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Home My WebLink About04-4859IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PALISADES COLLECTION, LLC, ASSIGNEE OF PROVIDIAN BANK Plaintiff VS. DENISE A MCCLINTOCK Defendant COMPLAINT IN CIVIL ACTION FILED ON BEEIALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: JAMES C WAILMBRODT, ESQUIRE PA l.D.#42524 WILLIAM T. MOLCZAN, ESQUIRE PA LD.#47437 Weltman, Weinberg & Reis Co., L.P.A. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#03426873 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PALISADES COLLECTION, LLC, ASSIGNEE OF PROVID1AN BANK Plaintiff VS. DENISE A MCCLINTOCK Defendant Civil Action No. COMPLAINT IN CIVIl, ACTION AND NOTICE TO DEFEND You have been sued in court. If you wish to defend againsl 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 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 TI) ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STRFET CARLISLE, PA 17013 (717) 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 5254 Terrace Road Mechanicsburg, PA 17050. 3. Defendant applied for and received a credit card issued by Plaintiffs assignor bearing the account number 5542850300497346. 4. Defendant made use of said credit card and has currently a balance due and owing to Plaintiff, as of September 3,2004, in the amount of $ 4,490.66. 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, DENISE A MCCLINTOCK individually, in the amount of $ 4,490.66 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, WE1NBERG & REIS, CO., L.P.A. ~MBRODT, ESQU IOLCZAN, ESQUIRE fO( I.D.#47437 /~eltman, Weinberg & Reis Co., L.P.A. ///2718 Koppers Bldg. ///4,4,.3.6 ,Seve,nth~ ,A, enue Pittsburgh, PA 15219 (412) 434-7955 WWR#:03426873 )ENISE A MCCLINTOCK 5254 TERRACE RD MECHANICSBURG, PA 17050 ADDRESS__ PALISADES FILE NUMBER 8945765 NEW BALANCE $4,490.66 PAYMENT ClUE DATE 7/10/2.004 MINIMUM pAYMENT $4,49O,66 PLEASE WRITE IN A~OUNT OF PAYMENT ENCLOSED $ ACCOUNT NUMBER 5542850300497346 DATE REFERENCE NUMBER 7/10/2004 PLEASE DETACH AND TOP PORTION WITH YOUR PAYMENT CREDIT LIMIT CREOIT AVAIABLE 0 0 NEW TRANSACTIONS 3ALANCE DUE 7/10/2004 =ALISADES COLLECTION, L.L.C. )ELAWARE LIMITED LIABILITY CORP- ASSIGNEE OF PROVtDIAN BANK >.0. BOX 1244 ENGLEWOOD CLIFFS, NJ 07632 STATEMENT CLOSING DATS 7/10/2004 AMOUNT $4,4g0.66 SUMMARY OF TRANSACTIONS PREVIOUS BALANCE PAYMENTS AND CREDITS $4,490.66 NEW BALANCE $4,490.66 MINIMUM PAYMENT $4,490.66 PAYMENT DUE DATE 7/10/2004 SEND INQUIRIES TO: PALISADES COLLECTION, LLC. P.O. ~OX 1244 ENGLEWOOD CLIFFS, NJ 07632 WWR - File # 3426873 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 Wentworth Browne O'~AME) Legal Operations Manager of Palisades Collection, LLC _, plaintiff herein, that (TITLE) (COMPPdqY) 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. Wentworth Brow~e~~ WWR# SHERIFF'S RETURN - REGULAR CASE NO: 2004-04859 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PALISADES COLLECTION LLC VS MCCLINTOCK DENISE A RICHARD SMITH , Cumberland County, Pennsylvania, says, the within COMPLAINT & NOTICE MCCLINTOCK DENISE A DEFENDANT , at 1930:00 HOURS, at 5254 TERRACE ROAD ~ECHANICSBURG, PA 17050 DENISE MCCLINTOCK a true and attested copy of Sheriff or Deputy Sheriff of who being duly sworn according to law, was served upon the on the 28th day of September, __ by handing to together with COMPLAINT & NOTICE 2004 and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18,00 Service 8.88 Affidavit Surcharge 10.00 .00 36.88 Sworn and Subscribed to before me this ~ day of ~ ~O~ A.D. ~rdthonot ary ~ So Answers: R. Thomas Kline 09/29/2004 /~ WELTMAN WE INBE~E I/ By: ~~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PALISADES COLLECTION, LLC., ASSIGNEE OF PROVIDIAN BANK Plaintiff VS. DENISE A. MCCLINTOCK Defendant No. 04-4859 CIVIL PRAECIPE FOR DEFAULT JUDGMENT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: 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#03426873 Judgment Amount $ 4,490.66 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. DENISE A. MCCLINTOCK Defendant Civil Action No. 04-4859 CIVIL PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter Judgment against the Defendant, Denise A. McClintock, above named, in the default of an Answer, in the amount of $4,490.66 computed as follows: Amount claimed in Complaint $4,490.66 Interest from date of judgment at the legal interest rate of 6.0% per annum TOTAL $4,490.66 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. PA I.D. #-47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#03426873 Plaintiff's address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7th Avenue, Pittsburgh, PA 15219 And that the last known address of the Defendant is: 5254 Terrace Road, Mechanisburg, PA 17050 IN THE COURT Of COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PALISADES COLLECTION, LLC, ASSIGNEE OF PROVIDIAN BANK Plaintiff VS. DENISE A MCCLINTOCK Defendant Civil Action No. 04-4859 CIVIL IMPORTANT NOTICE TO: Denise A Mcclintock 5254 Terrace Road Mechanicsburg, PA 17050 Date of Notice:/~ YOU ARE IN DEFAULT BECAUSE YOU PERSONALLY OR BY ATTORNEY AND FILE IN HAVE FAILED TO ENTER A WRITTEN APPEARANCE 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. William T. Molczan PA I.D. 1/47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR #03426873 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 & REIS CO., L.P.A. William T. Molczan,,~quire PA I.D. ¢f47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#03426873