELOY Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt PA l.D #42524 WELTMAN, WEINBERG & REIS CO, LPA 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 VWVR#03414908 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PALISADES COLLECTION,LLC,ASSIGNEE OF PROVIDIAN SANK Plaintiff vs. Civil Action No. 04-4499 CIVIL JODI I MELOY Defendant PRAECIPE FOR SATISFACTION OF JUDGMENT At the request of the undersigned attorneys for the Plaintiff, you are directed to satisfy the above-captioned Judgment WELTMAN, WEINBERG & REIS CO., L.PA WWR #03414908 \,-") "Tl :-=! 10 GJ ;'~,) C,J