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HomeMy WebLinkAbout13-3334 Supreme Court ofrP "r- ennsylvania COU , �o f Co`mm leas For Prothonotary Use Only. Docket No: S'� CUNJB RLAI�ID �� County 13 -3 - 3340M er 1N The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the filing and service ofpleadings or other papers as required by law or rules of court. Commencement of Action: S O Complaint n Writ of Summons ® Petition Transfer from Another Jurisdiction Declaration of Taking 'E C Lead Plaintiff's Name: Lead Defendant's Name: FIRST FINANCIAL INVESTMENT FUND VI, LLC CHAN IL PARK T I Are money damages requested? Yes ®No Dollar Amount Requested:Owithin arbitration limits (check one) [3outside arbitration limits 0 I N Is this a Class Action Suit? 0 Yes ED No Is this an MDJAppeal? 0 Yes El No A Name of Plaintiff/Appellant's Attorney: MICHAEL F RATCHFORD Check here if you have no attorney (are a Self - Represented jPro Se] Litigant) Nature of the Case Place an "X" to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim, check the one that you consider most important. i TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS © Intentional ® Buyer Plaintiff Administrative Agencies 0 Malicious Prosecution El Debt Collection: Credit Card El Board of Assessment Motor Vehicle El Debt Collection: Other F1 Board of Elections Ej Nuisance C i Dept. of Transportation © Premises Liability Statutory Appeal: Other 4 S ® Product Liability (does not include E mass tort) [3 Employment Dispute: ® Slander/Libel/ Defamation Discrimination C El Other: 13 Employment Dispute: Other Zoning Board T 0 Other: �I Ej Other: O MASS TORT 13 Asbestos N 0 Tobacco © Toxic Tort -DES Q Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS ® Toxic Waste ® Other: El Ejectment ®Common Law /Statutory Arbitration B El Eminent Domain/Condemnation © Declaratory Judgment D Ground Rent 0 Mandamus Landlord/Tenant Dispute Non - Domestic Relations ® Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABLITY © Mortgage Foreclosure: Commercial ® Quo Warranto ® Dental Partition ® Replevin © Legal ® Quiet Title :3 Other: ® Medical ® Other: ® Other Professional: Updated 1/1/2011 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FIRST FINANCIAL INVESTMENT FUND VI, LLC CIVIL ACTION 2800 N. 44th St. Phoenix, AZ 85008 Plaintiff VS. NO: C") CZ c a CHAN 1L PARK M'' - 1197 CROSS CREEK DR 7j MECHANICSBURG PA 17050 -8340_ Defendant " C - 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 to Defend 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 ON AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT REDUCED FEE OR NO FEE. MIDPENN LEGAL SERVICES 401 EAST LOUTHER STREET CARLISLE, PA 17013 717 - 243 -9400 G *l o.3. 75 pp ATry �# C2q /(a IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FIRST FINANCIAL INVESTMENT FUND VI, LLC CIVIL ACTION - 2800 N. 44th St. Phoenix, AZ 85008 Plaintiff _ vs. NO: CHAN IL PARK 1197 CROSS CREEK DR MECHANICSBURG PA 17050 -8340 Defendant COMPLAINT Plaintiff, FIRST FINANCIAL INVESTMENT FUND VI, LLC, by.and through its attorneys, Edwin A. Abrahamsen & Associates, P.C., complains of the Defendant as follows: 1. Plaintiff, FIRST FINANCIAL INVESTMENT FUND VI, LLC, (hereinafter "Plaintiff") is a corporation with a principal place of business located at 2800 N. 44th St. Phoenix, AZ 85008. 2. The Defendant CHAN IL PARK (hereinafter "Defendant ") is an adult individual residing at 1197 CROSS CREEK DR MECHANICSBURG PA 17050 -8340. 3. Defendant applied for and received a credit card issued by US BANK/SKYPASS VISA with the account number ending in 9531. 4. The within account was sold by US BANK/SKYPASS VISA to FIRST FINANCIAL INVESTMENT FUND VI, LLC for valuable consideration and all rights under said accounts were assigned to FIRST FINANCIAL INVESTMENT FUND VI, LLC. 5. Use of the US BANK/SKYPASS VISA credit card was subject to the terms and considerations of the Cardmember Agreement (hereinafter "Agreement "), a copy of which was sent to the Defendant along with the credit card. 6. _Defendant used the US BANK/SKYPASS VISA credit card account number ending in 9531, for purchases, cash advances and/or balance transfers. 7. The Defendant defaulted under the terms of the Agreement by failing and refusing to make monthly payments on the account as they became due. 8. The Defendant last made payment on August 18, 2009. 9. The total amount due and owing the Plaintiff, including interest, is $24,861.64. WHEREFORE, Plaintiff requests judgment in its favor and against Defendant in the amount of $24,861.64 plus costs of suit and any other relief as the Court deems just and appropriate. Re ectfully submitted, Mi abl ,. Ratchfor , E uire Attorney LD. Nos.: 862 5 120 N. Keyser Av Scranton, PA 18 `04 mratchford @e - law.com Phone: 800 - 503(1665 Fax: 570 -558 -5511 VERIFICATION I, Michael F. Ratchford, attorney for Plaintiff, FIRST FINANCIAL INVESTMENT FUND VI, LLC, am fully familiar with the facts set forth in the within Complaint and am authorized to make this Verification on behalf of. Plaintiff. I Verify that the facts set forth in the within allegations are true and correct to the best of my knowledge, knowing that any false statements are punishable by law pursuant to 18 C.S.A. 4904. Michael Ratchfo , E quire SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff „vo Cumber/ 1E PROTFICNO TA i\ Jody S Smith Chief Deputy 2013 JUN 20 PIS 3: 19 Richard W Stewart Solicitor e, -, ; = CUMBERLAND COUNT` PENNSYLVANIA First Financial Investment Fund VI, LLC vs. Case Number Chan IL Park 2013-3334 SHERIFF'S RETURN OF SERVICE 06/17/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Chan IL Park, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Complaint& Notice as"Not Found"at 1197 Cross Creek Drive, Hampden Township, Mechanicsburg, PA 17050-8340. This address is defendant's "rental home", deputies were informed that the defendant resides at 1327 Sugarloaf Reserve Drive, Duluth, Georgia 30097. SHERIFF COST: $39.30 SO ANSWERS, June 18, 2013 RONR ANDERSON, SHERIFF ou^4,S,Die Srt:rzh FIRST FINANCIAL INVESTMENT FUND . VI, LLC : hi the Court of Common Pleas of 2800 N. 44th St. Cumberland County,Pennsylvania Phoenix,AZ 85008 : Civil Division Plaintiff : .' • r o Vs. : C NO: 13-3334 CHAN IL PARK : < 1197 CROSS CREEK DR a MECHANICSBURG PA 17050-8340 '-�`2 Defendant : Praecipe to Reinstate Civil Complaint -' • • • • To the Prothonotary of Cumberland County Pennsylvania: Please enter the above Praecipe to Reinstate the Civil Complaint. Thank you, / àT4 M r brae . Ratc •rd,Esquire Edwin A. Abrah sen& Associates, P.C. Lawyer ID # 86,85 CS) 6Il. 74a1 ( /( 4hi 3?/O z44._ 91c, y Li SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson � c „ attic t,R Sheriff " t. { Jody S Smith ` , Chief Deputy C -2 AM 11' 'J Richard W Stewart � '9�u i�LA U COON Solicitor ' ` Y " `' ` PENNSYLVANIA First Financial Investment Fund VI, LLC vs. Case Number Chan IL Park 2013-3334 SHERIFF'S RETURN OF SERVICE 11/25/2013 05:40 PM - Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Chan IL Park, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Complaint&Notice as"Not Found" at 1197 Cross Creek Drive, Hampden Township, Mechanicsburg, PA 17050-8340. Deputies were advised by 1327 Sugarloaf Reserve Drive, Duluth, GA 30097. SHERIFF COST: $39.76 SO ANSWERS, November 26, 2013 RONNK ANDERSON, SHERIFF h rrf 7coft ■,; First Financial Investment Fund VI, LLC vs. CHAN IL PARK : In the Court of Common Pleas of Plaintiff : CUMBERLAND County, Pennsylvania : Civil Division : NO: 13-3334 Civil Term : Praecipe to Withdraw Civil Complaint Defendant : CZ> PRAECIPE TO WITHDRAW —4 To the Prothonotary of CUMBERLAND County Pennsylvania: Please enter the above Praecipe to Withdraw the Civil Complaint. Thank you, Mychael F. Ratchford, Es ire Edwin A. Abrahamsen Associates, P.C. Lawyer ID # 86285 120 N. Keyser Avenue Scranton, PA 18504 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY OFFICE OF Tki &1?SRIFF j i aw'"17y , .. III ._ ' 0 l i 1 11,1 !; it 1.5 2014 DEC 22 AM 110: C CUMBERLAN3 COUNTY PENNSYLVANIA Commonwealth of PA, Dept of Labor and Industry, to the use of the Unem Case Number vs. The Drexel Group, Inc. 2014-3334 SHERIFF'S RETURN OF SERVICE 12/18/2014 10:55 AM - William Cline, Deputy, who being duly sworn according to law, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands, possession, or control of the within named garnishee, Metro Bank, 20 Noble Boulevard, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to Nicole Erickson, Branch Manager, personally three copies of interrogatories together with three true and attested copies of the Writ of Execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on December 19, 2014 to The Drexel Group Inc., at 1832 Market Street, Camp Hill, PA 17011. LLIAM CLINE, DEPUTY SO ANSWERS, December 19, 2014 RON R ANDERSON, SHERIFF c) CountySuito Sheriff, Teleoso`t, Inc.