HomeMy WebLinkAbout04-4694IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANI
PLATINUM FINANCIAL SERVICES NO. 410?Q
CORP., A MARYLAND CORPORATION,
ASSIGNEE OF UNIFUND CCR PARTNERS
, ASSIGNEE OF MBNA AMERICA BANK-
MASTERCARD
P.O. BOX 10247
ROCKVILLE, MD 20849-0247
Plaintiff
VS.
CIVIL ACTION - LAW
GLENN E CHANEY
207 TAUNTON DR
CARLISLE PA 17013-4707
Defendant(s)
NOTICE
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 (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 or any other claim or relief requested by the Plaintiff.
You may lose money or property 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 HELP. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH
INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A
REDUCED FEE OR NO FEE.
NOTICIA
Le han demandado a used en la corte. Si used quarere defensas de esas demandas
expuestas en las paginas, siguientes, used tiene viente (20) dias de plazo al partir
de la fecha de lademanda y la notifiation. Used debe presentar una apariencia
escrita o en persona o por abogado y archivar en Is corte an forma escrita sus
defensas o sus objeciones a last demandas an corta de su persona. Sea avisado que
si used no se defienda, la corte tomara medidas y psedido entrar una orden contra
used sin previo aviso o notificacion y por cualquier queja o alivio que es pedido
en Is peticion de demanda. Used puede perder dinero o sus propledades o otros
derechos importantes pars used.
LLEVE ESTA DEMANDA A UN ABODOAGO IMMEDIATAMENTE. SI NO TIENE ABOGADO 0 SI NO TIENE
EL DINERO SUFFICIENTE DE PAGAR TAL SERVICIO VAYA EN PERSONA 0 LLAME POR TELEFONO A
LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABASO PARA AVERIGUAR DONDE SE PUEDE
CONSEGUIR ASSITANCIA LEGAL.
Lawyer Referral Service
Cumberland County Bar Assn.
32 S. Bedford St.
Carlisle PA 17013
800-990-9108
CVRNOT/PACCP W&A FILE NO. 102922902
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PLATINUM FINANCIAL SERVICES
CORP., A MARYLAND CORPORATION,
ASSIGNEE OF UNIFUND CCR PARTNERS
, ASSIGNEE OF MBNA AMERICA BANK-
MASTERCARD
P.O. BOX 10247
ROCKVILLE, MD 20849-0247
Plaintiff
NO. 014 - (4(.qL( l.. l U LL(--?
VS.
GLENN E CHANEY
207 TAUNTON DR
CARLISLE PA 17013-4707
Defendant(s)
CIVIL ACTION - LAW
COMPLAINT
Now comes the Plaintiff, PLATINUM FINANCIAL SERVICES , by and through its
attorneys, and the law firm of Wolpoff & Abramson, L.L.P., and files this Complaint
and in support avers as follows:
1. Plaintiff, PLATINUM FINANCIAL SERVICES
CORP., A MARYLAND CORPORATION,
ASSIGNEE OF UNIFUND CCR PARTNERS
, ASSIGNEE OF MBNA AMERICA BANK-
MASTERCARD
P.O. BOX 10247
ROCKVILLE, MD 20849-0247
is a business entity doing business within the Commonwealth of Pennsylvania and the
other states of the United States.
2. Defendant, GLENN E CHANEY
a last known address of
207 TAUNTON DR
CARLISLE PA 17013-4707
COUNTY OF CUMBERLAND
3. It is averred that Defendant(s) was/were
account. The Terms and Conditions governing this
incorporated herein and marked as Exhibit "A".
, is an adult individual with
issued an open end credit card
account is attached hereto,
4. At all relevant times material hereto, Defendant(s) has/have used said
charge card for the purchase of products, goods and/or for obtaining services.
1DSOA1/PACCP W&A FILE NO. 102922902
5. Plaintiff provided Defendant(s) with copies of the Statements of Account
showing all debits and credits for transactions on the aforementioned credit card
account to which there was no bona fide objection by Defendant(s).
6. Pursuant to the Agreement concerning this account, the parties agreed
that this matter be referred to Arbitration in the event of any claim and/or dispute
if the account is referred for collection. See Exhibit "A" as previously identified
and incorporated herein.
7. This matter was referred to Arbitration for determination and disposition,
whereby an Arbitration Award was entered against the Defendant(s) and in favor of
the Plaintiff for the outstanding balance due. A true and correct copy of the
Arbitration Award is attached hereto, incorporated herein and marked as Exhibit "B".
8. As of the date of this Complaint, the remaining balance due, owing and
unpaid on Defendant's credit card account, as a result of charges made by said
Defendant(s) and/or any authorized users is the sum of $ 5138.52
9. Despite reasonable and repeated demands for payment, Defendant(s) has/have
failed, refused and continue(s) to refuse to pay all sums due and owing on the
aforementioned account balance, all to the damage and detriment of the Plaintiff.
10. The amount in controversy is within the jurisdictional amount requiring
compulsory arbitration.
WHEREFORE, Plaintiff, PLATINUM FINANCIAL SERVICES respectfully requests
this Honorable Court enter judgment in favor of Plaintiff and against Defendant(s),
GLENN E CHANEY , in the amount of $ 5138.52 plus costs of this
action and such other relief as the Court deems proper and just.
Respectfully submitted,
X70
Amy F. Do ?E87062
Daniel F. ferkis lfson #20617
Bruce H. x/18837
Philip C. Warholic #86341
WOLPOFF & ABRAMSON, L.L.P.
Attorneys in the Practice of Debt Collection
267 East Market Street
York, PA 17403
(717) 846-1252
Counsel for Plaintiff
1DSOA2/PACCP W&A FILE NO. 102922902
ATTORNEY VERIFICATION
I hereby state that I am the attorney for the Plaintiff, who is located
outside of this jurisdiction and in order to file the within document in an
expedient and timely manner, am authorized to take this verification on behalf of
said Plaintiff in this action and verify that the statements made in the foregoing
Complaint are true and correct to the best of my knowledge, information, and
belief, based upon information provided by the Plaintiff.
The undersigned understands that false statements herein are made subject to
the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification
to authorities.
Date:
Amy F. Doyl #87062
Daniel F. fson #20617
Bruce H. C rkis #18837
Philip C. Warholic #86341
WOLPOFF & ABRAMSON, L.L.P.
Attorneys in the Practice of Debt Collection
267 East Market Street
York, PA 17403
(717) 846-1252
Counsel for Plaintiff
PAVERF/PACCP W&A FILE NO. 102922902
I Account Agreement
.,Y
General: In this Agreement, the words "you" and "your" refer to each and all of the persons in whose names this account was issued and who obtai
credit in any way provided for under this Agreement 7be r,ords "we," "us," "our," and '74BNA America" mean MBNA America Bank, NA The rvor•
"Advance" means any loan you obtain from us under this Agreement
I
Our Agreement with you consists of this Agreement and the terms and conditions printed on the required federal disclosures section Of the accompany
Terms of Your Account letter, which is incorporated herein and made a pan hereof. Please keep these documents, and subsequent amendments. if any,
together.
When you, or anyone whom you authorize or pemnit, use your account, you agree to the terms of this Agreement ;
You consent to and authorize MBNA Ameria, any of its affiliates, a its marketing associates m monitor s war record any 0 your lelephow
conversations with our representatives or the representatives of any of those companies.
All capitalized terms not defined herein shag ban the meaning as defined in the required federal disclosures section of your Terms of Yoty Account letta.
Credit Reporting Agencies: If you believe we hi ve'furnished inaccurate or incomplete information about you or your account to a credit reporting
agency, write to us at: MBNA, Credit Reporting Agencies, P. O. Box 17054, Wilmington, DE 19884-7054. Please include your name, address, home
phone number, and account number, and explain what you believe is inaccurate or incompkk.
now To Use Your Account: You may use your account to purchase or lease goods or services from persons who honor checks. You may obtain such
credit under your account by requesting checks or drafts payable in U.S. Dollars that will be sent either directly to your designated payees or to you for
iorwarding to your designated payees. We may offer the direct deposit of Advances into year banking account or those of your cseditos Avai1abMW of
funds sent through direct deposit depends upon the policies and procedures of the receiving bank. if this account includes a special fat6M to pumcmw
goods or cervices from s merchant, we may send Advances directly to the merchant on your behalf. From time to time, we may issue you additiaai
checks or offer other additional Advances in response to your rcqueaL You may not use any Advance solely to make a payment on this account or sokly to
make a payment on any other credit account with us.
i
If you permit any person to have access to your checks or account number with the authorization to make a charge, you may he gable for all Advanors
made by dot person including Advances for which you may not have intended to be liable.
You agree not to use a postdated check to obtain credit under your account V you do postdate a check by whieh you propose to obtain credit amda your
account, we may elect to honor it upon presentment or return it unpaid to the parry which presented it for payment, without in either case awaiting the desk
shown on the cheek. We an not liable to you for any loss or expense incurred by you arising out of to action we elect to take.
You must return all checks to us on request
Credit IAmiC Your credit limit is shown on your Terms of Your Account letter and generally on each monthly statmatuaL We my change your audit
limit or limits from time to time, and we will notify you if we do. The total amount of credit outstanding st anytime most no be more than your credit
limiL We my also establish a separate "edit limit for certain balances. If we do, your outstanding balance on these typo of items ray not exceed two
separate credit limit
Request for Credit Over Your Credit Limits: If you request credit in any form which, if granted, would result in either your total outstanding balm,
or your separate outstanding balm", including authorized transactions not yet posted to your account, being more than your credit limit or your separate
"edit limit, if we have established one for you, (whether or not such balances before the request were more than the respective credit limit), we may:
(I) Honor the request without permanently raising your credit limit;
.(2) Honor the request and treat the amount which is more tan your credit limit as due immediately, a
(3) Refuse to honor the request. We nay advise the person who made the request tut it has been refused. if we refuse to honora check, roe
may do so by advising the person presenting the check that credit has been refused, that there are insufficient funds to pay the check, or in any
other mamma.
If we have previously honored requests for credit over your credit limit, it does not man dust we will honor further ovsiim(t requests. If we decide 10
honor such a request, we nay assess an overlimdt fee as provided in this Agreement
Additional Advances: You may obtain additional Advances from time to time provided that you continue to meta our income and credit standards
without any significant adverse change. 71e approval of one request does not mean the approval of other requests. Additional Advances posted to your
account cause the tern of the loan to n-start, resulting in a revised minimum monthly payment and revised length of time to repay the loan. Additions]
Advances must be at least 5200.00.
Term of Your Loan: Your repayment term is disclosed in another document location. Your monthly payment amount will be disclosed as the Currant
Payment of your monthly statements. Chain evens may result in your account balance not being paid off during the temm In this case, we do not
change the minimum monthly payment amount Instead, we extend the term to repay the balance. For example, the following evens will extend the tarts:
(i) a payment holiday which you take; (ii) an increase in the prime rate for any variable annual percentage rate account (iii) all feet imposed on your
account, such as check transaction fees, late fees, ova the credit limit fees and insurance premiums; and (iv) payments received Iota than the payment due
date.
Also, the minimum rrronthly payment does not take into account the effect of adding unpaid periodic Rate Finance Charges assessed on Advances to t
daily Advance balance. This will extend the term
The following events will reduce the term (but will not change the mininatm payment due each matthk 1 a tempenary, reduction in the annual percentatg
rate, such as a promotional rate; (ii) a decrease in the prime rate for any variable annual percentage ate; and Citl) payments greater then the require
minimum payment
Repayment: You promise to pay us the amounts of all credit you obtain; this includes all Advances, any fees, charges, and insurance premiums we
charge against your account; and Finance Charges.
You may pay the entire amount outstanding at any time without penalty. You must pay each month at least the minimum payment shown on your
monthly statement The minimum payment will be the total of (ti) the current payment amount Shown on your monthly Statement; plus (ii) the amount oC
any past due paymmts. The current payment amount is based upon the amount outstanding, the term of your loan, and the annual Percentage see. uyou
overpay or if a credit balance is otherwise created in your account, we will not pay interest on such amounts. Payments greater than the required
minimum payment will reduce the total amount of Finance Charges otherwise payable by you.
We will allocate your payments in the manner we determine. In most instances, we will allocate your payments to balances (including new banac6c o s)
with low" APRs before balances with higher APRs. This will result in new balances with lower APRs (for example, those with pra mlimwi APR offers)
being paid before any other existing balances. All payments will be credited to your account for the billing cycle in which each payment is received.
Minimum monthly' payments cannot'be made in advance and payments made in mybining cycle which are greater thatithe minimum payment due wip
not affect your obligation to make subsequent minimum payments each month. We can reject payments not denominated in U.S. dollaas or not drawn on
a U.S. Bank No payment shall operate as an accord and satisfaction without the prior written approval Of $ Maio, officer of MBNA America.
All persons who initially or subsequently request, accept or use the account are individually responsible for any outstanding balsam If two or more
persona an responsr'ble to pay any outstanding balance, we may refuse to release any of them from liability until an of the checks outstanding under the
account have been wormed to us and the balance is paid in A&
Payment Holidayu We may allow you, from time to time, to omit a monthly payment We will notify you when this option is available. If you mart ¦
payment, Finance Charges and insurance premiums, if any, will accrue on your balance in accordance with this Agreement The requirement glut yeses
make a minimum payment each month win nes'ume folowing your payment holiday. A payment holiday will increase the farm of your loan.
Billing Cycle: A billing cycle begins on the day after the closing date shown on your secmmt's preceding monthly statement and code on the ebatng data
that appema on your account's statement for the current month.
insurance: Croup credit insurance may be offered to you from time to time. Purchase of this insurance is strictly optional. If purchased, the fi m me,
will protect us Kan event occurs for which benefits are provided. We determine the cost of this insurance by multiplying the insurance rate then in eifeet
by the avenge of your Advances and other charges outstanding during the billing cycle. The premium is charged to your account u an Other Charge.
Benefits: You may be offered certain benefits thorn time to time, which win be subject to the restrictions outlined by MBNA Amariea in a brochure a
otherwise. MBNA America serums the right to adjust, add, a delete benefits and services at my time and without notice.
Reasons for Requiring Immediate Payment: You will be in default and we can require immediate payment of an amounts you owe if: (1) you fill to
make any required payment by the Payment Due Date; (2) your New Balance Total exceeds your credit limit, or if we have established a separate "edit
limit for you, your separate outstanding balance exceeds your separate credit limit; or (3) you fail to abide by any other tune of this Agreement
If you default, unless prohibited by applicable law, we can also require you to pay the collection and court costs we incur in my collection proceeding, sid
a reasonable attomey'a fee if we rcfa your account for collection to an attorney who is not our salaried cmpkryae.
Our failure to exercise any of our rights when you default does not mean that we are unable to exercise those tights upon later defauh.
Refusal to Honor Your Account: We are not liable for any refusal to honur your account, including arty form of Advance, or far any retention of your
checks by us, my other bank, or my seller or lessor of goods or services.
Termination: We may suspend cr terminate your rights to obtain credit at any time for any reason. Your obligations under this Agreement continue an
after your rights to obtain credit have been suspended or terminated.
Amendments: We may amend this Agreement at any time by adding, deleting, or chmging.provisiota in compliance with the applieabk notifsatitn
requirements of federal law and the laws of the State of Delaware. If an amendment gives you the opportunity to reject the change, and if you reject the
change in the manna provided in such amendment, we may terminate your right to receive credit and may ask you to serum an credit devices ss a
condition of your rejection. The amended Agreement (including my higher rate or other higher charges or fees) will apply to the entire unpaid balance,
including the balance existing before the amendment became effective. We may replace your account with another account at any dine.
Assignments: We may at any time, and without notice to you, assign your account, any sums due on your account, this Agreement or our rights or
obligations under your account or this Agreement to any person or entity. The person or entity to whom we make any such assignment shall be entitled to
all of our rights and/or obligations under this Agreement, to the extent assigned.
Unauthorized Use of Your Account: You are liable for the unauthorized use of your account. You should immediately notify us at MBNA Amens
P.O. Box 15021, Wilmington, DE 19850, (Telephone 1-800492-8349), orally or in writing, of the loss, theft, ce possible unauthorized use or yes,
account.
Litigation: The Arbitration provisions below apply to you mien you were given the opportunity to reject the Arbitration provisions and you did so reja
them; in which case you agree that any litigation brought by you against us regarding this account or this Agreement shall be brought in a court located it
the State of Delaware.
I
Arbitration: Any claim or dispute ("Claim") by either you or us against ft other, or against the employees, agents or assigns of the other, arising from w
relating in any way to this Agreement or any print Agreement or your account (whether under a statute, in contract, tort, or otherwise and whether for
money damages, penalties or declaratory in equitable relief), including Claims regarding the applicability of this Arbitration Section or the validity of the
entire Agreement or any prior Agreement, shall be resolved by binding arbitration. "Claim" shall have the broadest meaning possible-
The arbitration shall be conducted by the National Arbitration Forum ("NAn, under the Code of Procedure in effect at the time the elai is filed. Rules
and forms of the National Arbitration Forum may be obtained and Claims may be filed at any National Arbitration Forum office, www. forum.eom, or
P.O. Box 50191, Minneapolis, Minnesota 55405, telephone 1.800474-2371. If the NAF is unable or unwilling to act as arbitrator, may substitute
another nationally recognized, independent arbitration organization that uses a similar code of procedure. At your written request, we ill advance any
arbitration filing fee, administrative and hearing fees which you are required to pay to pursue a Claim in arbitration. The arbitrator will d 'de who will be
ultimately responsible for paying those fees. In no event will you be mquimd.to reimburse us for any arbitration filing, administrative or hearing fees J. as
amount greater than what your court costs would have been if the claim bad been r. lwd in Battle court withjurisdiction. Any arbitration hearing at
which you appear will take phec: within the federal judicial district that includes your billing. address at the time the Claim is filed. This arbitration
agreement is made pursuant to a transaction involving interstate commerce, and shall be gavelled by the Federal Arbitration Act, 9 U.S.C. it 1-16
("FAA'). Judgment upon any arbitration award may be entered in any court having jurisdiction: TM arbitration shall follow existing substantive law ro
the extent consistent with the FAA and applicable statutes of limitations and shall honor any claims or privilege recognized bylaw. If any perry requests,
the arbitrator shall write an opinion containing the reasons fm the award.
No claim submitted to arbitration is heard by a jury and no Claim may be brought as a clan action or as a private attorney general. You do not have the
right to act as a class representative or participate a a member of a class of claimants with respect to any Claim This Arbitration Section applies to all
claim now in c?ds1mce or that may arise in the future.
This Arbitration Section shall survive the termiatim of your account with as as well as arty voluntary payment of the debt in full by you, any bardouptey,
by you or sale of the debt by 1111.
For the purposes of this Arbitration Section, "we' and' us" morns MBNA America Book NA, its parent, subsidiaries, affiliates, licensees, predecessors,
successor, assigns, and any purchaser of your account, and all of their officers, directors, employees, agents and assigns warty and all of there.
Additionally, "we" or "us" shall mncm any third party providing benefits, services, in products in connection with the account (including but not limited to
credit bureaus, merchants that accept any credit device issued under the account, reward or enrollment services, credit insurance companies, debt .
collector and all of their officers, directors, employees and agents) if, and only if, such a third party is named by you as a co-defendant in any Claim you
asset against us. Also, for the purposes of this Arbitration Section, "you" a yours" shall morn any person in entity approved by us to use the account,
including but not limited to all persons in entities contractually obligated on the account and all authorized user of the occo'M
If any pan of this Arbitration Section is found to be invalid or unenforceable under any law or stature consistent with the FAA, the ram inda of this
Arbitration Section shall be enforceable without regard to such invalidity in unenforcnbility.
THE RESULT OF THIS ARBITRATION AGREEMENT IS THAT, EXCEPT AS PROVIDED ABOVE, CLAIMS CANNOT BE L MGATED IN
COURT, INCLUDING SOME CLAIMS THAT COULD HAVE BEEN TRIED BEFORE A JURY, AS CLASS ACTIONS OR AS PRIVATE
ATTORNEY GENERAL. ACTIONS. .
Governing Law: This Agreement is made in Delaware. It is governed by the laws of the State of Delaware, without regard to its wnfliet of laws
principles, and by any applicable federal laws.
If any part of this Agreement is found to be invalid, the rest remains effective. Our failure in delay in exercising any of ow rights under this Agreement
does not mean that we am unable to exercise those rights later.
MBNA America® is a federally registered service mark of MBNA America Bank, N.A.
0 2001 MBNA America Bank NA
Privacy
Your privacv Is important to us
At MBNA, we are committed to providing you with the finest financial products and services backed by consistently top-quality serv
And while information about you is fundamental to our ability to do this, we fully recognize the importance of keeping personal and
account information secure. '
To offer you the widest range of products and services, MBNA may share information about you both within MBNA and outside of
MBNA with other companies. This allows us to offer you products and services that may interest you and best meet your needs, whet
they are available directly from MBNA or through our relationships with other companies. We want you to understand our informstic
safeguards, what information we collect, what information we share, and the benefits you receive when we share information about yo
This notice describes the privacy practices of MBNA Corporation and all MBNA affiliates, including MBNA America Bank, N.A.,
MBNA.America (Delaware), N.A., Palladian Travel Services, Inc., MBNA Hallmark Information-Services, Inc., hMNA" Marketing
Systems, Inc., and MBNA Insurance Agency, Inc. (collectively, "MBNA'), for financial products and services governed by the laws of
the United States of America. This notice explains MBNA's information collection and sharing practices and lets you choose whether
not MBNA may share certain information about you, either within MBNA or outside of MBNA with other companies.
our Security Procedures: MBNA understands the importance of protecting and securing information and using it appropriately.
Access to information about you is restricted to the people of MBNA who require it to provide products or services to you. We maintaf
physical, electronic, and procedural safeguards that comply with federal standards for the security of information.
When MBNA shares information about you with companies outside of MBNA, we require them to impose safeguards, use it only for a
permitted purpose, and to return it to us or destroy it once that purpose is served.. We limit the amount of information shared to what is
appropriate to offer a product or service efficiently. MBNA requires any company receiving information from MBNA to sign a
Confidentiality Agreement containing these requirements and obligating that company to protect the information as we would
Information We Collect: MBNA collects and uses nonpublic personal information about you to conduct our business and to
consistently deliver the top-quality Customer service you expect from us. Sources of this information include the following:
information we receive from you on applications and other formes or through your correspondence or communication with ua
including through the frail, by telephony or over the Internet;
Information we receive from third parties, such as consumer reporting agencies, to verify statements you've made to us, or regarding
your employment, credit, or other relationships; and '
Information about your transactions with MHNA and with other companies outside of MBNA.
information We Share Within MBNA: We may share all of the information we collect about you with financial service companies
within MBNA to offer additional products or services that may interest you and best meet your needs. We believe this is convenient for
you and may save you both time and money. To do so, we share identification information (such as name and address), transaction and
experience information (such as purchases and payments), credit eligibility information (such as credit reports and applications), and
other information. The decision to purchase any such products or services is yours alone. You may tell us not to share credit eligibility
information about you within MBNA, but please understand this'does not prohibit us from offering you additional products and services
or from sharing transaction and experience, identification, and other information within MBNA.
Information We Share With Others: Prom time to time, we may allow companies outside of MBNA to offer you their products and
services that may interest you. These products and services may be offered by financial service providers (such as banks, loan brokers,
account aggregators, insurance agents, insurance companies, mortgage bankers, and securities broker-dealers), by nonfinancial
companies (such as retailers, direct marketers, communications companies, Internet service providers, manufacturers, service companies,
travel agents, cruise lines, car rental agencies, hotels, airlines, publishers, and organizations endorsing MBNA financial products or
services), and others (such as nonprofit organizations). Subject to applicable law, we may share all the information we collect with these
companies outside of MBNA, unless you tell us not to.
Additionally, we may share all the information we collect with companies that perform marketing or other services on our behalf or to
other financial institutions with which we have joint marketing agreements. We are also permitted by law to share information about you
with other companies in certain circumstances. For instance, we may share all of the information we collect with companies assisting us
in servicing your loan or account, with companies that endorse our products and services through affinity agreements, with government
entities in response to subpoenas or regulatory requirements, and with consumer reporting agencies. If you tell us not to share
information with companies outside of MBNA that wish to offer you their products and services, as described above, please understand
that we will continue to share information in these additional circumstances.
,., important Information About Your Choice: We're dedicated to serving your needs -and to respecting your choices related to
privacy. You may tell us not to share credit eligibility information within MBNA, and you may tell us not to share information with
companies outside of MBNA that wish to offer you their products and services as described above. If you wish to opt out of such
information sharing, please call toll-free 1.866-751-1255. We will ask you to verify your identity and the specific accounts to which
opt out applies, so please have all your account, membership, or reference numbers and your Social Security number or Tirtpsyer
Identification number for deposit accounts available when you call.
MBNA applies opt outs at the account level, not by individual Customer. When any person listed with others on an account opts out I
example, a co-applicant, joint account holder, or authorized user), we will list the entire account as having opted ouL MBNA will
continue to adhere to its disclosed privacy practices for an account even if it becomes inactive or is closed
An opt out from information sharing on an account as described above, either within MBNA and/or with companies outsiI of MBNA
remains effective unless revoked in writing, Federal regulations require us to provide this notice on an annual basis, whe er or not as
account has previously opted out from either type of information sharing. Please remember when you receive our subsequent notices tl
an account previously opted out from either or both types of information sharing (and not revoked in writing) does not need to be opted
.out again.
_ .._ .
This notice updates and replaces any previous notices from MBNA about the pnvacy, security, and protection of infomtatioa For
additional information regarding MBNA's privacy practices concerning the Internet, and to view the moat recent version of this privacy
notice, please go to www.mbnacom and click on "Privacy Notice." You may have other privacy protections under state law& We may
amend this privacy notice at any time, and we will inform you of changes as required by law.
NATIONAL
ARBITRATION
Platinum Financial Services Corp
c/o Wolpoff & Abramson, L.L.P.
Attorneys in the Practice of Debt Collection
702 King Farm Blvd, Two Irvington Centre
Rockville, MD 20850-5775
FORUM a
CLAIMANT(S), AWARD
RE: Platinum Financial Services Corp v Glenn E Chaney
File Number: FA0304000154661
Claimant File Number: 74982999343973
Glenn E Chaney
207 Taunton Dr
CARLISLE, PA 170134707
RESPONDENT(s).
The undersigned Arbitrator in this case FINDS:
1. That no known conflict of interest exists.
2. That on or before 04/17/2003 the Parties entered into an agreement providing that this matter shall be resolved
through binding arbitration in accordance with the Forum Code of Procedure.
3. That the Claimant has filed a claim with the Forum and served it on the Respondent in accordance with Rule 6.
4. That the matter has proceeded in accord with the applicable Forum Code of Procedure.
5. The Parties have had the opportunity to present all evidence and information to the Arbitrator.
6. That the Arbitrator has reviewed all evidence and information submitted in this case.
7. That the information and evidence submitted supports the issuance of an Award as stated.
Therefore, the Arbitrator ISSUES:
An Award in favor of the Claimant, for a total amount of $5,138.52.
Entered in the State of Pennsylvania
Robert artm, Esq.
Arbitrator
ACKNOWLEDGEMENT AND CERTIFICATE
OF SERVICE
This Award was duly entered and the Forum hereby
certifies that a copy of this Award was sent by first
class mail postage prepaid to the parties at the above
referenced addresses on this date,
Honorable Harold KaI%ea
Date: 07/03/2003
Director of Arbitration
07/03/2003
-AZ
?? LL
SHERIFF'S RETURN - REGULAR
CASE NO: 2004-04694 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
PLATINNUM FINANCIAL SERVICES
VS
CHANEY GLENN E
CHIEF DEPUTY RONNY ANDERSON , Sheriff or Deputy Sheriff' of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
CHANEY GLENN E
the
DEFENDANT , at 1555:00 HOURS, on the 21st day of September, 2004
at CUMBERLAND CO SHERIFF'S OFFICE ONE COURTHOUSE SQUARE
CARLISLE, PA 17013-4707
GLEN E CHANEY
by handing to
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 .00
Affidavit .00
Surcharge 10.00
.00
28.00
Sworn and Subscribed to before
me this day of
aOz3 A.D.
/ pr thonota? "
So Answers:
R. Thomas Kline
09/21/2004
WOLPOFF &
By:
i f f \,,
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PLATINUM FINANCIAL SERVICES
CORP., A MARYLAND CORPORATION,
ASSIGNEE OF UNIFUND CCR PARTNERS
, ASSIGNEE OF MBNA AMERICA BANK-
MASTERCARD
P.O. BOX 10247
ROCKVILLE, MD 20849-0247
Plaintiff
vs.
GLENN E CHANEY
Defendant(s)
NO. 200404694P
PRAECIPE FOR JUDGMENT
Mr./Ms. Clerk:
Please enter Judgment in favor of Plaintiff and against Defendant(s),
GLENN E CHANEY
for want of ANSWER TO COMPLAINT, and
,
( X ) Amount due $ 5138.52
Interest $
Attorney's Commission $
Filing costs $
TOTAL $ 5138.52
( X ) I certify that the foregoing assessmentuofldamages isdforsspecified
amounts alleged to be due in the complaint and is calculable as a sum certain from
the complaint.
( X ) Pursuant to Pa.R.C.P. 237 (Notice of Praecipe for final judgment or
decree), I certify that a copy of this praecipe has been mailed to each other party
who has appeared in the action or to his/her Attorney of Record.
( X ) Pursuant to Pa.R.C.P. 237.1, I certify that written notice of the
intention to file this praecipe was mailed or delivered to the party against whom
judgment is to be entered and to his/her Attorney of Record, if any, after the
default occurred and at least ten days prior to the date of the filing of this
praecipe and a copy of the notice is attached.
DATE: - ? - _ 6,5
Signature:
NOW,
20 ()S , J1
PR AFr.T/PAmnT W&A FTTY Nn. 1!129229!12
AY F. oyle ??87062
Daniel F. Wolfs n ??20617
Bruce H. Cherki #18837
Philip C. Warholic #86341
Ronald M. Abramson #94266
Ronald S. Canter #94000
Donald P. Shiffer, III #89451
WOLPOFF & ABRAMSON, L.L.P.
Attorneys in the Practice of Debt Collection
267 East Market St., York, PA 17403
(717) 846-1252
Counsel for Plaintiff
MENT IS ENTERED AS ABOVO
Prothonotary/Clerk, C- i Division
y
702 KING FARM BLVD ROCKVILLE, MD 20830
REGIONAL OFFICES
10505 JUDICIAL DR.. BLDG. A-5, FAIRFAX, VA 22030
108 E. MAIN ST, S
TE. 1003 RI M216
5122 G EENWICH RD., VIRGINIA BEACND, VA 23462
919 N. MARKEr ST., STE. 1300, WILMINGTON, DE 19899
1954 GREENSPRING OR., STE. 400, TIMONIUM, MO 21093
1 VALLEY BANK BLDG. BOX 1226, CLARKSBURG, W V 26302
2625 TOWNSGATE RD ,#330, W ESTLAKE VILLAGE, CA 91361
267 E. MARKET ST., YORK, PA 17403
NATIONAL COLLECTION ATTORNEY NETWORK
AFFILIATED FIRM LOCATIONS NOT REGIONAL
OF ICES O OLPOFF 8 A AM ON, L.L,P,
ANCHORAGE. BIRMINGHAM, ALABAMA ENGLEWOOD, COLORADO
PHOENIX. ARIZONA ARIZONA ALASKA FT. LAUDERDALE, FLORIDA
PHOENIX, NORCROSS, GEORGIA
CABOT, ARKANSAS HONOLUW.HAWAII
102922902
GLENN E CHANEY
WOLPOFF &W ABIRAMSON,L.L.P.
Attorneys in the Practice of Debt Collection
(A National Collection Attorney Network Firm)
267 EAST MARKET STREET
FIRST FLOOR
YORK PA 17403-2000
717-848-6203
OUTSIDE YORK METROPOLITAN AREA
(TOLL FREE)
1-800-758-0675
FACSIMILE (717) 848.1146
PLEASE DIRECT ALL INQUIRIES TO YORK OFFICE
OCTOBER 15, 2004
207 TAUNTON DR
CARLISLE PA 17013-4707
•TA9 NcBo---nal ?looyon
Atlcrn9y N9Mnrk Ie an
aMlieaon of 9epereb law Brm
WBA Hours of Operation:
8 a.m. - 11 p,m. E.S.T. M-F
W&A File No. 102922902
Re: PLATINUM FINANCIAL SERVICES ASSIGNEE OF MBNA-MASTERCARD
vs. GLENN E CHANEY
Docket No. 200404694P
Dear GLENN E CHANEY ?'
Enclosed herein please find a 10-Day Notice pursuant to Rule 237.1 of the
Pennsylvania Rules of Civil Procedure.
Sincerely,
Enclosure
WOLP FF & ABRAMSON, L.L.P.
Am . Doyle, Esquire
This is an attempt by a debt collector to collect a debt and any information obtained
will be used for that purpose.
NOT10D/PANOTC
I Y. KANSAS
(
K
PROVIDENCE
RHODE
,
ENTUCK
LOUISIANA ,
COLUMBIA, SOUTH CAROL?II
MA
MASSACHUSETTS KNOXVILLE, TENNESSEE
HOUSTON
TEXAS
LI
D- MICHIGAN
.S, MINNESOTA ,
J
SANDY, UTAH
Mu wen-,.,...__. __
LTRHO (091
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PLATINUM FINANCIAL SERVICES
CORP., A MARYLAND CORPORATION,
ASSIGNEE OF UNIFUND CCR PARTNERS
, ASSIGNEE OF MBNA AMERICA BANK-
MASTERCARD
P.O. BOX 10247
ROCKVILLE, MD 20849-0247
Plaintiff
NO. 200404694P
VS.
GLENN E CHANEY
Defendant(s)
TO: GLENN E CHANEY
207 TAUNTON DR
CARLISLE PA 17013-4707
DATE OF NOTICE: 10/15/04
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU FAILED TO TAKE THE ACTION REQUIRED OF YOU IN
THIS CASE. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE,
A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR
PROPERTY OR OTHER IMPORTANT RIGHTS.
YOU SHOULD TAKE THIS NOTICE TO 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.
Lawyer Referral Service
Cumberland County Bar Assn.
32 S. Bedford St.
Carlisle
800-990-9108 PA 17013
WOLPOFF & ABRAMSON, L.L.P.
Attnorneys in the Practice of Debt Collection
.
By:
AMY'F. Do le, Esquire ...
267 East rket Street
York, Pen Sylvania 17403-2000
Telephone: (717) 846-1252
I.D. /87062
Counsel for Plaintiff
IMPNOT/PANOTC W&A FILE NO. 102922902
128
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PLATINUM FINANCIAL SERVICES No. 200404694P
CORP., A MARYLAND CORPORATION,
ASSIGNEE OF UNIFUND CCR PARTNERS
ASSIGNEE OF MBNA AMERICA BANK-
MASTERCARD
P.O. BOX 10247
ROCKVILLE, MD 20849-0247
Plaintiff
VS. CIVIL ACTION - LAW
GLENN E CHANEY
Defendant(s)
AFFIDAVIT OF NON-MILITARY SERVICE
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF YORK
The undersigned counsel, being duly sworn according to law, depose and say
that I am the Attorney for the Plaintiff in the above-captioned matter, and that to
the best of my knowledge, information and belief Defendant,
GLENN E CHANEY , above-named, is over 21 years of age; is last
known to reside at 207 TAUNTON DR
CARLISLE PA 17013-4707
County of CUMBERLAND , Pennsylvania; is not in the military service of
the United States or its Allies, or otherwise within the provisions of the
Servicemembers Civil Relief Act and its Amendments.
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Dina A. Sweitzer, Notary Public
City of York, York County
My Commis:aon Expires Apr. 16, 2008
SWORN and SUBSCRIBED to before me this
Amy Doyl 8 62
Daniel F. W lfson x/20617
Bruce H. Ch rkis #18837
Philip C. Warholic #86341
Ronald M. Abramson x/94266
Ronald S. Canter x/94000
Donald P. Shiffer, III #89451
WOLPOFF & ABRAMSON, L.L.P.
Attorneys in the Practice of Debt Collection
267 East Market St., York, PA 17403
(717) 846-1252
Counsel for Plaintiff
Iro- day of 20 .
Notary Public
PNMAFF/PANOJ W&A FILE NO. 102922902
129
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PLATINUM FINANCIAL SERVICES No. 200404694P
CORP., A MARYLAND CORPORATION,
ASSIGNEE OF UNIFUND CCR PARTNERS
, ASSIGNEE OF MBNA AMERICA BANK-
MASTERCARD
P.O. BOX 10247
ROCKVILLE, MD 20849-0247
Plaintiff
Vs. CIVIL ACTION - LAW
GLENN E CHANEY
Defendant(s)
CERTIFICATE OF RESIDENCE
PA. R.C.P. 236
I, hereby certify that the precise residence of Plaintiff is:
PLATINUM FINANCIAL SERVICES
CORP., A MARYLAND CORPORATION,
ASSIGNEE OF UNIFUND CCR PARTNERS
, ASSIGNEE OF MBNA AMERICA BANK-
MASTERCARD
P.O. BOX 10247
ROCKVILLE, MD 20849-0247
and certify that the last known address of the within Defendant(s) is:
GLENN E CHANEY
207 TAUNTON DR
CARLISLE PA 17013-4707
Amy F:'Doyle 11 #87U62
Daniel F. Wolf on #20617
Bruce H. Cherkis /18837
Philip C. Warholic x/86341
Ronald M. Abramson #94266
Ronald S. Canter #94000
Donald P. Shiffer, I II #89451
WOLPOFF & ABRAMSON, L.L.P.
Attorneys in the Pra ctice of Debt Collection
267 East Market St., York, PA 17403
(717) 846-1252
Counsel for Plaintif f
PCRES/PANOJ W&A FILE NO. 102922902
1J1
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PLATINUM FINANCIAL SERVICES NO. 200404694P
CORP., A MARYLAND CORPORATION,
Plaintiff
VS. CIVIL ACTION - LAW
GLENN E CHANEY
Defendant(s)
NOTICE OF JUDGMENT
( x ) Notice is hereby given that a
in the above-captioned matter has be n entered against you in the amount of
$ 5138.52 , plus interest, on 20_OS
( x ) A copy of all documents filed with the Prothonotary in support of the
within judgment is/are attached.
Prothonotary Civil iv'y' n
By' If you have any questions regarding this Notice, please contact the
filing party.
Amy F. Doyle #87062
Daniel F. Wo fson x/20617
Bruce H. Cherkis #18837
Philip C. Warholic #86341
Ronald M. Abramson x/94266
Ronald S. Canter x/94000
Donald P. Shiffer, III x/89451
WOLPOFF & ABRAMSON, L.L.P.
Attorneys in the Practice of Debt Collection
267 East Market St., York, PA 17403
(717) 846-1252
Counsel for Plaintiff
(This Notice is given in accordance with Pa.R.C.P. 236.)
NOTICE SENT TO:
GLENN E CHANEY
207 TAUNTON DR
CARLISLE PA 17013-4707
STNTC/PANOJ W&A FILE NO. 102922902
7 11
V w
c t\ 4?
a .- _l
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
PLATINUM FINANCIAL SERVICES CORP.,
A MARYLAND CORPORATION
ASSIGNEE OF UNIFUND CCR PARTNERS
ASSIGNEE OF MBNA AMERIA BANK -
MASTERCARD
Plaintiff
VS.
GLENN E. CHANEY
Defendant
NO. 200404694P
CIVIL ACTION - LAW
PRAECIPE TO SETTLE AND SATISFY
Please mark the judgment in the above-entitled cause as paid and satisfied.
Respectfully Submitted,
By:
Amy F.
CI
livid R. Galloway #87326
Sarah E. Ehasz #86469
Robert N. Polas, Jr. #201259
MANN BRACKEN LLP
The Successor by Merger to Wolpoff & Abramson, LLP
and Eskanos & Adler, PC
Attorneys in the Practice of Debt Collection
4660 Trindle Rd., Suite 300
Camp Hill, PA 17011
(866) 253-0128
Cc: GLENN E. CHANEY
207 TAUNTON DR
CARLISLE, PA 17013
MB File No. 102922902
a .'4
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
PLATINUM FINANCIAL SERVICES CORP.,
A MARYLAND CORPORATION
ASSIGNEE OF UNIFUND CCR PARTNERS
ASSIGNEE OF MBNA AMERICA BANK -
MASTERCARD
Plaintiff
VS.
GLENN E. CHANEY
NO. 200404694P
CIVIL ACTION - LAW
Defendant
CERTIFICATE OF SERVICE
The undersigned does hereby certify that a true and correct copy of Certificate Of
Service, was served upon the individual(s) listed below by Regular Mail, Postage
Pre-Paid on this day of , 20
GLENN E. CHANEY
207 TAUNTON DR
CARLISLE, PA 17013
f I
Am o yle #87
r C. Warholic #8 ??
avid R. Galloway #87326
Sarah E. Ehasz #86469
Robert N. Polas, Jr. #201259
MANN BRACKEN LLP
The Successor by Merger to Wolpoff &
Abramson, LLP and Eskanos & Adler, PC
Attorneys in the Practice of Debt Collection
4660 Trindle Rd., Suite 300
Camp Hill, PA 17011
(866) 253-0128
r ICE w '±'? r}?s!r GARY
2009 1ai:Y 19 A i :1a
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