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Home My WebLink About04-5098 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CREDITONE, LLC., assignee ofCITIBANK Plaintiff No. 64 - ~Dq; CIUltT~ vs. COMPLAINT IN CIVIL ACTION CHRISTINE R BRADY Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan, Esquire PA J.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 27 I 8 Koppers Building 436 Seventh Avenue Pittsburgh, P A 152 I 9 (412) 434-7955 WWR#03906954 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CREDITONE, LLC., assignee ofCITIBANK Plaintiff vs. CHRISTINE R BRADY Civil Action No. 0Ll - 509,? C;v~LL~ 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 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 Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249.3166 COMPLAINT 1. Plaintiff is a corporation with offices in Metairie, LA 70002. 2. Defendant is residing at 154 Lincoln Street, Carlisle, P A 17013. 3. Defendant applied for and received a credit card issued by Plaintiff's assignor bearing the account number 41280022 18030067. 4. Defendant made use of said credit card and has currently a balance due and owing to Plaintiff, as of October 23, 2000, in the amount of $9,226.23. 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 15.95% 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 thereofto Plaintiff. WHEREFORE, Plaintiff demands Judgment in its favor and against Defendant, Christine R. Brady individually, in the amount of $9,226.23 with continuing finance charges thereon at the rate of 15.95% per annum from October 23, 2000 plus costs. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED SHALL BE USED FOR THAT PURPOSE. WELTMAN, WEINBERG & REIS, CO., L.P.A. wl~~Ls ire PA 1.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#:03906954 VERlFCATION The undersigned does hereby verify subject to the penalties of 18 PA. C.S. 4904 relating to unsworn falsifications to authorities, that she is Suzanne Middleton, Chief Financial Officer of CreditOne, LLC, plaintiff herein, that 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 her knowledge, information and belief. Su p(J"k ~ \ 0 ~ ~ ~ ~ I/) c:J ~ ~ p-:. lJ '_.~ 8 ,.. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CREDITONE, LLC, ASSIGNEE OF C IT! BANK, Plaintiff vs. No. 04-5098 CIVIL TERM PRAECIPE FOR DEFAULT JUDGMENT CHRISTINE R. BRADY, Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan PA 1.0. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#03906954 Judgment Amount $15,298.02 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 CREDITONE, LLC, ASSIGNEE OF CITIBANK, Plaintiff vs. Civil Action No. 04-5098 CIVIL TERM CHRISTINE R. BRADY, Defendant PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter Judgment against the Defendant, CHRISTINE R. BRADY, above named, in the default of an Answer, in the amount of $15,298.02 computed as follows: Amount claimed in Complaint $9,226.23 Interest from October 23, 2000 to December 7,2004 at the contract interest rate of 15.95% per annum $6,071.79 TOTAL $15,298.02 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. By: L0jL;1~r- William T. Molczan / PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#03906954 Plaintiffs address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2601 Koppers Building, 436 ]'h Avenue, Pittsburgh, PA 15219 And that the last known address of the Defendant is: 154 Lincoln Street, Carlisle, PA 10713 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CREDITONE, LLC., ASSIGNEE OF CITIBANK Plaintiff vs. Civil Action No. 04-5098 CIVIL TERM CHRISTINE R BRADY Defendant IMPORTANT NOTICE TO: Christine R Brady 154 Lincoln Street Carlisle, PA 17013 Date of Notice:?'1A-"J QLJ.. { :ltJ#V YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN 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.PA By ~;I(:/i/~ William T. Molczan / PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.PA 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR #03906954 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. By: tJd'l AU~ William T. Molczan - 7 PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#03906954 CA:>~~ ~ }l ~ \) f.\'i::;~~ ~ ~ ~ F ~. 05 :5 :2 ~ r "./ ,- 1--) ;;;:: t," ,) () ...d,~'- ~ 'l"l r'::""j ---t .' t' t c) i~~::D I"" I "I l-? , ! ~- "'t ~~.~~' , ) . ~ 1 . ,_ I "17-: " ,"'-) r'.,) ,~", 1 ..r=-- u. SHERIFF'S RETURN - REGULAR CASE NO: 2004-05098 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CREDITONE LLC VS BRADY CHRISTINE R VALERIE WEARY I Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon BRADY CHRISTINE R the DEFENDANT I at 1514:00 HOURS I on the 26th day of October , 2004 at 154 LINCOLN STREET CARLISLE, PA 17013 by handing to PHYLLIS CAROTHERS I DAUGHTER a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 3.70 .00 10.00 .00 31.70 ,.-->,,;,;;"-,,' ':~'i/.:~ .,.,. , ,:/.';-.:7' ...-/(~.~-,~,:::...;.<-.".....~ R. Thomas Kline 10/27/2004 WELTMAN WEINBERG REIS Sworn and Subscribed to before By: ~.~ Deputy eriff me this 1!: day of C)1/~:U~} .;Jcv.l A. D. ( h-L- () ~P~h -' J~ rothonotary / ~7