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Home My WebLink About04-4726 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PALISADES COLLECTION, LLC, ASSIGNEE OF PROVIDIAN BANK Plaintiff No. C1.J - '{'''1J.Ic Ci(.)L ~84..~ vs. COMPLAINT IN CIVIL ACTION LORIE.NEGLEY-ORR Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt, Esquire PA J.D. #42524 WELTMAN, WEINBERG & RBIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 vvvrR#03406250/03411756 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CNIL DIVISION PALISADES COLLECTION, LLC, ASSIGNEE OF PROVIDIAN BANK Plaintiff vs. Civil Action No. LORI E. NEGLEY -ORR 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 obj ections 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 MAYBE 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 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 COUNT I - 4031151000638433 1. Plaintiff is a corporation with offices at P.O. Box 1244, Englewood Cliffs, NJ 07632. 2. Defendant is an adult individual residing at 408 South West Street, Carlisle, PA 17013. 3. Defendant applied for and received a credit card issued by Plaintiff's assignor bearing the account number 4031 151000638433. 4. Defendant made use of said credit card and has currently a balance due and owing to Plaintiff, as of September 6, 2004, in the amount of$1,821.02. 5. Defendant is in default of the terms of the cardholder Agreement having not made monthly payments to Plaintiffthereby rendering the entire balance immediately due and payable. 6. Plaintiff avers that the Cardholder Agreement between the parties provides that Plaintiff is entitled to the addition of finance charges at the rate of 6% per annum on the unpaid balance. 7. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed and/or refused to pay the principal balance, finance charges or any part thereof to Plaintiff. WHEREFORE, Plaintiff demands Judgment in its favor and against Defendant, Lori E. Negley- Orr individually, in the an10unt of$I,821.02 with continuing finance charges thereon at the rate of6% per annum from September 6, 2004 plus costs. COUNT II - 5409792600810863 1. Plaintiffis a corporation with offices at P.O. Box 1244, Englewood Cliffs, NJ 07632. 2. Defendant is an adult individual residing at 711 James Street, F12, Pittsburgh, P A 15212. 3. Defendant applied for and received a credit card issued by Plaintiff's assignor bearing the account number 5409792600810863. 4. Defendant made use of said credit card and has currently a balance due and owing to Plaintiff, as of September 6, 2004, in the amount of$I,585.46. 5. Defendant is in default of the terms of the cardholder Agreement having not made monthly payments to Plaintiff thereby rendering the entire balance immediately due and payable. 6. Plaintiff avers that the Cardholder Agreement between the parties provides that Plaintiff is entitled to the addition of finance charges at the rate of 6% per annum on the unpaid balance. 7. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed and/or refused to pay the principal balance, finance charges or any part thereof to Plaintiff. WHEREFORE, Plaintiff demands Judgment in its favor and against Defendant, Lori E. Negley- Orr individually, in the amount of$I,585.46 with continuing finance charges thereon at the rate of6% per annum from September 6, 2004 plus costs. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED SHALL BE USED FOR THAT PURPOSE. WELTMAN, WEINBERG & RBIS, CO., L.P.A. ..--<7 ,/ ;;? James C. armbrodt, Esquire P A J.D. 2524 WELT c.\N, WEINBERG & RBIS CO., L.P.A. 2718 ppers Building 436 venth Avenue Pi urgh, PA 15219 ( 2) 434-7955 WWR#:03406250/03411756 VERIFICATION The undersigned does hereby verify subject to the penalties of 18 P A. C.S. 4904 relating to unsworn falsifications to authorities, that he/she is Wentworth Browne (NAME) Le€(al Operations Manager (TITLE) Palisades Collection. LLC (COMPANY) of , plaintiff herein, that 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. ~~~~ WWR# ~ 0 ~ 1Q ~ a.o ~ tn - 0 t~.) a-- ' ' N >u ~ 8 Cfl VI ~ ..c:: r"i - co ~ / ~. SHERIFF'S RETURN - REGULAR CASE NO: 2004-04726 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PALISADES COLLECTION LLC VS ORR LORI E NEGLEY CPL. KATHY CLARKE , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon ORR LORI E NEGLEY the DEFENDANT at 1315:00 HOURS, on the 27th day of September, 2004 at CUMBERLAND CO SHERIFF'S OFFICE ONE COURTHOUSE SQUARE CARLISLE, PA 17013 by handing to LORI E NEGLEY ORR 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 .00 .00 10.00 .00 28.00 .r'~?/~ R. Thomas Kline 09/28/2004 WELTMAN WEINBERG REIS Sworn and Subscribed to before By: C'~/~J/~~ me this ~ day of ~ o2OzJ'l A.D. (1 -tJ Inu),.._ # -~honotary I . I · IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PALISADES COLLECTION, LLC., ASSIGNEE OF PROVIDIAN BANK Plaintiff No. 04-4726 CIVIL vs. PRAECIPE FOR DEFAULT JUDGMENT LORI E NEGLEY -ORR Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan, Esquire PA 1.0. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#03406250 Judgment Amount $ 1,821.02 I 'I ~ THIS LAW FIRM IS ATTEMPTING TO COLLECT THIS DEBT FOR ITS CLIENT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. ,. " U 1 -t 1'" IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PALISADES COLLECTION, LLC., ASSIGNEE OF PROVIDIAN BANK Plaintiff vs. Civil Action No. 04-4726 CIVIL LORI E NEGLEY -ORR Defendant PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter Judgment against the Defendant, Lori E Negley -Orr, above named, in the default of an Answer, in the amount of $1,821.02 computed as follows: Amount claimed in Complaint $1,821.02 Interest from date of judgment at the legal interest rate of 6.0% per annum TOTAL $1,821.02 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. ~;liamV(i1.~~ PA I.D, #47437 ~r/re WELTMAN, WEINBERG & REIS CO., L.PA 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#03406250 Plaintiff's address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 J'h Avenue, Pittsburgh, PA 15219 And that the last known address of the Defendant is: 408 South West Street Carlisle, PA 17013 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PALISADES COLLECTION, LLC, ASSIGNEE OF PROVIDIAN BANK Plaintiff vs. Civil Action No. 44726 CIVIL LORI E NEGLEY-ORR Defendant IMPORTANT NOTICE TO: Lori E. Negley-Orr 408 South West Street Carlisle, PA 17013 Date of Notice: oc/->> olCOY / YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN 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. 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. ~:lia!:(15/r PA 1.0. #47437 WELTMAN, WEINBERG & REIS CO., L.PA 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR #03406250 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 & REfS CO., L.PA ::liaJ!/J:.~,{r PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.PA 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#03406250 c?d ~ !i- f' r &; j ~ (U (f"- - -.0 ~ r---- ~ ~ 8 ~rP ~ r- f'. ~!2 ~ ,.- \ ,....~') :~: (-..} 'n ,.--: ::.-] , .... _.~ ' I ~ ' ~', "', _.~., " ",' f : " , " -.-. ~ . -~. ", ,"".) \.:) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PALISADES COLLECTIONS, LLC, Plaintiff YS. Civil Action No. 04-4726-CIVIL LORI E. NEGLEY.ORR Defendant NOTICE OF JUDGMENT OR ORDER TO: () Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the following Order or Judgment was entered against you onjJ~ (xx) Assumpsit Judgment in the amount of$1585.46 plus costs. () Trespass Judgment in the amount of$_ plus costs. () Ifnot satisfied within sixty (60) days, your motor vehicle operatorls license and/or registration will be suspended by the Department of Transportation, Bureau of Traffic Safety, Harrisburg. PA. (xx) Entry of Judgment of () Court Order () Non.Pros () Confession (xx) Default () Verdict () Arbitration Award ::"'~~A~,~ ~ PROTHONOTARY ( ru LORI E NEGLEY-ORR 408 SOUTH WEST STREET CARLISLE,P A 17013 Plaintiffs address is: cia Weltman, Weinberg & Reis Co., L.P.A., 27\8 Koppers Building, 436 7'" Avenue, Pittsburgh, PA 15219 1-888-434-0085 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PALISADES COLLECTIONS, LLC, Plaintiff No. 04-4726.CIVIL YS. PRAECIPE FOR DEFAULT JUDGMENT AS TO COUNT II ONLY LORI E. NEGLEY-ORR Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: WILLIAM T. MOLCZAN, ESQUIRE PA 1.D.#47437 Weltman, Weinberg & Reis Co., L.P.A. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, P A 15219 (412) 434-7955 WWR#03424056 Judgment Amount $ 1585.46 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 COLLECTlONS. LLC, Plaintitf vs. Civil Action No. 04-4726.CIVIL LORI E. NEGLEY.ORR Defendant PRAECIPE FOR DEFAULT JUDGMENT. AS TO COUNT II ONLY TO THE PROTHONOTARY: Kindly enter Judgment against the Defendant, LORI E. NEGLEY.ORR above named, in the default of an Answer, in the amount of$1585.46 computed as follows: Amount claimed in Complaint $1585.46 Interest from date of judgment at the legal interest rate of 6% per annum TOTAL $1585.46 I hereby certify that appropriate Notices of Default, as attached have been mailed in accordance with P A R.C.P. 237. I on the dates indicated on the Notices. WELTMAN, WEINBERG & REIS CO., L.P.A. By: WILLIAM T. MOLC PA J.D.#47437 Weltman, Weinberg & Reis Co., L.P.A. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, P A 15219 (412) 434-7955 WWR#03424056 Plaintiffs address is: cia Weltman, Weinberg & Reis Co" L.P,A., 2718 Koppers Building, 436 7'" Avenue, Pittsburgh, PA 15219 And that the last known address of the Defendant is: 408 SOUTH WEST STREET CARLlSLE,PA 17013 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PALISADES COLLECTION, LLC, ASSIGNEE OF PROVIDIAN BANK Plaintiff vs. Civil Action No. 44726 CIVIL LORI E NEGLEY.ORR Defendant IMPORT ANT NOTICE TO: Lori E. Negley-Orr 408 South West Street Carlisle, PA 17013 Date of Notice: Ocr;Jc), ;ZCOY YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN 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. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 WELTMAN, WEINBERG & REIS CO., LP.A. ~oo1(i!:!5' ~ PA 1.0. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR #03406250 IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL DIVISION PALISADES COLLECTIONS, LLC, Case no: 04.4726.CIVIL Plaintiff NON-MILITARY AFFIDAVIT vs. LORI E. NEGLEY.ORR Defendant The undersigned, who first being duly sworn, according to law, deposes and states as follows: That he/she is the duly authorized agent of the Plaintiff in the within matter. Affiant further states that the within Affidavit is made pursuant to and in accordance with the Servicemembers' Civil Relief Act (SCRA), 50 U.S.C. App. 9521. Affiant further states that based upon investigation it is the affiant's belief that the Defendant, LORI E. NEGLEY.ORR is not in the military service. Affiant further states that this belief is supported by the attached certificate from the Defense Manpower Data Center (DMDC). which states that the Defendant, LORI E. NEGLEY.ORR is not in the military service. Further Affiant sayeth naught. M;j./~ AFFIANT ' / AND BSC~my presence thid day N ',:{.... , ""~'l;- !.;Jt',Jii!;''I This law firm is a debt collector attempting to collect this debt for our client and any information obtained will be used for that purpose. Request for Military Status Page I of 1 Department of Defense Manpower Data Center mL-30-2005 08:51: I 0 Military Status Report Pursuant to the Service Members' Civil Relief Act -<. Last Name First/Middle Begin Date I Active Duty Status I Service/Agency NEGLEY -ORR Based on the information you have furnished, the DMDC does not possess any information indicating that the individual is currently on active duty. Upon searching the information data banks of the Department of Defense Manpower Data Center, the above is the current status of the individual, per the Information provided, as to all branches of the Military. -----r....:4 ...-- .? ' F-oWJ \:~6-~ Robert J. Brandewie, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The Department of Defense strongly supports the enforcement of the Service Members Civil Relief Act [50 USCS Appx. SS 501 et seq] (SCRA) (formerly the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are most strongly encouraged to contact us by Fax at (703-696-4156) or by phone at (703-696-6762). We will then conduct further research. Your failure to re-contact DMDC may cause provisions of the SCRA to be invoked against you. This response reflects current active duty status only. For historical information, please contact the military services SCRA point of contact. See: httJ2;!/www.deJ~I1s~ink..ill illfaqlJlj~P'C_Q_9SLDR.]1tl1)1. ReportID:PIPGCSXNTX https://www.dmdc.osd.millscra/owa/scra.pre_Select 7/30/2005 -lq. ~ ):::) () -.() 1t 1- \) C> ~ - ~ ~ ~ ~ g c-.:> ~ - ~ s! ~ \) '?,: ~ ~ ""'C',) ('1,E! }J ll- n.\(','; G'> -om - !2 -,;>-:J: :lJ '% -J ..............; I l t;, I/p a \j;) ~L ~ C> :',-.11 ~ -t- ?;\,-', ~ '-2\':") <:: ...:-rn ----L. y ..-'~ z(') oJ) 9. 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