HomeMy WebLinkAbout04-6087IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
PENNSYLVANIA
GLOBAL HOLDING AND INVESTMENT CO.,
LLC, assignee of 21ST CENTURY CONCEPTS
ROYAL PRESTIGE
Plaintiff(s)
-vs-
TODD E. REINECKER
Defendant(s)
NO. 014 -6OP7
IN CIVIL ACTION
COMPLAINT
CODE-
FILED ON BEHALF OF
PLAINTIFF
COUNSEL OF RECORD
FOR THIS PARTY:
James R. Apple, Esq.
PA I.D. No. 37942
Charles F. Bennett, Esq.
PA I.D. No. 30541
Joel E. Hausman, Esq.
PA I.D. No. 42096
APPLE AND APPLE, P.C.
Firm No. 719
4650 Baum Boulevard
Pittsburgh, PA 15213
Telephone: 412-682-1466
Fax: 412-682-3138
(j,ut-avv?
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
PENNSYLVANIA
GLOBAL HOLDING AND INVESTMENT CO., NO.
LLC, assignee of 21ST CENTURY CONCEPTS IN CIVIL ACTION
ROYAL PRESTIGE
Plaintiff(s)
-vs-
TODD E. REINECKER
Defendant(s)
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 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
1800-990-9108
2
COMPLAINT
1. Plaintiff is a corporation having offices at 375 Passaic Avenue, Fairfield, NJ
07004, and as the assignee of 21" Century Concepts Royal Prestige, stands in its
assignor's stead, and all are hereinafter referred to interchangeably as "Plaintiff'.
2. At a specific instance the Assignor sold, assigned and transferred to Plaintiff all of
Assignor's right, title and interest in, and to the agreement between Assignor and
Defendant. Assignor had the right to assign the agreement. A copy of the
assignment is attached hereto as Exhibit "A".
3. All conditions precedent to Assignor's right to be paid under the terms of the
contract have occurred.
4. Defendant is an individual whose address is 1703 Creek Vista Drive, New
Cumberland, Cumberland County, Pennsylvania 17070-2212.
5. On or about December 2, 2001, the Defendant applied for and was granted a loan
by Plaintiff at the terms and conditions agreed upon by the parties, as is more
specifically shown by the Application and Agreement, a true and correct copy of
which is attached hereto, marked Exhibit "B" and made a part hereof.
6. The Plaintiff avers that the agreement between the parties was based upon a
written agreement which the Defendant accepted by using the loan to purchase
certain merchandise as is more specifically shown by a true and correct copy of
the Sales Order marked Exhibit(s) "C" and made a part hereof.
7. Thereafter, in breach of obligations under the Agreement, the Defendant failed to
make payments as they became due.
8. Plaintiff avers that the terms of the Agreement provide for acceleration of the
entire balance due and owing upon Defendant's breach of the Agreement.
9. Plaintiff avers that the balance due amounts to $1,505.07, as is more specifically
shown by Plaintiff's Statement of Account, a true and correct copy of which is
attached hereto, marked Exhibit "D" and made a part hereof.
10. Plaintiff avers that the interest has accrued at the rate of 18.00% per annum on the
balance due from August 24, 2004.
11. Per the term of the agreement, the Defendant has agreed to pay to the Plaintiff as
liquidated damages, the costs of collection, including all reasonable attorneys'
fees incurred in the collection of monies owing, which Plaintiff avers will amount
to 25% of the balance due.
12. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed
and refused to pay the amount due to Plaintiff or any part thereof.
WHEREFORE, Plaintiff demands Judgment against Defendant in the amount of
$1,505.07, with appropriate additional interest from August 24, 2004, plus attorneys
fees and costs.
APPLE AND APPLE, P.C.
By:
Pfforneys o laintiff(s)
ASSIGNMENT OF CONTRACT
FOR VALUE RECEIVED, Seller,hereby sells, assigns and transfers to GLOBAL HOLDING AND
INVESTMENT CO., L.L.C., ASSIGNEE, its successors and assigns, all of :seller's right, title and interest
in and to the contract enumerated below and the goods described therE in. To induce Assignee to
purchase said contract, Seller represents and warrants to Assignee (1) thiza the enumerated contract is
valid and genuine and correctly states the terms of the retail transaction b:tween Seller and Buyer; (2)
that the down payment was paid in full, in cash or in trade and that no part was loaned, to Buyer by
Seller or was obtained by Extension of credit to Buyer; (3) that Seller had -ne right to sell said goods to
Buyer and that the goods are free of all liens, claims and encumbrance::; (4) that no notice of any
defense or right of action has been received by Seller from Buyer nor has Seller any knowledge of any
fact that would impair the validity of the contract; (5) that Seller has the right to sell and assign this
contract to Assignee; (6) that all Buyers have legal capacity to contract; (7;; that on the date of contract
Seller executed and delivered to each Buyer a completed copy of the 7.ontract; (8) the Seller has
complied with all other requirements of the Federal Truth in Lending Act, F`egulation Z and the Federal
Trade Commission Credit Practices Rule, and; (9) that if the retail transaction or negotiations related to
the retail transaction were conducted in a language other than English, Sels=_,r gave each consumer prior
to entering into the contract or any written agreement an unexecuted c:: py of the contract or other
written agreement in such foreign language. If any of the foregoing repr ,3entations and warranties is
breached, Seller agrees to repurchase the contract; and Seller shall ii:=iemnify and hold Assignee:
harmless from any and all liability that may result in any time from any clean asserted by the Buyer for
recovery of amounts paid arising out of any promise, representation or wz]-ranty made by Seller or the
Manufacturer to Buyer.
Buyer's / Borrower's Information:
Name I d ? 21 q e2 C kv- in Address:aOq C_r
City: ?
State: ` A q
Dated: f p? /-'/ 6'
Signed by uthorized Signature:
Printed Name of Authorized Signature: re
Si,?!Ier's Information:
Name: 2'1 sY CENTURY COI?IiJEf? 5
Address: ROYAL PhESTICE
City: 501 Route 208
State: Monroe, York 10950
11 ,-?.
/?_'(I- e.-) (:n 61
A
Royal Prestige invites you
a 7a L
to open a line of credit
'? " ! *;.+3 L .? WHY A ROYAL PRESTIGE CREDIT LINE?
_ NATIONWIDE CREDIT Your Royal Prestige Credit Une - YOUCHOOSETHEWAYYOUWANTTOPAY.Witn,Royal
may be used regardless of wnerB you Irve In the United Prestige Credit Lire you can budget your payments over as
Slates. Just call your Royal Prestige Representative and many months as you desire. And unlike other credit lines
order. there's no annual lee
CHOOSE FROM A LARGE SELECTION Jepentling upon SPECIALIZED CREDR. ROyal Presngespeaatzesnolfenrg
your credit level, you may charge any of the fine products credit to customers who purchase products through direct
marketed by Royal Prestige marketing.
v ORDER BY PHONE All you have to do Is pick up ins phone 11 SERVICE The credit department al Royal Prestige pntles
JJJI ^ antl call your local Royal Prestige Office With an already themselves on serving our sus yyyromplly, e11-mly
r}f ?%(J Q .? eslablrshed credit Ire, you lust need to say, 'charge e!• and courteously. pt ,?)
$ RETAIL INSTALLMENT CREDIT AGREEMENT/ REVOLVING CREDIT PLAN (l'?]y/?)
SECTION 1 - TELL US ABOUT YOURSELF- - 'r- _ 37t;i,-r3.?/'?c!y !1
am st \ Foos 11 lnNal Age Se Secunry No. Araaglpeyrmp ll¢M?IQI'ft Hqsde Phone
rPC ?2c ?FX'I ?A 1 _ ?3 ?Q-`LV"1 u. Yes ?No
Present Street Address Apt. No. ICI.ry Slate ZIP Code H Long No & Ages of Dependenrs
" 7AG { o c { 5 rtaCCiS? 3 ?A 1 i l of ?I<'5?
? Marti80 Separaled [I Own Rent i] With Parents Dnvers License NO
:S Unmarned El Other vw 1"(5 L7. L.k "11,2- S ?Z U7
Name of Larwlom/Mongage Holder Address PI Clly I State Zit Code Area Cod' 8 Phone No.
Previous Street Address { City State Zip Code How Long landlord
#?? ?. II.. Phone•
`.IPresenl Emplo er or Business Supv Name Area Wdela L #r How Long Occupation Gloss Mo. Salary
n 2;?-:- 1c1 ?m N\? \? X10..1\ (q",) s7-, -? d5 -l. sy?SIL\Q.a s pp?y zmo?
'Previous Employer (If less man 3 years) Reason for leaving How Long OccupanhA Gross Mo. Salary
H
Spouse's Employer does not )rcsn m n comamunry pooseny optional Area code 8 Business Phone How Lang ...U-".h .-- Mo. Salary
rwTw.R..owwncw.MOrRro,s.e.Ma.w ceo..,r.y mccww,a., rro eE eeve..ro,r rou opt sovxE( ) Gross Mo. Amount
Name - Last First ..`IXNUaI I Aqa?I y lal Security No /A/re E1 Ltblta RbiONt !' Home Pnone
I I1 ?Yes ?Np
resent Stref1drell o. Qry
State I IZip Godo I How Long I hip. & Ages of Dependents
,(Present Empr Business Sul, Name ArearD Q CEL6sSPa?N? ti ? H Long I OIccupp Ilion I Gross Mo. Salary
Ip`nma, Bank - Name ooress ( Area Code & Business Phone I ? Savings - Acct No.
Pts• ) I IJ ChecWng - Acct No.
°oir: ". ° r+vor?o.r.wsswr,.e...iw TMLS Cauc.+mn ,ro uE Ueverso r.w oo a e¢ I Gross Mo Amount
l 1
:iFLLiC.11 i 11ir1;-wlr.hfTI-f
??. ., • .? . . ? ?, ?r Ili ..1 • s . .3 7 ..• ` ..
? v ,.. . Ln?y L.k iv, . ?C , I I x11 t yJw: L, 1 c , ..? '=!.• .;-?'.?v.? ?C?r? 2L? ?L,s I 'k7
53? I (-??z)?3? -tzar C?,?R?
SECTION 4 = NOW TELL US A13OUT YOURCREDIT
)PmMARY BANNNAME 6AOORE53 EA COOEA PHONE,q- ? ,rye-ACR. No
?t-?+G-r?L? ai:?{' (E3oa) 'vSLZ p??, ?- ???L,?-ter NA Irat?.?.n 1 ?q-t ?1
rw.PA-T
UST ADDITIONAL CREDIT REFERENCES. BANKS. FINANCE COMPANIES. CHARGE CARPS-E'+ (OPEN AND CLOSED)
NAME OFCREDiTOR ApORES3 OrTYSTATE I-co- REAcio BPHONE ND
NAME IN wh.. ACCOUNT CAR - AOCOIINT NO ' MONnILYPIn-IT ' ArAN e-o
IeuAY:OF CREDnOq AODPESS /_ CnYSTATE ?OOE COOEB P,KK+E IVO
(REA I
(NAME .rv wHrCN ACCCUNr CARRIED AuCOUNT rb. MONTHLY PAYri<rT 9AUNCE OwEO?
Ia 5
nrWEdF CREOnOn /'? ADDRESS ? 011YSTATE 2W 000E REA FIONE NO
?N,?wwH?.ADd?a-`T?/R_ED . A?nNTNp _ T,.YPA?NT ? '?-? If
aA,?NdEdwEp
? A.?? la ?
Felons Ching a ppl n BALyr6 d Rase pamtitsd ny rem wYl lie cNrged an ma Ountadm9 naWnpe Iron nmmp Ip mmm. ev egmq Eaam. I desists, MY sY pia SWrmnla an me,nave eppluatmr era true errt Cpnatt YW mry rMSbgM my
haeDe, make h,f ImrdP9n yeti ? lRW8euerl or pr 9 any mewl a111hlamMlonNeumpNSd stall aYmerd l noys! YSI Pres P xhobre mry Pmdlece as or r HyCraparveile Hn Corypratew Nosin. or r my o y o omeftb al d ms terms on tlu nark mqubg creMlwlLOaea of Bpyal preAya pyritic, vducn i, my co-pumnaser, a Coln d us Iml
r ASSeylee.
NOTICE TO THE PURCHASER(S)
1. 1 acknowledge receipt of a copy of this document, including the important notice regarding errors or inquiries about my billing statements.
Z Do not sign this credit agreement before you read it or if it contains any blank spaces. You are entitled 10 an exact readable, and completely filled in copy of
this credit agreement at the time that you sign it Keep this agreement to protect your legal rights.
3. You have the right to pay in advance the full amount due.
4. You may cancel a purchase under this agreement, if it has been signed by a party at a place other than the address of the seller which may be his main office
or branch thereof; provided, you notify the seller in writing at his main office or branch, by ordinary mail posted, by telegram sent or by delivery, no later than
midnight of the third business day following a purchase under this agreement, excluding Saturday, Sunday, and a holiday on which regular deliveries.are not
made by the United States Postal Service.
5. The seller has no right to enter unlawfully your premises or commit any breach of the peace to repossess goods purchased under this agreement
5. The seller intends to sell this contract to HyClte Corporation, 340 Coyier Lane, Madison, Wisconsin 53713, or any other Sales Finance Company, which, if it
buys the contract, will become the owner of the contract and your creditor. After sale of this contract, all questions concerning either terms of the contract or
payments should be directed to the buyer of the contract
7. See reverse side of purchaser's copy for important information regarding your rights to dispute billing errors.
SEC710N.Y.YOUR.SIGNATt)RE;'_ v _
`-" -
RETAIL INSTALLMENT CREDIT AGREEMENT/REVOLVING CREDIT PLAN ?
CAUTION' IT IS IMPORTANT THAT YOU THOROUGHLY READ THE )
E TRACT BEF YOU SIGN IT
w
LERlq ,
o n r- r l E"? ?? l a - -01 X?'? ?7YOIJ SIGN IT
s toATEI ,PURCHASEn's sr,NA
BY T Vl,{ r `,- ?VI X
1REPPESE TATIYE531GNATUREI r WRCHASER's sxiW.ru-, IwlEl
mites rapt -eEN ". ORIGINAL
T-
j^b 3- ,
' ..v rr+a? rrav .???+VrL+v+ vn?a'Ir YtVnLL iVILIVI I TTGV VLYt1VV rvrTGtJlI rL/11V
gestdenca average Dairy
,Determined dv address Balance Subject Monthly ANNUAL Annual Fees FINANCE CHARGE
on data Agreement is to FINANCE Periodic PERCENTAGE charged under imposed on
•digned.) CHARGE Rate HATE this plan "New Purchases"
OH All Balances 2.08% 25% None ' Yes
A2, DC, DE, ID, IL, KY, NH All
NJ, NM, NV, CR, SO, SD. UT Balances 20% 24% None Yes
MO, LIT, NY, VA All Balances 2.0% 24% None No
CO, GA, IN, OK, TN, VT, WY, TX All Balances 1 75% 21% None Yes
MS, CA All Balances 1.75% 21% Nona No
MI All Balances 17% 20.4% Norte Yes
KS so - $loco 1.75% 210%
None
Yes
S1000 - OVER 12% 14.4%
MO. PR All Balances 167% 20.04% None Yes
CT, HI, FL, PA
WA, WI, W VA, RI All Balances 1.5% 18% None' Yes
LA, MA, ME, MN, NO, NO All Balances 15% 18% Nona No
$o - $1000 1.5% 18%
AK OVER $1000 Bl% 11% Norte Yes
$0-$500 175% 21%
NE
OVER $500
15%
18% None No
$0-$750 1.75% 21%
AL OVER 5750 1.5% 18% None Yes
- IA All Balances 1.65% 19.8°o None Yes
AR All Balances 10% 12°6 None Yes
1. PURCHASES UNDER THIS AGREEMENT, I may make purchases under mis Agreament by woften Sales Orders or by mall or telephone. You or your asu gm have the right to decline or accept
my order.
2, ASSIGNMENT, I understand mat seller may assign the Agreement to HyCne Carponnon,or to anther Sales Finance Company. I further understand that this Agreement wltl be effective whether
or not do assigned to HyCits Corporation, or to any other Sales Finance Company. If thin Agreement a assigned ho and accepted by HyCte. or any other Saks France Company, 1 well make my
payments dhrecty to HyCls Corporation or to any other Sales Finance Company, to whirth softer may assign this Agmamem. It this Agreement is not assigned or accepted by HyCde Corporation, ar
any other Sams France Company I will make my payments directly to seller who will remain the owner of this Agreement.
3. BILLING STATEMENTS. You will send me a monthly billing sWement it I have an undisputed debt or credit balance of $1.00 . more at the and at Me leafing Period unless you have sorted
collectWn proceedhrgs against me
4, MONTHLY PAYMENTS. (s) Dw, Amount Due and Application Psymene. I agree to pay you w,thin 25 days after each statement Closing Dale, at least the Minimum Payment shown on my
ailing datemant. ou wit credit payments when maehved and apply them first to finance chari
lbl Oatermi ing the Amount of tin Minimum Payment, When 1 make my !al pWwass, ( wt choose to pay ether 4%. 5%, 6%, 7°16, 8%, 9% 01 10% of the totat price of file goads . my
monthly Minimum Paymem. The dollar amount of the Minimum Payment will remain the same until my red purchase. At that time, you will apply the some perca doge to my New Bale.e.
(c) Changing the Minimum Payment. I may change my seeded percentage rh w i g on a Sales Orda at The imne 1 make new purchases width Ira Agreement The changed pncerdage, whtl
apply to all amounts which I owe on my account.
5. FINANCE CHARGES. (a) Agreement and Calculation or Finance Charges. I will pay a FINANCE CHARGE cakulaad by applying a parodic rate to the Average Daly Balance as shown on
above wan.
;b) Determining the Average Daily Sstarim To datemhme the Average Daly BaWce, first you wit take the beginning balance of my account each day. Second d there are finance charges
new p Wcnases as shown on the above schedule m my stale of reada+oe, you will add new purchases to my beginnng balance. (They will be added to my hegmmng balance -ma date
of posing.) It finance charges are not imposed on "new purchases ?n my stale you call not add new purchases to my begiming balance. (They ,It be added to my beginning balance on
the fiat day of Ire nerd bitting perod). Third you will subtract any payments or credits to anwe at the daily balance. Finally, ,- will add up at of the daily balances far the baring period and
dwids Ne total by the number of days m the billing penad. The g+ves you the Average Oaty Balance.
(c) Period For Which Finance Charges Are Assessed. If finance charges are imposed on 'now, purchases' in my stale. finance charges for my purchases begin on the dale you post the pur-
chase to my account. In at omit slates, finance charges begin on the I t day of the men boring period Howe,m, d 1 pay the Nil amount of the New Balance shown on my bung statement
wtho 25 days after the Closing Date shown on the statement. you will not charge me any finance charges for the paced between the Closing Dare and the date I make my payment
(d) Effect of Failure to Make Minimum Payment. If I fat la make a Minimum Paymarn tar a billing period my Minimum Payment for the net billing period .,If be the Minimum Payment omt-
nanly due, plus any unpaid pmyd,,y Mmimum Payments.
6. TERMINATION. You may land or cancel my right to make further purchases under the Agreement.
7 DEFAULT. I will be n default it t fat to pay at least the Mn- Payment on Ilene twice in any 12 month period, unless otherwise provdad by law. It I am m detour, you can make me pay my
Mom balance (including unpad finance charges) unless you are required by law to give me notice of my defaus and an Opponun y to cure a in mat ease, d you give me notne and I do not cure my
AMA. at that time you can make me pay my ant. balance.
6 DEFENSES AGAINST HOLDER. ANY HOLDER OF THIS CONSUMER CREDIT CONTRACT IS SUBJECT TO ALL CLAIMS AND DEFENSES WHICH THE DEBTOR COULD ASSERT
%GAINST THE SELLER OF GOODS OR SERVICES OBTAINED PURSUANT HERETO OR WITH THE PROCEEDS HEREOF. RECOVERY HEREUNDER BY THE DEBTOR SHALL NOT EXCEED
%MOUNTS PAID BY THE DEBTOR HEREUNDER.
9. SECURITY INTEREST IN GOODS NOT RETAINED. The company dais not elan any ndins in any goods financed under the. Agreement.
10 CHANGES IN TERMS. You may charge the forms of li a Agreamem, mdudng the ate of the hence wage and emir terms of payment, after lotlrg me knew that you will be making a change,
n acc.dance win applicable state and federal taw.
1 RETURN POLICY, Except as provided under ire Notice of Cancellabon shown On the Sales Omer, all sales are final and goods may not be returned
2. ENTIRE AGREEMENT AND SEVERABILITY. This Agreement a me entire agreement between us, It any of its pmnaons are unenforceable under the law, that fact will not affect the vai ddy of
my Omer provsrons.
i3. NOTICE TO MARRIED APPLICANTS. In Wisconsin no provaien Of any Rectal papery agreement, unilateral Statement under s.766.59, Wis. Slats., or court decree under s.766.70 adversely
htacts the interest at the creditor unim ire credit., prior to the time the credit is granted or an open-and cmda plan a entered into, is furnished a copy of the agreement. se emem or decree or nisi
ictual knowledge of me adueres P.--.
14. NOTICE TO WISCONSIN APPLICANTS. Annual Percentage Rate: 18% Ana+al Fee: None Other Creiges: None
irwhce Charges begin, ~ a Purchsss a posted. If Annual 1 Percentage
is Pekin fur weh{n 25 days of statement closing data, no finance charges are assessed between ocrang doe and Payment date
5. NOTICE TO KANSAS APPLICANB- The winner agreement a a final -fort a er, of fie agreement between theaedtor and depror and may nit be contraddted by the ewo'mroe of y prior
,ml agreement at of a comareftemo nave; oral agreement between rte areas. and debtor.
ASSIGNMENT
For value received. Seller an" all tits tgms, duties, bblgelions and interest in this Agreement to
("AsMgnee') whoes address is
The assignment is expressly governed by and made subject to the
current Agreement between Seger and Areagnes govemmg assignments, of open end credit pans, setae offers and similar doeumend s.
Nana d Assignee
By- (SEAL) By A, LJ R k,,,- CV a-a / /? (SEAL)
AUlt-..O Signature I J 0.n.ttail Si9Pe are Ll? l
Cate 19_ Dat.
SELLER ROYAL PRESTIGE
PO SOX 1039
MO(?? ?0
M-6759
DATE RECD. I ACCOUNT NO. I DISTRICT NO.
SALES ORDER
(CONSUMER PAPE?)I :. t
P
SOLD TO: NAME
-T(?I ICI( !fie! inl !0.1y n !
ADDRESS
ZIG1911
CITY STATE ZIP
hicd(ziQli I?ibl+?11?I?I7 I i I ??I
0 Y 70 5 '
760083
VERIFIED BY (CODES I i LOG # CR _MT (DATE
{r I
1A d It
SHI A E (Sale as S IL
unrss indicated
! ! ! !
IZ
APARTMENT NO. AD
1 1 1 1 64 -/ 0q
CITY STAY ZIP
I"711101`?
PLEASE ADD ZIP + 4 - i i I I
HOME PHONE BUSINESS PHONE NO CELL PHONE AIS EXTENSION ? DELIVERY DATE
(1-711171) 12-131 1-131U121Cal (17111-71) 171 11 1-10Z71?I
AREA CODE AREA CODE
SETS / PIECE PATTERN PATTERN 8.5" OMELETTE PAN
PC. 4 (PLATES
F 20 SALAD PLAP1E5,SERVICEBREAD &FORBDTERcurs,sAUCEAS, 10.5" OMELETT PAN
TER PLATE PLATES)
HEALTH SYSTEM 1 10 PC. L 20 PC. SERVICE FOR FOUR
HEALTH SYSTEM 2 7 PC. A 12 PC. SERVICE FOR FOUR R 12 PC. SERVICE FOR 4(PLATEa CUPS, SAUCERS) 12" OMELETTE PAN
HEALTH SYSTEM 3 12 PC.(S) 1y 4 PC. SERVICE M SUGAR5 PC. EGETABLEBom,PLATTER. 4 QUART MIXING BOWL &COR, CREAMER)
BoATs
C HEALTH SYSTEM 4 12 PC.(C) RA TABLEWARE CHEST A 6 PC. SERVICE GROUP(GRAVr O
VER) ura SINGLE GIRDDLE
O L PEPPER, OVAL BAKER, aUTTEp DISH 8 COVER)
C HEALTH SYSTEM 5 9PC.XL E C NAPKIN RINGS LARGE PLATTER DOUBLE GRIDDLE
COVERED
?'?K ?IEALTH SYSTEM 6 14 PC. C 4 PC. STEAK SET - EPCSTK H DINNER BELL CASSEROLE ROUND GRIDDLE
( I.JF_' !rte HEALTH SYSTEM 7 17 PC. U 4 PC. KITCHEN SET - EPCKIT N CV. BEVERAGE BREAD & BUTTER R 5 PIECE BAKEWARE SET
R HEALTH SYSTEM 8 22PC.? T 4 PC. CARVING SET- EPCCAR A PLATES I 1 SOUPS I (FRUITS E SALAD MACHINE
E 8 QT. W/COVER E RP KITCHEN SHEARS n PATTERN M 3 PIECE MIXING BOWL SET
12 QT W/COVER R KNIFE BLOCK u 20 PC. SERVICE FOR 4 (PLATES. CUPS.
U ALL PURPOSE ROASTER
SAUCERS, SALAD PLATES, SOUP BOWLS)
20 QT.W.COVER Y KNIFE SHARPENER ? 5 PC. SERVICE SET (ROUND PLATTER, SUGAR M ELECTRIC BROILER
C BOWL WITH COVER. CREAMER. VEGETABLE BOWLI _ S
H 5 PC. COMPLETER SET(SALT & PEPPER SHAKERS,
PAELLA PAN E UV AIR MASTER i GRAVY BOAT, OVAL PIATTER,VEGETABLE BOWq 5 QT. LIQUID CORE COOKER(elec.)
1 AQUA 1500 A 10 3/4" LIQUID CORE SKILLET (elec.)
L INFINITY LUMINA R PATTERN 12" LIQUID CORE SKILLET(elec.)
E INFINITY SHOWER FILTER Y GOBLET ELECTRIC JUICER
R INFINITY DISTILLER DL T CHAMPAGNE WOK
S INFINITY DISTILLER DLX L WINE KITCHEN TOOL SET
Charge to my credit card I i I i I I I I I ! I I I ( ! I I ? AMER EXPRESS h El eISA 11 DISCOVER ? MASTERCARD
Mon
ENTER PURCHASER'S CREDIT CARD NUMSER ABOVE Exp. Date AMOUNT TO BE CHARGED $
1 agree to purchase and Seller agrees to sell the listed items, provided this Sales Order is accepted SALE PRICE $ [ n
under my Revolving Credit Agreement for purchases of Royal Prestige products (the "Credit Plan"). I
request that this Sales Order be accepted under the Credit Plan, and I agree to pay the Unpaid FREIGHT & HANDLING $ r
Balance in accordance with the terms of the Credit Plan um Payment under the Credit SALES TAX $ /
Plan, to be made each month by me, will be (Circle on % 6% 7% 8% 9% 10% TOTAL PURCHASE PRICE $
of the sum of the Unpaid Balance on this order and any of is currently owed for prior pur- LESS DOWNPAYMENT $
chases, plus previous unpaid Minimum Payments. I acknowledge receipt of a completed copy of this
Sales Order and the attached two copies of the Notice of Cancellation form. UNPAID BALANCE $
TO OUR CUSTOMERS. Over and above the separate warranty on individual products, Seller promises you fair and honorable treatment. If you ever have a prob-
count on us to do everything that is fair and reasonable to
lem of any kind with our merchandise, whether specifically cov d our warranty or not, y umay
remedy it. \ G warr
YOU, THE PURCHASER, MAY CANCEL THIS TRANSACTION AT ANY TIME PRIOR TO MIDNIG T OF THE THIRD BUSINESS DAY AFTER THE DATE OF
THIS TRANSACTION -B-Y CERTIFIED MAIL. SEE THE ATTACHED NOTICE OF CANCELLATION FORM FOR AN EXPLANATION OF THIS RIGHT 7
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4? J _L Dated: l i '7L
t?(Seiler- Company Name) t _gREDIT ONLY
Representative ase Print) (Purchasers Signature)
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7 ?(?eP??rese
(Purchaser's Signature)
FORM NO. 10(8-97) ORIGINAL .
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REINECKER,TODD
5 RICHLAND LN
CAMP HILL, PA 17011
DEBTOR NAME/ADDRESS
55*21SO55*047053*--
REINECKER,TODD
5 RICHLAND LN
CAMP HILL, PA 17011
PHI 717 761-3797
PH2 717 691-6200 EXT 6277
CRT/COSTS:
ATTY/FEES:
PRINCIPAL:
INTEREST :
LATE/CHGS:
BALANCE :
1,068.95
370.26
65.86
1,505.07
08-23-04
EMP/REF/MISC/SOURCE/STATUS PAY/DATE AMOUNT TC
CLI: 21ST CENTURY CONCEPTS
SPOUSE:
PAST DUE AMT 1349.26
INT.RATE : 1800
FIN.AMOUNT: 1470.02
NO.PMTS 31
MO.PMT 111.00
01-14-02 58.80 01
02-11-02 60.00 01
03-08-02 58.80 01
04-05-02 58.80 01
05-16-02 58.80 01
06-17-02 58.80 01
07-15-02 58.80 01
08-12-02 58.80 01
09-20-02 120.00 01
11-29-02 2.94 38
12-29-02 2.94 38
01-29-03 2.94 38
03-01-03 2.94 38
03-29-03 2.94 38
04-29-03 2.94 38
05-29-03 2.94 38
06-29-03 2.94 38
07-29-03 2.94 38
08-29-03 2.94 38
09-29-03 2.94 38
10-29-03 5.00 38
11-29-03 2.94 38
12-29-03 2.94 38
01-29-04 2.94 38
02-29-04 2.94 38
03-29-04 2.94 38
04-29-04 2.94 38
05-29-04 2.94 38
06-29-04 2.94 38
07-29-04 5.00 38
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
PENNSYLVANIA
Global Holding and Investment Co., LLC, NO. 2004-06087
assignee of 2151 Century Concepts Royal IN CIVIL ACTION
Prestige
Todd Reinecker
-vs- Plaintiff(s)
PRAECIPE FOR DEFAULT
Defendant(s) JUDGMENT
CODE-
FILED ON BEHALF OF
PLAINTIFF
COUNSEL OF RECORD
FOR THIS PARTY:
James R. Apple, F,sq.
PA I.D. No 37942
Charles F. Bennett, Esq.
PA I.D. No 30541
Joel Hausman, Esq.
PA I.D. No. 42096
APPLE AND APPLE, P.C.
Firm No. 719
4650 Baum Boulevard
Pittsburgh, PA 15213-1237
Telephone (412) 682-1466
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
PENNSYLVANIA
Global Holding and Investment Co., LLC, NO. 2004-06087
assignee of 21" Century Concepts Royal IN CIVIL ACTION
Prestige
Todd Reinecker
-vs- Ptointiif(s)
Defendant(s)
PRAECIPE FOR DEFAULT JUDGMENT
TO THE PROTHONOTARY:
Kindly enter Judgment against the above- named Defendant(s) in Default of an Answer, in
the amount of $1,997.85, computed as follows:
Amount named in Complaint $1,505.07
Interest from August 24, 2004
to January 28, 2005 on $1,505.07 $116.52
Less payment of: -$
Attorney fees $376.26
TOTAL $1,997.85
I certify that Notice of the intention to enter this Judgment was given pursuant to Pa. R.C.P.
237.1. A copy of said Notice is attached, and was mailed on January 17, 2005 by regular mail,
postage prepaid and, addressed as follows:
Defendant: Todd Reinecker
1703 Creek Vista Drive
New Cumberland PA 1 707 0-22 1 2
APPLE AND APPLE, P.C.
Dated: By: ?-
cl? Atto or the Plaintiff(s)
/
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
PENNSYLVANIA
GLOBAL HOLDING AND INVESTMENT CO., NO. 2004-06087
LLC, assignee of 21ST CENTURY CONCEPTS IN CIVIL ACTION
ROYAL PRESTIGE
Plaintiff(s)
-vs-
TODD E. REINECKER
Defendant(s)
Todd Reinecker
1703 Creek Vista Drive
New Cumberland, PA 17070-2212
Date of Notice: January 17, 2005
IMPORTANT NOTICE
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 Bar Association
2 Liberty Avenue
Carlisle, PA 17013
1800-990-9108
By:
James R. Apple, Esq.
Attorneys for Plaintiff(s)
4650 Baum Boulevard
Pittsburgh, PA 15213-1237
Telephone (412) 682-1466
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SHERIFF'S RETURN - REGULAR
CASE NO: 2004-06087 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
GLOBAL HOLDING AND INVESTMENT
VS
REINECKER TODD E
J. MICHAEL ICKES , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
REINECKER TODD E the
DEFENDANT , at 1500:00 HOURS, on the 27th day of December , 2004
at 1703 CREEK VISTA DRIVE
NEW CUMBERLAND, PA 17070
by handing to
KENYON REINECKER, WIFE
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 18.00
Service 12.58
Affidavit .00
Surcharge 10.00
Sworn and Subscribed to before
me this /0 day of
0-0,5 A.D.
othonotary
So Answers:
R. Thomas Kline
12/28/2004
APPLE & APPLE
By:
/l 01AAv D ,J/j.b/--
Deputy Sheriff
l a
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
PENNSYLVANIA
GLOBAL HOLDING AND INVESTMENT CO., NO. 2004-06087
LLC, assignee of 21 ST CENTURY CONCEPTS IN CIVIL ACTION
ROYAL PRESTIGE
Plaintiff(s)
-vs-
TODD E. REINECKER
Defendant(s)
PRAECIPE FOR SATISFACTION
OF JUDGMENT
CODE-
FILED ON BEHALF OF
PLAINTIFF
COUNSEL OF RECORD
FOR THIS PARTY:
Charles F. Bennett, Esq.
PA I.D. No. 30541
Joel E. Hausman, Esq.
PA I.D. No. 42096
APPLE AND APPLE, P.C.
Firm No. 719
4650 Baum Boulevard
Pittsburgh, PA 15213
Telephone: 412-682-1466
Fax: 412-682-3138
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
PENNSYLVANIA
GLOBAL HOLDING AND INVESTMENT CO.,
LLC, assignee of 21ST CENTURY CONCEPTS
ROYAL PRESTIGE
NO. 2004-06087
IN CIVIL ACTION
Plaintiff(s)
-vs-
TODD E. REINECKER
Defendant(s)
PRAECIPE FOR SATISFACTION
OF JUDGMENT
At the request of the undersigned attorneys for the Plaintiff, you are directed to
satisfy the above-captioned Judgment.
APPLE AND APPLE, P.C.
Dated: 9A S- at
By:
A torneys for Plaintiff(s)
I HEREBY CERTIFY THAT THE FOREGOING IS TRUE AND CORRECT
STATEMENT OF THE ABOVE CASE.
THIS STATEMENT IS MADE SUBJECT TO THE
PENALTIES OF 18 PA. C.S. 4904 RELATING TO
UNSWORN FALSIFICATIONS TO AUTHORITIES.
Ls.:+