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Home My WebLink About04-4870 , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PALISADES COLLECTION, LLC, ASSIGNEE OF PROVIDIAN BANK Plaintiff No. o <-?- It't 70 ~ vs. COMPLAINT IN CIVIL ACTION KEITH CHESTNUT Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: .lames C. Warmbrodt, Esquire P A J.D. #42524 WELTMAN, WEINBERG & RElS CO.. L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#034I 1451 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PALISADES COLLECTION, LLC, ASSIGNEE OF PROVIDIAN BANK Plaintiff vs. Civil Action No. 0'/- If f '10 {1;J -r ~ KEITH CHESTNUT 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 objections to the claims set forth against you. You are warned that if you fail to do so the case may procced without you and ajudgrnent 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 HA VE 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. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 COMPLAINT I. Plaintiff is a corporation with offices at P.O. Box 1244, Englewood Cliffs, NJ 07632. 2. Defendant is an adult individual residing at 121 E. South Street, Carlisle, PA 17013. 3. Defendant applied for and received a credit card issued by Plaintiff's assignor bearing the account number 5409790700542899. 4. Defendant made use of said credit card and has currently a balance due and owing to Plaintiff, as of September 7,2004, in the amount of$I,684.12. 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, Keith Chestnut individually, in the amount of $1,684.12 with continuing finance charges thereon at the rate of 6% per annum from September 7, 2004 plus costs. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED SHALL BE USED FOR THAT PURPOSE. WELTMAN, WEINBER:G & REIS, CO., L.P.A. ", ~/f() //0111/1 r r~-- Jarriel ~~ Warm brodt, Esquire PA LD, #42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh A venue Pittsburgh,PA 15219 (412) 434-7955 WWR#:0341 1451 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) Legal Operations Manager (TITLE) of 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 true and correct to the best ofhis/her knowledge, information and belief. WWR# ,~ }; '"'- U' 1 <>,;;, - ( C>('"' '-.. ~ U'-' -f\ '--" r ~ \ l/ ~ v ?- ~~ II ~, cf o r) l.Ji ~ J, c' r;0':l '.' r-.) -~) (:' .,- r.,} , " SHERIFF'S RETURN - REGULAR CASE NO: 2004-04870 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PALISADES COLLECTION LLC VS CHESTNUT KEITH JODY SMITH Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon CHESTNUT KEITH the DEFENDANT , at 1520:00 HOURS, on the 1st day of October 2004 at CUMBERLAND CO SHERIFF'S OFFICE ONE COURTHOUSE SQUARE CARLISLE, PA 17013 by handing to KEITH CHESTNUT 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 Service Affidavit Surcharge So Answers: 18.00 .00 .00 10,00 .00 28,00 ~~~ R. Thomas Kline 10/04/2004 WELTMAN WEINBERG REIS Sworn and Subscribed to before ~t~s S+t . dayof LU e}~. """; r ~(J fA. D, ~ J,J. ty,,' , 'Pro'''''n 'ary~ ....~ >tl..~ f U --~IJU By: ".h-h .S~ D~p~(f Sheriff ..~~ ..... IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PALISADES COLLECTION, LLC, ASSIGNEE OF PROVIDIAN BANK Plaintiff No,04-4870 CIVIL VS, STIPULATION OF THE PARTIES FOR PAYMENT AND FOR THE ENTRY OF JUDGMENT BY CONSENT KEITH CHESTNUT Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Mo1czan, Esquire PA J.D. #47437 WELTMAN, WEINBERG & RBIS CO" L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#03411451 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. Civil Action No. 04-4870 CIVIL KEITH CHESTNUT Defendant STIPULATION OF THE PARTIES FOR PAYMENT AND FOR THE ENTRY OF JUDGMENT BY CONSENT TO THE PROTHONOTARY: Kindly enter Judgment in favor of Plaintiff and against the Defendant, Keith Chestnut, above-named, in the amount of $1,684,12 pursuant to the Stipulation of the Parties for Payment and for the Entry of Judgment by Consent, as follows: 1. Defendant admits indebtedness to Plaintiff in the amount of $1,684.12 with continuing interest thereon at a rate of 6.00% per annum plus costs from the date of judgment. 2. To secure the repayment of said indebtedness. Defendant agrees that Judgment by Consent will be entered in favor of the Plaintiff and against the Defendant, Keith Chestnut, in the amount of $1,684.12 plus continuing interest thereon at the rate of 6.00% per annum from the date of judgment and costs. 3. Plaintiff agrees not to Execute on its Judgment so long as Defendant causes to be delivered to Plaintiff the following payments in full by 12:00 NOON on the following dates: (a) $100,00 due immediately; (b) no less than $100.00 per month due on the 7th day of each consecutive month thereafter until the Judgment amount plus accrued interest and costs are paid in full. 4. All payments are to be made payable to the order of "Palisades Collection" 5. All payments due under this agreement are to be received at the offices of Weltman, Weinberg & Reis, Co" L,P.A., 2718 Koppers Building, 436 Seventh Avenue, Pittsburgh, PA 15219. 6, In the event of default, each payment received shall be first attributed to costs, interest and then to principal. 7. Time is of the essence of this agreement and should the Defendant fail to have in the hands of Plaintiff or Plaintiff's counsel any payment in full within five (5) calendar days of the stated due date, then Plaintiff shall be immediately free to issue Execution as well as pursue all other remedies, in law or in equity, to collect the full balance of the Judgment entered hereunder plus appropriate additional interest and costs. 8, No act or omission of the Plaintiff, nor of anyone alleged to be acting on its behalf, shall constitute a waiver, estoppel, or any other excuse for non-performance of any duty undertaken by the Defendant in this Stipulation which the parties agree is final and complete. 9. Intending to be legally bound, the parties set their hands and seals this /8 day of ocf;, 20 oLf THIS LAW FIRM IS ATTEMPTING TO COLLECT THIS DEBT FOR ITS CLIENT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. WELTMAN, WEINBERG & REIS CO., L,P,A. By: W~~ William T, MOIC!.a;, Es ire PA \.0. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A, 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#03411451 Keith Chestnut By: ~~~_dLJ-~ Defendant t . . . ~ ~ t 7"J t ...0 ft. . D ,...." () 0 (:.:;) 0 \:) ~~~; (~c::> -n F ..s:..- .-{ "- <". :;c - , ; ',- . , c-; -'- -'-'1 ~ ~ -u r, I rnr". ....:: TJrn , I :':''1) ~ J.J D p: 1...0 () -) t/) C/) ::~~il :7.>- ~. ) ('-') "-.J rr- 1- :..:k: :::;rn P? C3 :~:i / .. . ~:;... :.j 1'.) ~~2 -(, CO . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PALISADES COLLECTION, LLC, ASSIGNEE OF PROVIDIAN BANK Plaintiff No. 04-4870-CIVIL vs. PRAECIPE FOR SATISFACTION OF JUDGMENT KEITH CHESTNUT Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt PA /.D #42524 WELTMAN, WEINBERG & REIS CO, L.PA 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WVVR#03411451 . IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PALISADES COLLECTION, LLC, ASSIGNEE OF PROVIDIAN BANK Plaintiff vs. Civil Action No. 04-4870-CIVIL KEITH CHESTNUT Defendant PRAECIPE FOR SATISFACTION OF JUDGMENT At the request of the undersigned attorneys for the Plaintiff, you are directed to satisfy the above-captioned Judgment. WELTMAN, WEINBERG & REIS CO, L.P.A. By: James C/ armbrodt PA 1.0 if42 24 WEL TMA , WEINBERG & REIS CO., L.PA 2718Ko ers Building 436 Se nth Avenue Pitts gh, PA 15219 (412 ~34-7955 WWR#03411451 IEALTH OF PENNSYJ.,VANIA 1---- Nota"al Seal I Heidi J. Kelly, Notal)' Public ) City Of pittsburgh, Allegheny County L~y Commission Expires Nov. 4, 2009 . Member. Penn'sylvania Association of Notaries r"-,; c:;;> ,:::-.> c,.... o -T1 ..-l ::C-n n'p'-;; -('1 rr~ .;::.,~~~::i -r'" ..~ ';t:l>-4 :';-'0 N :s:: ~ ,.":~?=s ;:jfTl ~\ ," ).J -< r0