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HomeMy WebLinkAbout12-2464 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FIA CARD SERVICES, N.A. 4161 PIEDMONT PKWY GREENSBORO, NC 27410-8110 Plaintiff vs. ROBERT F DERICK 1102 MOUNTAIN RD NEWBURG PA 17240-9140 Defendant CIVIL ACTION G Iuji r NO: I dL•a`- uq (. im 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 attornev 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 d QUA q6J°& 7S (vk # c??8'Va Q RE. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FIA CARD SERVICES, N.A. 4161 PIEDMONT PKWY CIVIL ACTION GREENSBORO, NC 27410-8110 Plaintiff vs. NO: ROBERT F DERICK 1102 MOUNTAIN RD NEWBURG PA 17240-9140 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 4161 PIEDMONT PKWYGREENSBORO, NC 27410-8110 2. The Defendant ROBERT F DERICK (hereinafter "Defendant") is an adult individual residing at 1102 MOUNTAIN RD NEWBURG PA 17240-9140. 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 7505. 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 7505, 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 August 13, 2011. 10. The total amount due and owing the Plaintiff including interest, is $18,266.07. WHEREFORE, Plaintiff requests judgment in its favor and against Defendant in the amount of $18,266.07 plus costs of suit and any other relief as the Court deems just and appropriate. Respectfully Ydwin A. Abrahamsen & Michael F. Ratchford, Esc Attorney I.D. Nos.: 86285 120 North Keyser Ave. Scranton, PA 18504 mratchford@eaa-law.com 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. FIA CARD SERVICES, N.A. vs. ROBERT F DERICK In the Court of Common Pleas of CUMBERLAND County, Pennsylvania Civil Division Plaintiff Defendant PRAECIPE TO WITHDRAW NO: 12-2464 CIVIL Praecipe to Withdraw Civil Complnt ?v. i M r ; --r7 To the Prothonotary of CUMBERLAND County Pennsylvania: Please enter the above Praecipe to Withdraw the Civil Complaint. Thank you, Michael F. Ratchford, Esquire Edwin A. Abrahamsen & Associates, P.C. Lawyer ID # 86285 120 N. Keyser Avenue Scranton, PA 18504 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff s -?E '-P . -ER:FF Jody S Smith Chief Deputy Richard W Stewart Solicitor 11012 MAY -8 AM 9-- 54 CUMg?gLdND COUNTY PEIiNSYL4ANIA FIA Card Services, N.A. vs. Case Number Robert F. Derick 2012-2464 SHERIFF'S RETURN OF SERVICE 04/24/2012 05:40 PM - Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on April 24, 2012 at 1740 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Robert F. Derick, by making known unto Brenda Derick, Wife of Defendant at 1102 Mountain Road, Newburg, Cumberland County, Pennsylvania 17240 its contents and at the same time handing to her personally the said true and correct copy of the same. DENNI FRY, DEPU SHERIFF COST: $48.00 April 26, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF soi GounfySude Sheriff, rehcsMl. Inc.