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Home My WebLink About04-4501IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PALISADES COLLECTION, LLC, ASSIGNEE OF PROVIDIAN BANK Plaintiff VS. DEBRA K. NOLL, Defendant COMPLAINT IN CIVIL ACTION FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: WILLIAM T. MOLCZAN, ESQU1RE PA I.D.#47437 Weltman, Weinberg & Reis Co., L.P.A. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#03416578 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PALISADES COLLECTION, LLC, ASSIGNEE OF PROVIDIAN BANK Plaintiff VS. DEBRA K. NOLL, Defendant Civil Action No. 0 ~- t/SO I 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. 1F 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 Plaintiff is a corporation with offices at P.O. Box 1244, Englewood Cliffs, NJ 07632, PA 17050. Defendant is an adult individual residing at 12t5 MITCHELL DR, MECHANICSBURG, 3. Defendant applied for and received a credit card issued by Plaintiffs assignor bearing the account number 4328072300419450. 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 $5,320.49. 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. Althoug~ repeatedly requested to do so by Plaintiff, Defendant has willfully failed and/or refused to pay thc principal balance, finance charges or any part thereof to Plaintiff. WHEREFORE, Plaintiff demands Judgment in its favor and against Defendant, DEBRA K. NOLL, individually, in the amount of $5,320.49 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. W LL AM . OL~ZAN, 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#:03416578 VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA. C.S. 4904 relating to unswom falsifications to authorities, that he/she is ~, 6., I6,L'l [.g~c,t] OI?~.j'~'J'I~D~ ~flflO~g~ of P£tJit3/t~/-~ (.~O[[e&'J'j~gl. [.LC, plaintiffherein, that ! (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. Stephen Schlicht [,egal Operations Manager SHERIFF'S RETURN CASE NO: 2004-04501 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PALISADES COLLECTION LLC VS NOLL DEBRA K - 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 NOLL DEBR~ K DEFENDANT , at 1446:00 HOURS, at 1215 MITCHELL DRIVE MECHANICSBURG, PA 17050 DEBP~A K. NOLL a true and attested copy of COMPLAINT & NOTICE the on the 13th day of September, 2004 by handing to together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 6.66 Affidavit .00 Surcharge 10.00 o00 34.66 Sworn and Subscribed to before me this /~, ~ day of ~'~/, ~",~c.,' · ~ ~2 ~,~ Y' A.D. ~ ~Prothonotary ~ ~ ' So Answers: R. Thomas Kline 09/14/2004 WELTMAN WEINBERG RELg //~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PALISADES COLLECTION, LLC., ASSIGNEE OF PROVIDIAN BANK Plaintiff VS. DEBRA K. NOLL Defendant No, 04-4501 PRAECIPE FOR DEFAULT JUDGMENT 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 Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#03416578 Judgment Amount $ 5,320.49 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. DEBRA K. NOLL Defendant Civil Action No. 04-4501 PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter Judgment against the Defendant, Debra K. Noll, above named, in the default of an Answer, in the amount of $5,320.49 computed as follows: Amount claimed in Complaint $5,320.49 Interest from date of judgment at the legal interest rate of 6.0% per annum TOTAL $5,320.49 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. pWi/~lli.a~ T~TM4~l~zan, E~f~fire WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WW R#03416578 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: 1215 Mitchell Drive Mechanicsburg, PA 17050 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PALISADES COLLECTION, LLC, ASSIGNEE OF PROVIDAN BANK Plaintiff VS, DEBRA K. NOLL Defendant TO: Debra K. Noll 1215 Mitchell Drive Mechanicsburg, PA 17050 Date of Notice: /"~X/g~¢// YOU ARE IN DEFAULT Civil Action No. 04-4501 TO ENTER A WRITTEN APPEARANCE IMPORTANT NOTICE BECAUSE YOU HAVE FAILED 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 #03416578 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., L.P.A. William T. Molczan, Es~fire PA I.D. #-47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#03416578