HomeMy WebLinkAbout12-3926WELTMAN, WEINBERG & REIS CO., L.P.A.
BY: William T. Molczan, Esquire Attorney for Plaintiff(s)
Pa. Identification No. 47437 ; F
436 Seventh Avenue, Suite 1400
Phone: 412.434.7955 w
Fax: 412.434.7959
File #09438135
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ATLANTIC CREDIT AND FINANCE, INC. } Court of Common Pleas
} CUMBERLAND County
} CID
}
vs. }
}
CHRIS M CHOI }
NO. /a - 39a(
0'. i' ? r.
COMPLAINT IN CIVIL ACTION AND NOTICE TO DEFEND
tea'-.,
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 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS
OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
(717) 249-3166
4? log.-75 PO Arm
##105(0'7317
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COMPLAINT IN CIVIL ACTION
Plaintiff is a corporation licensed and authorized to conduct business in the State
of Virginia with a place of business located at 2727 Franklin Road, Roanoke, Virginia 24014.
2. Upon information and belief, Defendant is an adult individual who at all times
pertinent hereto resided at 11 Nottingham Drive, Mechanicsburg, PA 17050.
3. Plaintiff is the holder and/or assignee of a credit account opened by Defendant
bearing an account number of xxxx-xxxx-xxxx-0182.
4. Upon information and belief, Defendant failed to make the required monthly
payments on this credit account and is therefore in default of his payment obligations.
5. The current balance due Plaintiff as a result of Defendant's default is $3,061.95.
See statement reflecting balance owed attached hereto and made a part hereof and marked
Exhibit "1 ".
6. Despite demand for payment, Defendant refuses to pay the amount owed and
has an outstanding balance in the amount of $3,061.95.
WHEREFORE, Plaintiff demands judgment be entered in its favor and against
Defendant in the amount of $3,061.95, plus interest at the statutory rate of 6.00% from time of
judgment, plus costs.
WELTMAN, WEINBERG AND REIS, CO. L.P.A.
k? 71/1-?
William T. Molczan, quire
This law firm is a debt collector attempting to collect this debt for our client and any
information obtained will be used for that purpose.
1
9438135
0#1 re mnizone' 40 kried HSBC lD
PROGRAM MASTERCARD Reward Zone Program Platinum MasterCard Account
CHRIS M CHOI Account Number 5156-25M M88-0182
Pay I of 2 Prom November 21 2010 to Deetrber 21 2010
Previous Balance $2,988.73
Payments $0.00
Other Cre" so 00
Purdsaa/Debita + 50,00
Balance Trawfen + 50.00
Cub Advanww + $0.00
Pat Due Amount 5638.00
Fees Charged + 535.00
Inbred Charged + .22
New Balance $3,061.95
Credit Limit 54,000.00
Credit Available $0,00
Cub Limit t SI,000.00
Cub Available $0,00
Statement Closing Date December 21, 2010
Days in Billing Cycle 30
tCash Limit is a portion of Total Credit Limit.
New Balance 53,061.95
Minimum Payment Dan $742.00
Payment Due Date )amury 16, 2011
Late Payment Warning: if wa do no receive you minimum payment by the
due listed above, you may have to pay a lam In of up to $35.00 and your APRs
may be increased to the Penalty APR of 29.99%.
Mlnbmnu Prytnent Warning: if you make only the minimum payment each
period, You will pay awe in interest and it will take you longer to pay off your
balance. For exempla:
Wynn male no additional You will pay off the And you will end up paying
chat=s u" &a card balance shown on an estimated total of.
and each nwn* you this statemtmt in
Pay. about..
Only the minimum 15 Years S7Z60
Pay-
$107 3 Yearn 53,852
(Savings - $3,408)
If you world like information about credit eauuse6ng services call
1-866-569-2227.
aryouse
Reward Zone Program MasterCard, PO Box 17051,
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Automated Account hnf 1-800.419-4959 Baltimore,
297 .I
Lost or Stolen Card I-800.3954500 B11Nng kWArim: Reward Zoos Program MasterCard
PO Box 80045
Salinas
Out" USA Collect
1.702-243.1575 ,
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CA 93912 -0043
TDOWearisg Impaired I-800-395-9020 Menage Your account When at www ,coos
tAneehaese auastew Amount
Base Buy Spemda (4% on ciigibk pumbans) 50.00
Other MasterCard Spend' (up to 2% an eligible purchases) 50.00
For award and point devil. to update you profile, check out exclusive offers and more, visit MyRowa niZone.eom. Use the card, earn the points, get the rewards.
*May include ineligible purcltsea.
As a reminder, you may pay your credit card bill online or through our automated phone system for no fee.
IF YOU ARE UNABLE TO SEND YOUR PAYMENT TODAY. PLEASE CALL 866.843.3978 TO DISCUSS A REPAYMENT ARRANGEMENT.
Tray Bela Ib - neat Deetxlpgan (Tr waealkn or CredR Paid wm Type IBaNntsoa Nam4er AnWAVt
Tram Data Pod Dote Desm"on of Feee Raftes Number Amount
12/16/(0 12/16/10 LATE CHARGE ASSESSMENT 10000006080000999562990 S35.00
Toted Fees For This Is- S3S.00
Dooor"on of kllaost Charge Amount
Deeeh eoi,wn awe. 1- ,.ie yew p, e .
WImwlamizone'
PROGRAM MASTERCARD
SOnn5E 21 0000000601 0 antra D 4 6136Dar1 3eanvr00etee Dr keaRea i4O„reaan
CHRIS M CHOI
34 E LOCUST ST
MECHANICSBURG PA 17055:3938
III --- UN qy d %%Ift
Account Number. 5156-2500-8086-0182
New Balance $3,061.95
Minimum Payment Due $742.00
Payment Due Date 01/182011
Include account metber on check to Reward Zane Progrunl
MasterCard. Do net seed cub. Place tend your payment 7 to 10
da
ys prior to the payment due dale to ensure Broady delivery. EX Eg??
AMOUNT
500 NC OSL ED HIBIT
REWARD ZONE PROGRAM MASTERCARD I
PO BOX 17051
BALTIMORE MD 21297-1051
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515625008088018200074200003061951
1
®I rwardzone 40 irredby HSBC m
PROGRAM M A S T E R C A R D Reward Zone PmBtam Platinum MaetaCard Account
CHRIS M CHOI AccomNumbar5156.2500-8088-0182
Pace 2 of 2 Fmm November 21 2010 to Deomrber 21 2010
INTEREST CHARGE ON CASH ADVANCES $000
INTEREST CHARGE ON PURCHASES $38.22
INTEREST CHARGE ON BALANCE $000
TRANSFERS
ToW h tom For This Period $38.22
MMM Total fan wharpd in 2010 $276.00
Total interest eharpd iD 2010 5373.19
Y-Amom d PS -Mp Rabe (APR) is dts amrd iomnat mB a your soarer
Type of Stet" Annual Peteenlye Rate (AFMtt Balmwe Subject to limbno t Rab monist charge
PURCHASES 10001 1414% $2,787.16 532.63
PURCHASES 10001 29.99% $226.93 $5.59
CASH ADVANCES 20001 25.99% $0.00 $000
BALANCE TRANSFER 1424% $0.00 $000
41111
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Happy HolWsyat fiat tPh for ewtsyom on your list, inchtdlty a variety of Holiday thettr on wards at Ban Boy. Pia, an your RrwardZmw Mast rCord to Bowe an
you peed- this holiday aeaaon.
Seem ia 11 semaauN 0 snom D t ally Dan
9438135
VERIFICATION
The undersigned does hereby verify subject to the penalties of 18 PA. C.S. 4904 relating
to unsworn falsifications to authorities, that he/she is ?axAm &J?
_
(NAME)
Cif ;,?Q of _ ?p, -?r 'Maj: n,•plaintiff herein, that
(TITLE) T (COMPANY)
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 of his/her knowledge, information and belief.
(SIGNATURE)
WWR#09438135
CHOI, CHRIS M
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart:
Solicitor
Atlantic Credit & Finance Inc.
vs.
Chris M Choi
?9 ?utt? a4 4;ur,Grr??,
SHERIFF'S RETURN OF SERVICE
NONO FAl'
2912 JU - 3 PM 1: 22
CUMERLA D COUNTY
PEROSYLVANIA
Case Number
2012-3926
06/26/2012 05:14 PM - Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on June
26, 2012 at 1714 hours, he served a true copy of the within Complaint #7a tic , pon the within named
defendant, to wit: Chris M. Choi, by making known unto himself person 1 N ttingham Drive,
Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents e s me time handing to
him personally the said true and correct copy of the same.
WN HARRISON, DEPUTY
SHERIFF COST: $38.00
June 28, 2012
SO ANSWERS,
RONNY RANDERSON, SHERIFF
. it, ?.?1 ._..