HomeMy WebLinkAbout04-6497
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
UNIFUND CCR PARTNERS,
Plaintiff,
CIVIL DIVISION
ARBITRATION DIVISION
No. 04 - /., l/q7 C! /(J II ~E/l... '"'l
COMPLAINT IN CIVIL ACTION
vs.
PAULA R. LAWRENCE,
Defendant.
Filed on behalf of Unifund CCR
Partners, Plaintiff
Counsel for Unifund CCR Partners:
Janelle F. Miller, Esquire
Pa.I.D.#92856
TUCKER ARENSBERG, P.C.
Firm #287
1500 One PPG Place
Pittsburgh, PA 15222
(412) 566-1212
L1T:345395-1 014636-118315
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
UNIFUND CCR PARTNERS,
Defendant.
)
)
)
)
)
)
)
)
)
No.
Plaintiff,
vs.
PAULA R. LAWRENCE,
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
(800) 990-9108
USTED DEBE LLEVAR ESTE PAPEL A SU ABOGADO ENSEGUIDA. SI USTED NO TIENE UN
ABOGADO, VA Y A 0 LLAME POR TELEFONEE LA OFICINA FIJADA AQUf ABAJO. EST A OFICINA
PUEDE PROVEERE CON INFORMACI6N DE COMO CONSEGUIR UN ABOGADO.
SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE
INFORMACI6N 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
Defendant.
)
)
)
l No. 04 -10497 GuL'1-8ul
)
)
)
)
)
UNIFUND CCR PARTNERS,
Plaintiff,
vs.
PAULA R. LAWRENCE,
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 Defendant, Paula R. Lawrence is an individual and a resident of
6203 Haymarket Way, Mechanicsburg, PA 17050.
3. On or about April 20, 1993, the Defendant applied for and was
approved to receive a First Usa Bank Credit Card (hereinafter "Account"). Such Account
was issued at Account Number 4417122292060622.
4. The Defendant utilized such Account and incurred a balance due
and owing.
5. As of March 17, 2004, the Defendant owed $6,797.35 in principal,
and $3,393.46 in interest. The total amount owed is $10,190.81. 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 Defendant has
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
Defendant:
Principal and Interest
Reasonable Attorney's Fees (20%)
TOTAL:
$10,190.81
$2.038.16
$12,228.97
9. The Account has been assigned by First USA Bank to the Plaintiff
including all rights to collect the amount due from the Defendant.
- 2-
WHEREFORE, the Plaintiff, Unifund CCR Partners demands that judgment
be entered in its behalf and against the Defendant, Paula R. Lawrence, in the sum of
$12,228.97 plus costs and interest.
TUCKERARENSBERG, P.C.
fvAlltlA Ilo..if ..
By ---r:~c:::;:;:,.;
Janelle F. MiI~
Pa.I.D.#92856
Counsel for Unifund 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, infonnation and belief and
understands the statements therein made are made subject to the penalties of 18
Pa.C.S. 94904 relating to unsworn falsification to authorities.
- C~~
Christina M.~~n
Unifund CCR Partners
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 Paula R Lawrence, Account Number 4417122292060622, the amount of
$10190.81 (principal balance in the amount of$6797.35 plus interest up through 03/17/2004 in the amount
of $3393.46). By the terms of the agreement between the defendant and the original creditor, interest is
accruing from the aforesaid date at the rate of23.74 percent per annum. This balance reflects any payments,
credits or offsets made since the account was charged off.
This account was originated with FIRST USA BANK. Unifund CCR Partners purchased this account from
FIRST USA BANK. Said account has been assigned, transferred and set over unto, Tucker Arensberg with
full power and authority to do and perform all acts necessary for the collection, settlement, adjustment,
compromise or satisfaction of said claim, on behalf ofUnifund CCR Partners.
DATED this March 1 2004
I
By: Jessica Bergholz
Media Supervisor
10625 Techwood,is Circle Cincinnati, OH 45242
1 Address
Subscribed and sworn to befo I me this 12day of March, 2004
(1// Year
Notary Public
My commission Expires
Client # 215
:(~Te ...
\. '"aH. j~uw." '} <
'~Tll!' CW oP',.;'"
''''''''".ttfi$~
, <. ..,':? :~:;:..'i~
· i' LG :d,i) :';oiCW EXPiRES' ;;IA~C~~:J2007
1= p "6<;t. """
i ~ (") .:= 0
C c;::> -n
~~;, .s:-
O -4
rrt ~::o
~ C) (""'") r-
9-J ~r:~ ('J -c' i'n
CO :rj9 8
f'- ~u S~O
~ ~ ~ 'E:c' "'U :.1= =n
~ ~...t ::Jt ~,1o
~ ...- ( ) 6rn
---.J >"C~, -
z .. :~
~ =< .r;:- :Xl
N ;....:.
F
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
UNIFUND CCR PARTNERS,
CIVIL DIVISION
ARBITRATION DIVISION
Plaintiff,
No. 04-6497 CIVIL TERM
vs.
TEN DAY NOTICE
PAULA R. LAWRENCE,
Defendant.
Filed on behalf of Unifund CCR
Partners, Plaintiff
Counsel for Unifund CCR Partners:
Janelle F. Miller, Esquire
Pa. I.D. #'92856
TUCKER ARENSBERG, P.C.
Firm #28i'
1500 One, PPG Place
Pittsburgh, PA 15222
(412) 566-1212
L1T:349428-1014636-118315
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Defendant.
) CIVIL DIVISION
) ARBITRATION DIVISION
)
) No. 04-6497 CIVIL TERM
)
)
)
)
)
UNIFUND CCR PARTNERS,
Plaintiff,
V5.
PAULA R. LAWRENCE,
TO: Paula R. Lawrence
6203 Haymarket Way
Mechanicsburg, PA 17050
DATE OF NOTICE: January 25, 2005
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
, hMLPl1~
~iller, Esquire
Pa.I.D.#92856
Counsel for Plaintiff
TUCKERARENSBERG, P.C.
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 January 25, 2005:
Paula R. Lawrence
6203 Haymarket Way
Mechanicsburg, PA 17050
C)MvJ7k~~
Janelle F. Miller, Esquire
Pa. I.D. ;/1'92856
TUCKER ARENSBERG, P.C.
1500 One PPG Place
Pittsburgh, PA 15222
~>
c,::?
~;._-,~)
(J'l
,-
:C...
~
"')
0)
:J:
r:,,?
C"1
CD
n
-n
-.,
~T-
h1plJ
n'
(:J
,
C>
~T'~
()
;n
SHERIFF'S RETURN - REGULAR
CASE NO: 2004-06497 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
UNIFUND CCR PARTNERS
VS
LAWRENCE PAULA R
HAROLD WEARY
, Sheriff or Deputy Sheriff of
Cumberland County, pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE
LAWRENCE PAULA R
was served upon
the
DEFENDANT
at 2036:00 HOURS, on the 4th day of January
2005
at 6203 HAYMARKET WAY
MECHANICSBURG, PA 17050
PAULA R LAWRENCE
by handing to
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
Service
Affidavit
Surcharge
18.00
7.40
.00
10.00
.00
35.40
Sworn and Subscribed to before
me this .2'1 '" day of
C}",... " } ,2IJ7J"- A.D.
l ) .t..<-- (}.~1" dw-:
II Prothonotary I -r-1
So Answers:
.~~~f-<(~~
,
R. Thomas Kline
01/05/2005
TUCKER ARENSBERG
By:
?~~ ~~
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
UNIFUND CCR PARTNERS,
CIVIL DIVISION
ARBITRATION DIVISION
Plaintiff,
No. 04-6497 CIVIL TERM
PRAECIPE FOR ENTRY OF DEFAULT
JUDGMENT
vs.
PAULA R LAWRENCE,
Defendant.
Filed on behalf of Unifund CCR
Partners, Plaintiff
Counsel for Unifund CCR Partners:
Janelle F. Miller, Esquire
Pa.I.D.#92856
TUCKERARENSBERG,P.C.
Firm #287
1500 One PPG Place
Pittsburgh, PA 15222
(412) 566-1212
L1T:352830-1014636.118315
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
UNIFUND CCR PARTNERS,
Plaintiff,
)
)
)
)
)
)
)
)
)
No. 04-6497 CIVIL TERM
vs.
PAULA R. LAWRENCE,
Defendant.
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 $12,228.97 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: February 24, 2005
~/T~
By:. '* A
Janelle F. Miller, Esquire
Pa.I.D.#92856
Counsel 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. 04-6497 CIVIL TERM
vs.
TEN DAY NOTICE
PAULA R. LAWRENCE,
Defendant.
Filed on behalf of Unifund CCBj
Partners, Plaintiff
Counsel for Unifund CCR Partners:
Janelle F. Miller, Esquire
Pa.I.D.#92856
TUCKER ARENSBERG, P.C.
Firm #287
1500 One PPG Place
Pittsburgh, PA 15222
(412) 566-1212
L1T:349428-1014636-118315
C)
'"',
':'::,')
:;;l
en
,-
~.::
..iL~
N
0)
1);-)
cr;
co
.
.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Defendant.
) CIVIL DIVISION
) ARBITRATION DIVISION
)
) No. 04-6497 CIVIL TERM
)
)
)
)
)
UNIFUND CCR PARTNERS,
Plaintiff,
vs.
PAULA R. LAWRENCE,
TO: Paula R. Lawrence
6203 Haymarket Way
Mechanicsburg, PA 17050
DATE OF NOTICE: January 25, 2005
IMPORT ANT 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
~~
J nelle F. Miller, Esquire
Pa. 1.0. #92856
Counsel for Plaintiff
TUCKER ARENS BERG, P.C.
1500 One PPG Pi ace
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 January 25, 2005:
Paula R. Lawrence
6203 Haymarket Way
Mechanicsburg, PA 17050
~~~
Janelle F. Miller, Esquire
Pa. 1.0. #92856
TUCKER ARENSBERG, P.C.
1500 One PPG Place
Pittsburgh, PA 15222
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
UNIFUND CCR PARTNERS,
Plaintiff,
)
)
)
)
)
)
)
)
)
No. 04-6497 CIVIL TERM
vs.
PAULA R. LAWRENCE,
Defendant.
NOTICE OF JUDGMENT
To: Paula R. Lawrence
6203 Haymarket Way
Mechanicsburg, PA 17050
You are hereby notified that a judgment was entered against you and in favor of
Plaintiff in the above-captioned proceeding on ~,~ ,..)) J.('A. \' . The
(
default judgment is in the amount of $12,228.97 plus costs of suit.
'-------' a()~ 0 ~r) 71z-/{ /7/5, /
Deputy
(";;dP ~
~ ~ 7i \)
R _ ~ \))
Ii;"" ::2 ~
~ ?: ~ P-
~ v Z; :t:?
r ,~
-..
(
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
UNIFUND CCR PARTNERS,
CIVIL DIVISION
ARBITRATION DIVISION
Plaintiff,
No. 04-6497 CIVIL TERM
vs.
PRAECIPE TO SETTLE
AND DISCONTINUE
PAULA R. LAWRENCE,
Defendant.
Filed on behalf of Unifund CCR
Partners, Plaintiff
Counsel for Unifund CCR Partners:
Janelle F. Miller, Esquire
Pa.I.D.#92856
TUCKER ARENSBERG, P.C.
Firm #287
1500 One PPG Place
Pittsburgh, PA 15222
(412) 566-1212
L1T:361946-1014636.118315
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
UNIFUND CCR PARTNERS,
Plaintiff,
)
)
)
)
) No. 04-6497 CIVIL TERM
)
)
)
)
)
)
vs.
PAULA R. LAWRENCE,
Defendant
PRAECIPE TO SETTLE AND DISCONTINUE
To: Prothonotary
Kindly settle and discontinue this matter.
TUCKER ARENSBERG, P.C.
BY~~
Pa.I.O.#92856
Counsel for Unifund CCR Partners:
TUCKER ARENSBERG, P.C.
1500 One PPG Place
Pittsburgh, PA 15222
Attorneys for Plaintiff
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the within Praecipe to Settle
and Discontinue was served on the following by first class mail, postage pre-paid on
this J
day of June, 2005.
Paula R Lawrence
6203 Haymarket Way
Mechanicsburg, PA 17050
~~~te~
Janelle F. Miller
(') ,.., 0
-=
c: = "1'
?;: cJ' -I
~U" <- ::t:-n
(r c:: rnF:
-:;1'''.... --
.t.:-- .~,-: - ~m
zr.' I
(f)): .<~
-<.;:- W QlT
<<:1:. -0 ::r!'~
?Zc 0--'
::II: -;(~
-"n "',..r
):> c: .:;- 9
~ 0 ;s;
.- .<