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Home My WebLink About04-4692IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PALISADES COLLECTION, LLC, ASSIGNEE OF PROVIDIAN BANK Plaintiff VS. PAMELA J WATKINS Defendant COMPLAINT IN CIVIL ACTION FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: JAMES C WARMBRODT, ESQUIRE PA I.D.#42524 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#03415792 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PALISADES COLLECTION, LLC, ASSIGNEE OF PROViDIAN BANK Plaintiff VS. PAMELA J WATKINS Defendant Civil Action No. 0¢. ~/6 ~,W.. ~ ~ 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 enter/ng 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 BEDFQRD STREET CARLISLE, PA 17013 (7'~ 7) 249~3166 COMPLAINT Plaintiffis a corporation with offices at P.O. Box 1244, Englewood Cliffs, NJ 07632. 2. Defendant is an adult individual residing at 107 Lilmont Drive Pittsburgh, PA 15218. 3. Defendant applied for and received a credit card issued by Plaintiff's assignor bearing the account number 4254480600690274. 4. Defendant made use of said credit card and has currently a balance due and owing to Plaintiff] as of September 4, 2004, in the amount of$ 3,317,68. 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. Plaintiffavers 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, PAMELA J WATK1NS individually, in the amount of $ 3,317.68 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,~WWWWW~RG & REIS, CO., L.P.A, JA1VI~ES C WARMBRODT, ESQUIRE PA Lp.#42524 WIL/,IAM T. MOLCZAN, ESQUIRE PA ~/.D.#47437 We/Itman, Weinberg & Reis Co., L.P.A. 27/18 Koppers Bldg. d~36 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#:03415792 I AUSAi)ES COLLECTIOIi, LLC, PAMELA J WATKINS 107 LILMONT DR PITTSBURGH, PA 15218 PALISADES FILE NUMBER 8878505 NEW BALANCE $3,317.68 ADDRESS tPAYMENTDUEDATE 7/10/2004 PLEASE WRITE IN AMOUNT OF PAYMENT ENCLOSED MINIMUM PAYMENT $3,317.68 pLEASE DETACH AND TOP PORTION WITH YOUR PAYMENT ACCOUNT NUMBER 4254480600690274 DATE REFERENCE NUMBER 7/10/2004 CREDIT LIMIT 0 CREDIT AVAIASLE 0 NEW TRANSACTIONS BALANCE DUE 7/10/2004 PALISADES COLLECTION, L.L.C. DELAWARE LIMITED LIABILITY CORP. ASSIGNEE OF PROVIDIAN BANK P.O. BOX 1244 ENGLEWOOD CLIFFS, NJ 07632 PAST DUE $3,317.68 STATEMENT CLOSING DATE 7/10/2004 AMOUNT $3,317.68 SUMMARY OF TRANSACTIONS PREVIOUS BALANCE $3,317.68 PAYMENTS AND CREDITS PAYMENT DUE DATE 7/10/2004 SEND INQUIRN~S TO: PALISABES COLLECTION, LLC. P.O. BOX 1244 ENGLEWOOD CLIFFS, NJ 0;'832 NEW BALANCE $3,317.68 MINIMUM PAYMENT $3,317.68 WWR- File # 3415792 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 Legal Operations Manager of (TITLE) Wentworth Browne (NAME) Palisades Collection, LLC (COMPANY) , plaintiffherein, that he/she is duly authorized to make this verification, and that the facts set forth in the foregoing Complaint are tree and correct to the best of his/her lmowledge, information and belief. Wentworth Browne ~ WWR# SHERIFF'S RETUR/q - OUT OF CASE NO: 2004-04692 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PALISADES COLLECTION LLC VS WATKINS PAMELA J COUNTY R. Thomas Kline duly sworn according to law, says, that he made a diligent and inquiry for the within named DEFENDANT , to wit: WATKINS PAMELA J but was unable to locate Her in his bailiwick. deputized the sheriff of ALLEGHENY County, serve the within COMPLAINT & NOTICE , Sheriff or Deputy Sheriff who being search and He therefore Pennsylvania, to On October 20th , 2004 , this office was in receipt of the attached return from ALLEGHENY Sheriff's Costs: Docketing 18.00 Out of County 9.00 Surcharge 10.00 Dep Allegheny Co 50.00 Notary 3.00 90.00 R. ~~S° answe~r~- ......... - Sheriff of Cumberland County Sworn and subscribe~o before me this 2% dayof [~?0~-)~ AD 10/20/2004 WELTMAN WEINBERG REIS In The CoUrt of Common Pleas of Cumberland County, Pennsylvania Palisades Collection LLC ~~ VS. Parnela J. Watkins OW 04.4692 civil /07 [tlmc -t c , Se~r 21, 2004 , I, S~FF OF C~E~ CO~TY, PA, do h~eby deputize ~e Shehffof hllegheny Co~W to execute ~is Writ, ~is deputation being made at the request and risk of the Plaintiff, ~,~ ~ ~rT Sheriff of Cumberland County, PA Affidavit of Service Sow,.~'~(7'-,~-,-~ ~ ~ ,200~., at //J-5-~o'clock upon P~I,~t~CA L,d~lT-tct,~,ff by h~ding to ~*l ~ ~ r~ ~ M. served the a and made known to copy of the original the contents thereof. So answers, Sheriff of ~tl~F*~'~ County, PA COSTS Sworn and subscribed before SERVICE me fids day of 0C~- 0 *3, ~ MILEAGE ~ r/~k~ AFFIDAVIT / ~.[,.-Jr~.M~COMMONWEALTH OF PENNSYLVANIA ~ No[axial Seal ~ Sheila R. O'Bden, NolatyPublic ~ City of Pittsburgh. AJlesheny Couaty I Myl2ommissioa~Expires Jtme 19.2008 Member, Pennsylvania Asaociation of Nofatfe$ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PALISADES COLLECTION,LLC., ASSIGNEE OF PROVIDIAN BANK Plaintiff VS. PAMELA J. WATKINS, Defendant No. 04-4692 PRAECIPE TO SETTLE, DISCONTINUE AND END WITHOUT PREJUDICE TO REFILE FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt PA I.D fl42524. William T. Molczan, Esquire PA. I.D.f14743'7 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWRC¢03415792 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PALISADES COLLECTION,LLC., ASSIGNEE OF PROVIDIAN BANK Plaintiff VS. PAMELA J. WATKINS, Defendant Civil Action No. 04-4692 PRAECIPE TO SETTLE, DISCONTINUE AND END WITHOUT PREJUDICE TO REFILE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: SIR: Settle, Discontinue and End the above-captioned matter upon the records of the Court without prejudice to refile and mark the costs paid. Wendy L. Gaul Notary PuOtlc Ci~ Of I:~tsburgh, Allegheny Coun.r~' Mv Com~ssion Ex~ires July 15, 20¢6 SWORN TO AND SUBSCRIBED before[~ thi,s ~'~ day WELTMAN, WEINBERG & REIS CO., L.P.A. Attorr~;~ for Plaintiff 271 K ppers Building 43~SKe IePnP~hr ~,vBeU~ du ~g Pi~sbL~t'gh, PA 15219 (~12),A34-7955 WW/~#03415792 //