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Home My WebLink About13-0103 ~~ E (~~~ F'~;~TM~3~~~T~h~~~= 2013 JAt~ - 7 AM I l~ 4 5 ~11~1~~RLANO COUNTY ~F~t~iSY'LVANt~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION MIDLAND FUNDING LLC Plaintiff No: f ~j- ~U3 ~~~ vs. PATRICIA BARD COMPLAINT IN CIVIL ACTION Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan,47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 (412) 434-7955 FAX: 412-338-7130 09795054 C A Pit ABR Q~3.~p~ G~'1 Ck~ ~08~&os~ ~~~849~~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION MIDLAND FUNDING LLC Plaintiff vs. Civil Action No PATRICIA BARD Defendant COMPLAINT AND NO't'ICE 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. 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. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 CIVIL ACTION 1. Plaintiff, MIDLAND FUNDING LLC, is a business entity with offices located at 8875 Aero Drive, Suite 200, San Diego, CA 92123. 2. MCM's records show that the Defendant(s) PATRICIA BARD is/ are individual(s) residing at 5 BARD RD, SHIPPENSBLTRG, PA 17257 3. As set forth in records maintained on behalf of Plaintiff, this action is based upon a credit agreement entered into between Defendant(s) and the original credit grantor. 4. Plaintiff is the current owner of, and/or successor to, the obligation sued upon, and was assigned all the rights, title and interest to Defendant's GE MONEY BANK account XXXXXXXXXXXX7987 (hereinafter "the account"). Midland Credit Management, Inc. (hereinafter "MCM") services the account on behalf of Plaintiff. >. MCM's records state that this action is based upon a credit agreement entered into between defendant(s) and the original credit grantor. MCM's records further state that defendant(s) used or authorized the use of the credit account but failed to make the payments due pursuant to the agreement. 6. MCM's records show that the defendant(s) owed a balance of $1687.95 as of 2011-11-13. 7. Attached hereto are records regarding the account and/or payment(s) received. WHEREFORE, Plaintiff respectfully requests that judgment be entered in favor of Plaintiff and against Defendant(s) in the amount of $1687.95, togethe,~ with interest and costs. a, l~/~iG~ Weltman, Weinberg & Reis, Co., LPA Attorney for Plaintiff Page - 1 8550751748 AFFINDEBTMEDIA PATRICIA W BARD Account Number: 348 579 798 71 Previous Balance -Other Credits $1,867.95 $1,887.95 New Balance __ $0.00 Credit Limit $1,484.00 Available Credit Notre Statement Cbsirg Date 11M32011 Days n Billing Cyde 28 Vak us at jcp.comlcredit Customer Service: 1-800-527-3369 PO Box 965009 Ortando FL 32898.5009 Amount Past Due EO 00 Total Minimum Payment Due $814.00 Payment Due Date 11115!2011 Late Payment Waming: If we do not receive your minimum payment by the date listed above, you may have to pay a late fee up to E35.00. Date Reference Number Type Description of Transaction a Credd 11/13 F9119009X00999990 R CHARGE OFF ACCOUNT-PRINCIPALS 11/13 F91191H19X00999990 R CHARGE OFF ACCOUNT'FINANCE CHARGES' FEES TOTAL FEES FOR THIS PERIOD INTEREST CHARGED 11/13 INTEREST CHARGE ON PURCHASES TOTAL INTEREST FOR THI8 PERIOD Total Fees Charged in 2(111 $235.00 Total Interest Charged in 2011 E344.23 ($880.80) ($707.15) nnnuar rercemags Rate (APR) is the arxwal krterest rate OR your account Annual Balance Expiration Percentage Subject To Interest t3alance of Balance Date Rate Interest Rate Charged Method ant Transactions inued on next page) PLEASE NOTE YOUR MAILED PAYMENT MUST BE RECEIVED BY 5 P.M. (ET) OR YOUR INSTORE PAYMENT MUST BE RECEIVED DURING STORE HOURS ON THE DUE DATE. N071CE: Your payment may be converted info an electronic debit. See reverse for details, BiNing Rights Information and other importarrtirdonnation. PLEASE DETACH AND RETURN THIS STUB WITH YOUR CHECK PAYABLE TO GECRB. -~ Account Numbar:346 579 798 71 E814.00 EO.IXI 11/152011 Ep,00 FILL IN TOTAL PAiD ~ o 0 o a a . ^ ^ N"~~I~ ~ ~~ I ~ ~A~'il ~ ~ New address or email? Print changes on the back. PATRICIA W BARD 5 BARD RD ~1~ }1 ~ r SHIPPENSBURG PA 17257-8143 as,4' %~p ~i ,i P.O. Box 960090 ~ '1 Orlando FL 32896-0090 ems„ ,.a„m4_--- 5433 H5N 1 5 13 111113 Z X PAGE 1 of 3 5135 3900 H775 01E[15433 IrRONSON® Contemporary Styles. New Trends. Hot Brands. See what's new this season with I Heart Ronson. Mnual Balance Expiration PercerLtage Sut>jeG To Interest Balance of Balance Date Rate Interest Rate Charged Method lar NA 29.98% $0.00 §0.00 E on or before 03!29!2010 23.99% 5433 H5H 1 5 13 11 L113 Z X PAGE 2 of 3 9115 3900 M175 Ol EM5933 Verification Bonnie Gohman, being duly sworn (or affirmed) according to law deposes and says that I am employed as a Legal Specialist for Midland Credit Management, Inc. ("MCM"), servicer of this account on behalf of plaintiff. I am a competent person over eighteen years of age, and make these statements herein based upon personal knowledge of those account records maintained on plaintiffs behalf. I am authorized to make this verification on plaintiffs behalf. The facts set forth in the foregoing pleading are true and correct. The undersigned understands that the statements therein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. DEC 12 2Q12 Date ~- Gohman OH 14 Weltman, Weinberg & Reis. Co., L.P.A Page - 2 -~- ~11l~IN~H ° . NMIIIIIH 8550751748 ARFINDEBTMEDIA