HomeMy WebLinkAbout04-5222
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
UNIFUND CCR PARTNERS,
Plaintiff,
CIVIL DIVISION
ARBITRATION DIVISION
No. Ol../-S~~^- CI.CJLI82-.~
vs.
COMPLAINT IN CIVIL ACTION
WILLIAM R. SCHNEIDER
and DOROTHY T. SCHNEIDER,
Defendants.
Filed on behalf of Unifund CCR
Partners, Plaintiff
Counsel for Unifund CCR Partners:
Jonathan S. McAnney, Esquire
Pa. 1.0. #50041
TUCKER ARENSBERG, P.C.
Firm #287
1500 One PPG Place
Pittsburgh, PA 15222
(412) 566-1212
UT:337507-1 014636-116456
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
UNIFUND CCR PARTNERS,
Plaintiff,
)
)
)
)
)
)
)
)
)
No. CI-I - });;U...
Cc.>'LL '-r€IL..~
vs.
WILLIAM R. SCHNEIDER
and DOROTHY T. SCHNEIDER.
Defendants.
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 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 MAYBE 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
2 LIBERTY AVENUE
CARLISLE, PA 17013
(800) 990-9108
USTED DEBE LLEVAR ESTE PAPELA SU ABOGADO ENSEGUIDA. SI USTED NO TlENE UN
ABOGADO, VAYA 0 LLAME POR TELEFONEE LA OFICINA FIJADA AQUf ABAJO. ESTA OFICINA
PUEDE PROVE ERE CON INFORMACION DE COMO CONSEGUIR UN ABOGADO.
SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVE ERE
INFORMACION ACERA AGENCIAS. QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS
ELIGIBLE AQ UN HONORARIO REDUCIDO 0 GRATIS.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
(800) 990-9108
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
UNIFUND CCR PARTNERS,
Plaintiff,
)
)
)
)
)
)
)
)
)
)
)
No C>4 - -.5..2 ":2.2.-, ~ .f ~,., ,
. Ll u\ L lu<-~
vs.
WILLIAM R. SCHNEIDER
and DOROTHY T. SCHNEIDER,
Defendants.
COMPLAINT IN CIVIL ACTION
AND NOW, comes the Plaintiff, UNIFUND CCR PARTNERS, by its
counsel, Tucker Arensberg, P.C. and files this Complaint stating as follows:
1. The Plaintiff is Unifund CCR Partners, a Delaware partnership, with
offices located at 10625 Techwoods Circle, Cincinnati, Ohio 45242.
2. The Defendants, William R. Schneider and Dorothy T. Schneider are
individuals and residents of 207 Pennsylvania Avenue, Camp Hill, PA 17011.
3. On or about May 28, 1991, the Defendants applied for and were
approved to receive a Citibank Universal Card Svcs Credit Card (hereinafter "Account").
Such Account was issued at Account Number 5398800002886937.
4. The Defendants utilized such Account and incurred a balance due
and owing.
5. As of September 29, 2003, the Defendants owed $1,080.30 in
principal, and $189.25 in interest. The total amount owed is $1,269.55. See the Affidavit
of Indebtedness attached hereto as Exhibit "A" and incorporated by reference as if fully
set forth at length herein.
6. Despite written and oral demands for payment, the Defendants have
failed and refused to pay the amount due and owing.
7. Reasonable attorneys' fees in the amount of 20% of the principal
balance are due and owing.
8. The following amounts are currently due and owing from the
Defendants:
Principal and Interest
Reasonable Attorney's Fees (20%)
TOTAL:
$1,269.55
$ 253.91
$1,523.46
9. The Account has been assigned by Citibank Universal Card Svcs to
the Plaintiff including all rights to collect the amount due from the Defendants.
-2 -
WHEREFORE, the Plaintiff, Unifund CCR Partners demands that judgment
be entered in its behalf and against the Defendants, William R. Schneider and Dorothy T.
Schneider, in the sum of $1 ,523.46 plus costs and interest.
TUCKER ARENSBERG, P.C.
Jonathan S. M
Pa.I.O.#500
(l
By
nney, Esquire
Counsel for nifund CCR Partners:
TUCKER ARENSBERG, P.C.
1500 One PPG Place
Pittsburgh, PA 15222
Attorneys for Plaintiff
- 3 -
VERIFICATION
The undersigned verifies that the statements made in the foregoing
Complaint are true and correct to the best of her knowledge, information and belief and
understands the statements therein made are made subject to the penalties of 18 Pa.C.S.
94904 relating to unswom falsification to authorities.
Chr~r
Unifund CCR Partners
UT:317956-1014636-014524
( 1(P [I S{P
AFFIDAVIT OF INDEBTEDNESS
State of Ohio)
County of Hamilton ) ss.
Jessica Bergholz being sworn, deposes and says that she is Media Supervisor ofUnifund CCR Partners
herein called assignee, which is doing business at 10625 Techwoods Circle, Cincinnati, Ohio 45242 and that
she is authorized to make the statements and representations herein.
The defendant is not in any branch of the military.
There is due and payable from William R Schneider, Account Number 5398800002886937, the amount of
$1334.28 (principal balance in the amount of$1080.30 plus interest up through 07/27/2004 in the amount
of$253.98). By the terms of the agreement between the defendant and the original creditor, interest is
accruing from the aforesaid date at the rate of 6.00 percent per annum. This balance reflects any payments,
credits or offsets made since the account was charged off.
This account was originated with Citibank Universal Card Svcs. Unifund CCR Partners purchased this
account from Citibank Universal Card Svcs. Said account has been assigned, transferred and set over unto,
Tucker Arensberg with full power and authority to do and perform all acts necessary for the collection,
settlement, adjustment, compromise or satisfaction of said claim, on behalf ofUnifund CCR Partners.
DATED this July 27, 20 4
By: Jessica Bergholz
Media Supervisor
10625 Techwoods Circle Cincinnati, OH 45242
Address
. s 27 day of Julv. 2004
Year
Notary Public
My commission Expires
Client # 215
ANGELA l. FRECKMAN, NOTf\~V r' ::-. iC
I'J il:~D ~nR THE 2-:,:' ..
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MY COMMiSSiON D:P\Ht.~ .'.
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SHERIFF'S RETURN - REGULAR
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CASE NO: 2004-05222 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
UNIFUND CCR PARTNERS
VS
SCHNEIDER WILLIAM R ET AL
HAROLD WEARY
I Sheriff or Deputy Sheriff of
Cumberland CountylPennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE
was served upon
SCHNEIDER WILLIAM R
the
DEFENDANT
I at 1810:00 HOURS, on the 3rd day of November I 2004
at 207 PENNSYLVANIA AVENUE
CAMP HILL, PA 17011
by handing to
WILLIAM R SCHNEIDER
a true and attested copy of COMPLAINT & NOTICE
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
18.00
20.72
.00
10.00
.00
48.72
So Answers:
.;~~~~~;~ ~~
R. Thomas Kline
11/04/2004
TUCKER ARENSBERG
Sworn and Subscribed to before
By:
~L4/ J~'-1---
Deputy Sh.e'f'iff
me thi s dv.::.
day of
A.D.
.4<
SHERIFF1S RETURN - REGULAR
~ . CA"SE NO: 2004 - 05222 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
UNIFUND CCR PARTNERS
VS
SCHNEIDER WILLIAM R ET AL
HAROLD WEARY
, Sheriff or Deputy Sheriff of
Cumberland County/Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE
was served upon
SCHNEIDER DOROTHY T
the
DEFENDANT
I at 1810:00 HOURS I on the 3rd day of November I 2004
at 207 PENNSYLVANIA AVENUE
CAMP HILL, PA 17011
by handing to
WILLIAM R. SCHNEIDER I HUSBAND
a true and attested copy of COMPLAINT & NOTICE
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
6.00
.00
.00
10.00
.00
16.00
So Answers:
~?* /"",:1 ,.-;:?'
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-:t'.;.;"
R. Thomas Kline
...,.,/(-:te.p
11/04/2004
TUCKER ARENSBERG
Sworn and Subscribed to before
By:
714ft ~)
Deputy Sh~
me thi s .j~~ day of
C)O;;J J-LJV~ A.D.
Ck. Cl rrulk-e ~.
Prothonotary i
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
UNIFUND CCR PARTNERS,
CIVil DIVISION
ARBITRATION DIVISION
Plaintiff,
No. 04-05222
PRAECIPE FOR ENTRY OF DEFAULT
JUDGMENT
vs.
WilLIAM R. AND DOROTHY T. SCHNEIDER,
Defendants.
Filed on behalf of Unifund CCR
Partners, Plaintiff
Counsel for Unifund CCR Partners:
Jonathan S. McAnney, Esquire
Pa. 1.0. #50041
TUCKER ARENSBERG, P.C.
Firm #287
1500 One PPG Place
Pittsburgh, PA 15222
(412) 566-1212
L1T:355648-1 014636-116456
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
UNIFUND CCR PARTNERS, )
)
Plaintiff, )
)
vs. )
)
WilLIAM R. AND DOROTHY T. SCHNEIDER, )
)
Defendants. )
No. 04-05222
PRAECIPE FOR ENTRY OF DEFAULT JUDGMENT
To Prothonotary:
Please enter Judgment by Default in the above-captioned case for the
Plaintiff and against Defendant, in the amount of $1,523.46 plus costs and interest, for
failure to answer or otherwise respond to the Complaint.
I hereby certify that the attached written Notice of Intention to take a
Default Judgment was mailed to the Defendant ten days prior to the filing of the
Praecipe for Entry of Default Judgment.
Date:
J. 74 0>
By:
Jon
Pa. I. . #50041
Co sel for Unifund CCR Partners:
TUCKER ARENSBERG, P.C.
Firm #287
1500 One PPG Place
Pittsburgh, PA 15222
412-566-1212
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
UNIFUND CCR PARTNERS,
CIVil DIVISION
ARBITRATION DIVISION
Plaintiff,
No. 04-05222
vs.
TEN DAY NOTICE
WilLIAM R. AND DOROTHY T. SCHNEIDER,
Defendants.
Filed on behalf of Unifund CCR
Partners, Plaintiff
Counsel for Unifund CCR Partners:
Jonathan S. McAnney, Esquire
Pa.I.O.#50041
TUCKER ARENSBERG, P.C.
Firm #287
1500 One PPG Place
Pittsburgh, PA 15222
(412) 566-1212
L1T:343782-1014636-116456
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Defendants.
) CIVIL DIVISION
) ARBITRATION DIVISION
)
) No. 04-05222
)
)
)
)
)
UNIFUND CCR PARTNERS,
Plaintiff,
vs.
WILLIAM R. AND DOROTHY T. SCHNEIDER,
TO: William R. And Dorothy T. Schneider
207 Pennsylvania Avenue
Camp Hill, PA 17011
DATE OF NOTICE: December 1, 2004
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY AN ATTORNEY AND FILE IN WRITING WITH THE
COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU.
UNLESS YOU ACT WITHIN TEN (10) 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 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
2 LIBERTY AVENUE
CARLISLE, PA 17013
(800) 990-9108
McAnney, Esquire
41
Plaintiff
TUCKER RENSBERG, PC.
1500 One PPG Place
Pittsburgh. PA 15222
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the within Ten Day Notice
was served on the following by first class mail, postage pre-paid on December 1, 2004:
William R. And Dorothy T. Schneider
207 Pennsylvania Avenue
Camp Hill, PA 17011
Jonathan .
Pa.I.D.#50
TUCKER A
1500 One P G Place
Pittsburgh, PA 15222
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