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Home My WebLink About12-1713IN THE COURT OF COMMON PLEAS OF ' CUMBERLAND COUNTY, PENNSYLVANIA 22 i 2 MARk 19 AM 10: 35 FIA CARD SERVICES, N.A. OUMBERLANB COUNTY 655 PAPERMILL ROAD CIVIL ACTION € ENNSYLVA,NIA NEWARK, DE 19711 Plaintiff VS. NO: a0l ?- ?7/,3 di? EDWARD W PAWLUK JR 300 HOGESTOWN RD MECHANICSBURG PA 17050-3120 Defendant : 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 to Defend 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 AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT REDUCED FEE OR NO FEE. MIDPENN LEGAL SERVICES 401 EAST LOUTHER STREET CARLISLE, PA 17013 717-243-9400 495 OJK+41D9.7Spd At- 0k# a S3a's 124a-7 asap 1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FIA CARD SERVICES, N.A. 655 PAPERMILL ROAD CIVIL ACTION NEWARK, DE 19711 Plaintiff VS. NO: EDWARD W PAWLUK JR 300 HOGESTOWN RD : MECHANICSBURG PA 17050-3120 Defendant COMPLAINT Plaintiff, FIA CARD SERVICES, N.A. , by and through its attorneys, Edwin A. Abrahamsen & Associates, P.C., complains of the Defendant as follows: 1. Plaintiff, FIA CARD SERVICES, N.A. , (hereinafter "Plaintiff") is a corporation with a principal place of business located at 655 PAPERMILL ROADNEWARK, DE 19711 2. The Defendant EDWARD W PAWLUK JR (hereinafter "Defendant") is an adult individual residing at 300 HOGESTOWN RD MECHANICSBURG PA 17050-3120. 3. At all relevant times herein, Plaintiff was engaged in the business of debt purchase and collection. 4. Defendant applied for and received a credit card issued by FIA CARD SERVICES, N.A. with the account number ending in 9894. 5. Use of the FIA CARD SERVICES, N.A. credit card was subject to the terms and considerations of the Cardmember Agreement (hereinafter "Agreement"), a copy of which was sent to the Defendant along with the credit card. A copy of this document has been requested from FIA Card Services, N.A. and will be provided upon receipt. 6. Defendant used the FIA CARD SERVICES, N.A. credit card account number ending in 9894, for purchases, cash advances and/or balance transfers. 7. The Defendant was mailed account statements relative to the Defendant's use of the subject credit card. The Defendant defaulted under the terms of the Agreement by failing and refusing to make monthly payments on the account as they became due. 9. The Defendant last made payment on October 19, 2010. 10. The total amount due and owing the Plaintiff including interest, is $12,212.67. WHEREFORE, Plaintiff requests judgment in its favor and against Defendant in the amount of $12,212.67 plus costs of suit and any other relief as the Court deems just and appropriate. submitted, Edwin M Ab`rahamsen & Michael F. Ratchford, Es Attorney I.D. Nos.: 8628`. 120 North Keyser Ave. Scranton, PA 18504 I mratchford@eaa-law. con Phone: 570-558-5510 Fax: 570-558-5511 VERIFICATION I, Michael F. Ratchford, attorney for Plaintiff, FIA CARD SERVICES, N.A. , am fully familiar with the facts set forth in the within Complaint and am authorized to make this Verification on behalf of Plaintiff. I Verify that the facts set forth in the within allegations are true and correct to the best of my knowledge, knowing that any false statements are punishable by law pursuant to 18 C.S.A. 4904. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff 4„titt, Jody S Smith Chief Deputy 3 i APR -5 PH ir: r s Richard W Stewart Solicitor OF MSEfgi. ?f, fNil) N' S Y UVHN,'l f? FIA Card Services, N.A. vs. Case Number Edward Walter Pawluk 2012-1713 SHERIFF'S RETURN OF SERVICE 04/04/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Edward Walter Pawluk, but was unable to locate him in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant Edward Walter Pawluk. Request for service at 300 Hogestown Road, Mechanicsburg, Pennsylvania 17050 the Defendant was not found. Current resident advised Deputies Edward Walter Pawluk moved 6 months ago. The Mechanicsburg Postmaster has confirmed, Edward Walter Pawluk has moved and left no forwarding address. SHERIFF COST: $43.00 April 04, 2012 SO ANSWERS, ,IM RbNWY- R ANDERSON, SHERIFF FIA CARD SERVICES, N.A. 655 PAPERMIL,L ROAD NEWARK, DE 19711 Plaintiff vs. EDWARD W PAWLUK JR 401 SIMPSON ST APT A MECHANICSBURG PA 17055 In the Court of Common Pleas of F Cumberland County, Pennsylvania Civil Division cr3 t .. c ? =< L, NO: 2012-1713 CIVIL " ? r. ? te 7n ?r Praecipe to Reinstate Civil Complaint Defendant To the Prothonotary of Cumberland County Pennsylvania: Please enter the above Praecipe to Reinstate the Civil Complaint. Thank you, r-awin A. Aoranam Lawyer ID # 86285 rsquire & Associates, P.C. Q???} 0k) -?+ ?ig o" SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff` Jody S Smith Chief Deputy Richard W Stwmrt Solicitor ?Q?,?,t? of man+brt{??? OFFICE OF Tr E s?-EIRlr;= FtLEG'-O FIc- t-' THE PROTHONGTtiP` 'j12 MAY 22 AM 9: c8 CUMBERLAND COUNTY PENNSYLVANIA FIA Card Services, N.A. Vkta Bank of America vs. Edward Waiter Pawiuk Case Number 2012-1713 SHERIFF'S RETURN OF SERVICE 05/18/2012 Ronny R. Anderson, Sheriff, who being duly swom according to law, states that he made a diligent search and inquiry for the within named defendant to wk: Edward Waiter Pawluk, but was unable to locate him in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant Edward Waiter Pawluk. Request for service at 401 W. Simpson Street, Apartment A, Mechanicsburg, Pennsylvania 17055 the Defendant was not found. The Mechanicsburg Postmaster has confirmed, Edward Waiter Pawluk has moved and left no forwarding address. SHERIFF COST: $43.00 May 18, 2012 SO ANSWERS, RON ` R ANDERSON, SHERIFF (c) CountySuite Sheriff, Teleoseft, Inc. FIA CARD SERVICES, N.A. In the Court of Common Pleas of 655 PAPERMILL ROAD Cumberland County, Pennsylvania NEWARK, DE 19711 Civil Division Plaintiff M c vs. NO: 2012-1713 CIVIL ,.? 77 : •". fit. c?a EDWARD W PAWLUK JR 105 Quarry Dr. Praecipe to Reinstate Civil Complaint Bloomsburg PA 17815-8406 = Defendant To the Prothonotary of Cumberland County Pennsylvania: Please enter the above Praecipe to Reinstate the Civil Complaint. Thank you, Ratchford, Edwin A. Abraham Lawyer ID # 86285 P.C. O 11.75 A4 A aftx"oo SHERIFF'S OFFICE OF CUMBERLAND COUNT'S Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor " '. -3 AM 8: 24 t IV, I., INAS''? VA11iIP% FIA Card Services, N.A. f/k/a Bank of America vs. Case Number Edward Walter Pawluk 2012-1713 SHERIFF'S RETURN OF SERVICE 06/12/2012 Ronny R. Anderson, Sheriff who being duly sworn according to law states that he made a diligent search and inquiry for the within named defendant, to wit: Edward Walter Pawluk, but was unable to locate him in his bailiwick. He therefore deputized the Sheriff of Columbia County Pennsylvania to serve 'he within Complaint and Notice according to law. 06/26/2012 04:10 PM - Columbia County Return: And now June 18, 2012 at 1610 hours I, Timothy "f. Chamberlain, Sheriff of Columbia County, Pennsylvania, do hereby certify and return that I served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Edward Walter Pawluk by making known unto himself personally, at The Columbia County Sheriffs Office, P.O. BOX 380, Bloomsburg, Pennsylvania 17815 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $37 00 June 29, 2012 SO ANSWERS, RON Y R ANDERSON. SHERIFF SHERIFF'S OFFICE OF COLUMBIA COUNTY Timothy T. Chamberlain Earl D. Mordan, Jr. Sheriff y.„ Chief Deputy FIA CARD SERVICES NA vs. Case Number EDWARD WALTER PAWLUK 2012-1713 SHERIFF'S RETURN OF SERVICE: 06/26/2012 04:10 PM - SERVED THE REQUESTED NOTICE TO DEFEND BY "PERSONALLY" HANDING A TRUE COPY TO A PERSON REPRESENTING THEMSELVES TO BE THE DEFENDANT, TO WIT EDWARD WALTER PAWLUK AT THE COLUMBIA COUNTY SHERIFF'S OFFICE, P?/BOX 380 BLOOMSBURG, PA 17815. / Y PRICE, DEPUTY f , SO ANSWERS, June 27, 2012 TIMOTHY T. CHAMBERLAIN, SHERIFF Affirmed and subscribed to before me this 27TH day of JUNE Notarial Sea? SAR/?H JANE KLiNC;i?kl) ^,i Notary F u"?h - Town, ,f Bloomsburg. C:oiuMbi?- :.,ounty PA NOTARY My Cornrni sicm E=xpires 5ertci,-ihe= 30, 2012 2012 KEYSER AVEN SCRANTON, P 18504 Plaintiff Attorney.- EDWIN A ABRAHAMSEN, P. C., 120 N. FLN CARD SERVICES. N.A. In the Court of Common Pleas of 05? PAPERMILL ROAD Cumberland County, Pennsylvania 'A ARf _ DE 197,11 : Civil Division Plaintiff : N S. NO: 2012-1713 C1V?1L 1-D\\ ARD W PA"TOK JR 10? Ouarrv Dr. Praecipe; to Reinstate Civil Compl:?int 1-11oo,Tasbur- PA 17815-8406 Defendant To the Prothonotary of Cumberland COUnty Pennsylvania: Please enter the above: Praecipe to Reinstate the Civil Complaint. Thant. you. a ff Michaef F. Ratchfo Edwiii A. Abraham Law-y,,x ID 'r 86285 S, P.C. IN THE C()1-JR1- OF COMMON PLEAS OF CIIMBERLAIND COUNT Y, 1]']---'N-N SYLVAN" 'N Ft,? CARD SERVICES, N.A 65 PAPERMILL ROAD \k' A, I'K. 1) E 19 7 11 \`s. LI?G'?'?.1.D W PA???LUK JR lio( ES I ()WN? RD .9r-('HANICS31jRGPA 17050-31'?O Plaintiff DefCndant CIVIC ACTION NO: Old-(w1 6-V17 NOTICE TO DEFEND c Cl 1 . '- u, -- c - G > 'l i' >u have been sued in court. If you wish to defend against the claims set forth. 11, he foilowir;g pages, you must take action within twenty (20) days after this Complaint and Notice to Defend aie served by entering a written appearance personally or by an attorney and I-lint; in writing ??,Ith 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 y(,u by the court without further notice for any money claimed in the Complaints o? for any other claim or relief requested by the plaintiff. You may I,)se money or property or oth°r rights important to you. 'i'i_)U SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF Y(-)U 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 f IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BJ- ,ABLE TO PROVIDE YOU WITH INFORMATION ON AGENCIES THAT MAY OFFER LE(3.AI SERVIC.F.S TO ELIGIBLE PERSONS AT REDUCED FEE OR NO FEE_ MIDPENN LEGAL, SERVICES 401 EAST LOUTHER STREET CARLISLE, PA 17013 717-243-9400 _ 11 +k -, (A (02 COMPLA 7 INSTATED PRO NOTARY TRUE COPY FROM RECORD r In Testimony whereof, I here unto set my Land \ and the seal of said Co at Carlisle, Pa. his day _ 20 Al _ Prothonotary Aj IIOtp4T5 ..2 •.q ?y i yL IN TIM COURT OF COMMON PLEAS OF CUMBERI AND COUNTY, PEI,NSYLVANL% I-1- CArD SFRVICFS, N. A. 6`> PAPF-MILL MAD CIVIL ACTION N1,"K, D !9111 r: Plaintiff S. =i ii HOC; I-S1-0`X,\11 1 D M CI -I;:-y4K-BURG PA 17050-3120 Defendant NG: COMPLAINT !"aintitt, iLA- C ??Kll hKVlt:?5, N.A. , by anu Mroug,n its auorneys, Ab; ahani,;en & Associates, P.C., complains of the Defendant as folio"vs: Plaintiff, FIA CARD SERVICES, N.A. , ('Ierel rafter "Plaintiff") is a ??ecpo ation wit'! a pi-iricipal place of business located at 655 PAPERMILL ROADNF WARK, ' ; The Defendant EDWARD W PAWLUK JR (hereinafter "Defendant") is an a,'•ult individual residing at 300 HOGESTOWN RD MECHANICSBURG PA 17050-3120. ? At all relevant times herein, Plaintiff was engaged in the business of deb! Uurchase ana coilection. zI. Defendant applied for and received a credit card issued by FLA CARD SY ' %ICES, N-A, %vitli the accourit number ending in 9894. Use of the FIA CARD SERVICES, N.A. credit card was subject to the t"m and considerations of the Cardmember Agreement {hereinafter "Agreement"}, a copy of which, a!as sent to t 1e Defendam` along with the credit card. A copy of this document has been requ-,--stcd from FI4. Card Services, N.A. and will be provided upon receipt- Defendant used the F.A CARD SFP VICFIS, N.A. credit card account :- uT, i,?cr ending in 9894, for purchases, cash advances and/or bala:,ce transfers ]-he Defendant was mailed account statements relative to the Defe:ndaa,,s ;,:,c of the suhiect credit card. !-he Defendant defaulted under the terms of thc. Agccrrn_nt by fail.n? ? c fusing t;; make' i withk l=ayments on the account as they hec:im, due. ?-ne Defendant last made payment on October I 'y; %ij I [?. I h, - iotal amount due and owing the Plain-_iff including interest, i., q, ' ???, W'HEREFCRE, Plaintiff req,iests judgment in its favor and against Defendant !"1 i?c amount of$12,2i2.57 plus costs W suit and any other relief;-.'s the Court deeilts ji? t ar.1 aphropr,?;te. Resk?ecif,.ily subn-istted, _? ---mot---; t-t?- -- Edwin Al-Abraharnsen 8c A Michael C'. F:atchford, Esq? Attorney 1.D. Nos : 86285 120 North Keyser Ave. Scranton. PA 18504 mratchford@,,eaa-law.com Phone: 570-5_58-5510 Fax: 570-558-5511 VERIFICATIO N i, M'chael F. Ratchford, attorney for Plaintiff, FIA CAP F SERVICES, N- A a? fully fa?riliar ?-,:Ith the facts set forth in the 1.vithin Complaint and --jn ,,iuthorxzed to makr ,'I Ve ifnation on behalf of Plaintiff. I I, erify that the facts set forth in the within allcs2al?ui s are and -on-ect to the best of my krnoNvledge, knowing, that t:r, to se statements are ?at'_ahle _),:rsuant 'o 18 C.S.A. 4904. J 1- Raatchtord, 1 11fA 1 Blatt, Hasenmiller, Leibsker & Moore; LLC Attorney for Plaintiff Morris Scott Attorney I.D. #83587 Syretta Martin Attorney I.D. #309370 1835 Market Street, Suite501 Philadelphia, PA 19103 800-850-1079 FIA CARD SERVICES,N.A. IN THE COURT OF COMMON PLEAS do Blatt, Hasenmiller, Leibsker& Moore, LLC Plaintiff, CUMBERLAND COUNTY, PA vs. CIVIL ACTION "?= No. 2012-1713 CIVIL -o rn; EDWARD W PAWLUK JR tom.) V*t.-) Defendant(s). tr) Cs PRAECI PE TO SUBSTITUTE COUNSEL "'' — s` TO THE PROTHONOTARY: Kindly ENTER the appearances of Morris A. Scott, Esquire (ID#83587) and Syretta J. Martin, Esquire (ID#309370) in the above captioned matter on behalf of the Plaintiff. Papers may be served at the address of Blatt, Hasenmiller, Leibsker& Moore, LLC, at 1835 Market Street, Suite 501, Philadelphia, PA 19103, (Tel) 215-564-1567. Respectfully submitted, /// Mar rs Scott, Esqu' (ID#83587) Syre'a Martin, Esquire (ID#309370) Kindly WITHDRAW the appearances of ABRAHAMSEN &ASSC, P.C. in the above captiI • matter on behalf of the Plaintiff. R: .ect Ily ;.ii' •• 1� AB' ` AMSEN : ASSC, P.C. CERTIFICATE OF SERVICE I, as attorney filing the attached pleading, hereby certify that I m.sled an exact copy of the Praecipe to Substitute Counsel, to the party(ies) below at the address i dicated by U.S. Mail first class postage prepaid. EDWARD W PAWLUK JR 300 HOGESTOWN RD MECHANICSBURG PA 17050 Mom .. quire (ID#83587) Date Syretta Martin, Esquire (ID#309370) OMTNHPSC(11/14/2013) 2886608 111111111111111111 111111111011 111111111111111 11111 111111111111111 11111111