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Home My WebLink About04-5634 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAeV' OF COLORADO LLC Plaintiff No. DLl - .rWi.( (!IOLL~ vs. COMPLAINT IN CIVIL ACTION DAVID E SNYDER Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt PA 1.D #42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, P A 15219 (412) 434-79555 WWR#03390367 TN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CACY OF COLORADO LLC Plaintiff vs. Civil Action No. DI..[ - SI-3V C,"u,tT'iR...'1 DA YID E SNYDER 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 HA YE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP LAWYER REFERRAL SERVICES CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD ST. CARLISLE, PA 17013 COMPLAINT 1. Plaintiff is a corporation with offices in 370 17th St. Suite 5000, Denver, CO 80202. ., Defendant is residing at 205 N. 25th St., Camp Hill, P A 17011. 3. Defendant applied for and received a credit card issued by Plaintiffs assignor bearing the account number 5260310420216704. A true and correct copy of Plaintiffs Statement of Account is attached hereto, marked as Exhibit "1" and made a part hereof. 4. Defendant made use of said credit card and has currently a balance due and owing to PlaintifC as of October 25,2004, in the amount of$4,628.64. 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 of23.99% 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 thereof to Plaintiff. WHEREFORE, Plaintiff demands Judgn1ent in its favor and against Defendant, Davin E. Snyder individually, in the amount of $4,628.64 with continuing finance charges thereon at the rate of 23.99% per annum from October 25,2004 plus costs. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED SHALL BE USED FOR THAT PURPOSE. ERG & REIS, CO., L.P.A. ../ , ..f1t; WV"vY)//. JaI~s C. Wannbrodt P A J.D #42524 WELTMAN, WEINBERG & RBIS CO., L.P.A. 27}8 Koppers Building )1' 4 6 Seventh A venue / ittsburgh,PA 15219 , (412)434-79555 WWR#:03390367 ~ame, or aaaress Telephone changes Home ( ) Work ACCOUNT NUMBER PAYMENT DUE DATE PAST DUE AMOUNT MIMINUM PAYMENT NEW BALANCE AMOUNT OF PAYMENT ENCLOSED 5260 3104 2021 6704 03/15/2002 I 454.00 2890.58 3761. 58 $ 8122 3100 AT F X 1 7 13 DAVID E SNYDER, ANNA M SOSSSONG 205 N 25TH ST CAMP HILL PA 17011-3611 ACCOUNT NUMBER CREDIT LINE CREDIT AVAILABLE DAYS IN BILLING CYCLE BILL DATE PAYMENT DUE DATE MINIMUM PAYMENT DUE 5260 3104 2021 6704 1400 32 02/19/2002 03/15/2002 2890.58 DATE OF TRANS POST REFERENCE NUMBER DESCRIPTION OF TRANSACTIONS AMOUNT 0000 0000 0219 0000 OVERLIMIT FEE LATE CHARGE - MIN P'!MT NOT RECD BY DATE 29.00 29.00 FAILURE TO MAKE PAYMENT HAS DAMAGED YOUR CREDIT RATING. HOWEVER, WE WANT TO WORK WITH YOU TO REBUILD YOUR CREDIT. CALL TODAY TO GET STARTED. ENROLL IN CHASE PAYMENT PROTECTOR PLAN TODAY. THE PLAN THAT HELPS PROTECT YOUR CREDIT RATING. * * * FINANCE CHARGE CURRENT PURCHASE 77.19 PREVIOUS BALANCE PAYMENTS CREDITS NEW PURCHASES AND ADVANCES DEBIT ADJUSTMENTS FINANCE CHARGE OVERLINE AMOUNT NEW BALANCE 3626.39 .00 .00 .00 58.00 77.19 2361.58 3761. 58 ~ AMOUNT FOLLOWED BY A MINUS SIGN(-) IS A CREDIT OR A CREDIT BALANCE UNLESS OTHERWISE INDICATED b t ..11 - .. I' t-xh. I _ 7 "'" YOU MAY AVOID ADDITIONAL FINANCE CHARGES ON PURCHASES IF YOU PAY THIS AMOUNT BY THE DUE DATE TYPES OF CREDIT TO WHICH RATES APPLY PURCHASES ADVANCES FINANCE CHARGE BALANCES 3669.93 DAILY PERIODIC RATE .06573 % .06573 % NOMINAL ANNUAL PERCENTAGE RATES 23.99 % 23.99 % ANNUAL PERCENTAGE RATES 23.99 % % $ 3761. 58 I .~ I SEND INQUIRIES TO PO BOX 15919 WILMINGTON DE 19850-5919 IF YOU TELEPHONE YOUR INQUIRY, YOU DO NOT PRESERVE YOUR :tIGHTS UNDER FEDERAL LAW. :USTOMER SERVICE TELEPHONE NUMBER'S: 800-334-3942, 800-545-0464 ro REPORT LOST/STOLEN CARDS, TOLL FREE 800-334-3942 ANYTIME FROM ALL 50 STATES, PUERTO RICO, AND THE U.S. VIRGIN [SLANDS. YOU ARE NOT REQUIRED TO PAY ANY SPECIFIC AMOUNT YOU HAVE PROPERLY REPORTED TO US AS DISPUTED PENDING OUR ::OMPLIANCE WITH APPLICABLE LAW. VERI FICA TION 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 :r:;'/vv &cJu.r (NAME) / /t/I./ A<<~...J- &e,,,,J.;v'k (TITLE) of c;,i/~d 4",;:.-,"('<- (COMPANY) , plaintiff herein, that 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. ~ ~IGNATURE) 03390367 I ,~ ~ (:) ~ 1 U) #- ~ 0 c' !"-..) --- ~ c: <:::.:") (,) (0 = '3 .j;.- -'I r'1~ 1::1'/ z --4 ~ it! I' C:) I-n ~ rl1- )J :::"i. .....:: r-" ! ,\ I -ofT! CI') '-.D 7~C" .......0 ~ _.l ':::4t) ~ b ~.~ '"'j'"' -l~ .OJ' \ ("):11 c :~.: J::- c- o (~h1 - .' oIC... ..-I .::- .~~. ..< ~ (}1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CACV OF COLORADO, LLC., Plaintiff No. 04-5634 CIVIL TER vs. PRAECIPE TO SETTLE, DISCONTINUE AND END WITHOUT PREJUDICE TO REFILE DAVID E. SNYDER, Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt PA 1.0 #42524 WELTMAN, WEII\JBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 1 :5219 (412) 434-7955 WWR#03390367 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CACV OF COLORADO, LLC., Plaintiff vs. Civil Action No. 04-5634 CIVIL TER DA VI D E. SNYDER, Defendant PRAECIPE TO SETTLE. DISCONTINUE AND END WITHOUT PREJUDICE TO HEFILE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: SIR: Settle, Discontinue and End the above-captioned matter upon the records of the Court without prejudice to refile and mark the costs paid. WELTMAN, WEINBERG & REIS CO., L.P.A "---- I' , W l'VUl......,.U < ~. endy L. Ga I - ';' .'_ Lity Of Pittsb U 1: I\",-I'! r' Jb,IC , , urgt - cHI" C '" rOfY\m,s,cJO:l Ev' '''_;J t;, 'f at.,: I.y .. _ ::)lr,~,~~v 15, 20{)f C) f"o.) 0 c:;:) f; ~ .." .r:- '"- 0 -! 'L1W fT'1 :I:::n n-1rr: (""') ~r;; Z:'1,~~ 6JS'~, N -00 \.0 beL) ::-:"".. c:. C~- ::y.l~; ~ ----h ~o :J; Q(') .....~{; am P.f~ ..-. ~ -r> 0 :'0 -..l .< SHERIFF'S RETURN - NOT FOUND CASE NO: 2004-05634 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CACV OF COLORADO LLC VS SNYDER DAVID E R. Thomas Kline {Sheriff or Deputy Sheriff, who being duly sworn according to law, says{ that he made a diligent search and inquiry for the within named DEFENDANT SNYDER DAVID E but was unable to locate Him In his bailiwick. He therefore returns the COMPLAINT & NOTICE I NOT FOUND I as to the within named DEFENDANT { SNYDER DAVID E 205 N 25TH STREET CAMP HILL, PA 17011 DEFENDANT'S ADDRESS IS 57 CHAMBERLAIN DR NEWPORT { ME 04953-4139. Sheriff's Costs: Docketing Service Not Found Surcharge So answers :_.__ 18.00 11.10 5.00 10.00 .00 44.10 ~_.. ,,;c.'c..' ...... ...:' .",/ .. .." ',,/ .' ._:<.n" ,...::::;..,:..'.. .' ..~... ~~~.. ~,",>_...- -----""'~-? _.' ~c.;- c'''~'''2/'''>'--'---- ( . R. Thomas Kline .' Sheriff of Cumberland County WELTMAN WEINBERG REIS 12/06/2004 Sworn and subscribed to before me /p tf: day of CIA" ~7 this ;2 tJ05' A . D . ~a~ Pr t onotary I ~