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Home My WebLink About04-4500V• IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PALISADES COLLECTION, LLC, ASSIGNEE OF PROVIDIAN BANK Plaintiff VS. BRETT A. BOSTWICK Defendant No. b ?- e/ S o-v C', ? 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#03415252 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PALISADES COLLECTION, LLC, ASSIGNEE OF PROVIDIAN BANK Plaintiff vs. Civil Action No. b(/' dS-O-Z) BRETT A. BOSTWICK 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. 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 1404 RED MAPLE CT NEW CUMBERLAND,PA 17070. 3. Defendant applied for and received a credit card issued by Plaintiffs assignor bearing the account number 4031182699715364. 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 $4,270.46. 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, BRETT A. BOSTWICK individually, in the amount of $4,270.46 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. WILL AM T. MIL AN, ESQUIRE PA I.D.947437 Weltman, Weinberg & Reis Co., L.P.A. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#:03415252 VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA. C.S. 4904 relating to unsworn falsifications to authorities, that he/she is S f qke n C k (IGt1 t (NAME) Ll5al l1ni o- i0diS ?' IGIt' er ot- Phiiyade? C?i le??r?n L?, plaintiff herein, that J (TITLE) ?J (COM4ANY) 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. XW"A (SIGNATURE) Stephen Schlicht Legal Operations Manager V` v' J M I ? J ` a 1 l 1 ??. _ V\ _ CJ `?i Lii ? SHERIFF'S RETURN - REGULAR CASE NO: 2004-04500 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PALISADES COLLECTION LLC VS BOSTWICK BRETT A. SHANNON SHERTZER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon BOSTWICK BRETT A the DEFENDANT , at 1950:00 HOURS, on the 14th day of September, 2004 at 1404 RED MAPLE COURT NEW CUMBERLAND, PA 17070 by handing to BRETT BOSTWICK a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 12.58 Affidavit .00 Surcharge 10.00 .00 40.58 Sworn and Subscribed to before me this daw .C day of ???w. flloo`( A.D. /PXthonoottary So Answers: R. Thomas Kline 09/15/2004 WELTMAN WEINBERG REIS By: Vt=putyLSherif IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA CIVIL DIVISION PALISADES COLLECTION, LLC, ASSIGNEE OF PROVIDIAN BANK, Plaintiff vs. BRETT A BOSTW ICK, Defendant No 04-4500 SUGGESTION OF BANKRUPTCY FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY JAMES P VALECKO, ESQ PA ID 79596 WELTMAN W_INBERG & REIS CO LP A 2718 KOPPERS BUILDING 4367 AVE PITTSBURGH PA 15219 (412) 434-7955 W W R#03415252 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANiu CIVIL. DIVISION PALISADES COLLECTION, LLC, ASSIGNEE OF PROVIDIAN BANK, Plaintiff vs. BRETT A. BOSTW ICK, Defendant TO PROTHONOTARY: No 04-4500 SUGGESTION OF BANKRUPTCY AND NOW comes Plaintiff, by counsel, Weltman, Weinberg & Reis, Co.. L.P.A. to advise this Honorable Court that the above named Defendant, Brett A. Bostwick, has filed a Chapter 13 Bankruptcy in the United States Bankruptcy Court for the Middle District of Pennsylvania at Bankruptcy C Ise Number 04-06093, and accordingly, all proceedings in this Court are stayed pursuant to 11 ?J ., C 362 W ELTMAN W EINBERG & REIS CO.. L.P A. By)bo..es P aie sq. Attorney foi/tintiff 2718 Koppers Building 436 Seventh Avenue Pittsburgh PA 15219 ro l i c_? i r oc? ` ? y"- ?.? .._{ r 1. ? ._ ?.J r- :: t'} .? ?_ c? Renee K. Simpson Deputy Prothonotary Curtis R. Long prothonotary e of tI), pr(jtb(m(jtarp offt,c (Cumberfaub Ccuntp John E. Slike solicitor ?S-? CIVIL TERM ORDER OF TERMINATION OF COURT CASES .NOVEMBER 2007 CSAFTERINMAILING HE ABOV O AND NOW THIS 5? DAY OF WITH PA N TO PROCEED AND RECEIV IN??I ACCORDANCE INTENTION F CASE IS HEREBY TERMINATED WITH R. C P 230.2. BY THE COURT, CURTIS R. LONG PROTHONOTARY Carlisle, Pennsylvania 17413 (717) 240-6195 • Fax (717) 240-6573 One Courthouse Square Car