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Home My WebLink About04-4874IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DiViSiON PALISADES COLLECTION, LLC, ASSIGNEE OF PROVIDIAN BANK Plaintiff VS. JAMES P. TAYLOR, Defendant COMPLAINT IN CIVIL ACTION FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt, Esquire PA I.D. #42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-79555 WWR#03407725 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PALISADES COLLECTION, LLC, ASSIGNEE OF PROVIDIAN BANK Plaintiff VS. .lAMES P. TAYLOR, Defendant Civil ActionNo. O~ ¥'FvY ~ ~e..~ 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 t'or 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. lF 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 Plaintiffis a corporation with offices at P.O. Box 1244, Englewood Cliffs, NJ 07632. 17070. Defendant is an adult individual residing at 341 9TH ST, NEW CUMBERLAND, PA 3. Defendant applied for and received a credit card issued by Plaintiffs assignor bearing the account number 4465680500895288. 4. Defendant made use of said credit card and has currently a balance due and owing to Plaintiff, as of September 10, 2004, in the amount of $4,628.99. 5. Defendant is in default of the temps 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, JAMES P. TAYLOR, individually, in the amount of $4,628.99 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. WELTM~M~BERG & REIS, CO., L.P.A. James C. Wan,nbrodt, Esquire PA I.D. #42524 WELTMAN, WEINBERG & RE1S CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsbur~:3t, PA 15219 (412) 434-79555 WWR#:03407725 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) plaintiff herein, 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 knowledge, information and belief. WWR# SHERIFF'S CASE NO: 2004-04874 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PALISADES COLLECTION LLC VS TAYLOR JAMES P RETURN - REGULAR SHANNON SUNDAY , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon TAYLOR JAMES P the DEFENDANT , at 0848:00 HOURS, on the 30th day of September, 2004 at CUMBERLAND CO SHERIFF'S OFFICE ONE COURTHOUSE SQUARE CARLISLE, PA 17013 by handing to JAMES TAYLOR 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 13.32 Affidavit .00 Surcharge 10.00 .00 41.32 Sworn and Subscribed to before me this ~ day of ~ '~/~9' A.D. ,pz~ot honot ary , So Answers: R. Thomas Kline 09/30/2004 WELTMAN WEINBERG REIS 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CWIL DIVISION PALISADES COLLECTION, LLC., ASSIGNEE OF PROVIDIAN BANK, Plaintiff VS. JAMES P. TAYLOR, Defendant No. 044874 CIVIL PRAECIPE TO SETTLE, DISCONTINUE & END FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt PA I.D ~42524 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#03407725 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DWISION PALISADES COLLECTION, LLC., ASSIGNEE OF PROVDIAN BANK, Plaintiff VS. JAMES P. TAYLOR, Defendant Civil Action No. 04-4874 CIVIL PRAECIPE TO SETTLE DISCONTINUE, AND END TO THE PROTHONOTARY OF COUNTY: Please kindly Settle Discontinue and End the above captioned matter upon the records of the Court and mark the cost paid. WELTMAN, WEINBERG 8,: REIS CO., L.P.A. James/C]. Warmbrodt PA~.D2042524 Wflllia/h T. Molczan, Esquire /W~'LTMAN, WEINBERG & REIS CO., L.P.A. 2/7'18 Koppers Building [/436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#03407725