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Home My WebLink About14-0768 09823751 C A Pit ABR Supreme Court; �v��R # Cou 'of Comon ;P.leas 1 Clvil�Cover,rSheet• ForProthowlaq• Use Onlp: f, C UMBERLAND! ,,i Count. Docket No: u. " G The information collected on this form is used solely for court administration purposes. This Jorrn does not supplement or replace the filing and service ofpleadings or other papers as required by /oil. or rules of court. Commencement of Action: S M Complaint ❑ Writ of Summons ❑ Petition E Transfer from Another Jurisdiction 13 eclaration of Takin C Lead Plaintiff's Name: Lead Defendant's Name: T MIDLAND FUNDING LLC MELANIE COOK I C Are money damages requested? 1l Yes ❑ No Dollar Amount Requested: ® within arbitration limits N (check one) ❑ outside arbitration limits A Is this a Class Action Suit? 13 Yes 13 No Is this an MDJ Appeal? 13 Yes Ea No Name of Plaintiff /Appellant's Attorney: William T. Molczan,47437 ❑ Check here if you have no attorney (are a Self- Represented [Pro 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. TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS ❑ Intentional ❑ Buyer Protection Administrative Agencies • Malicious Prosecution Tom, Debt Collection: Credit Card ❑ Board of Assessment • Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections ❑ Nuisance ❑ Dept. of Transportation S ❑ Premises Liability ❑ Statutory Appeal: Other E [3 Product Liability (does not include [3 Employment Dispute Mass tort) Discrimination C ❑ Slander/Libel/Defamation ❑ Employment Dispute: Other ❑ Zoning Board T ❑ Other: ❑ Other: I ❑ Other: O N MASS TORT ❑ Asbestos B ❑ Tobacco REAL PROPERTY MISCELLANEOUS ❑ Toxic Tort - DES ❑ Ejectment ❑ Common Law /Statutory Arbitration • Toxic Tort — Implant ❑ Eminent Domain/Condemnation ❑ Declaratory Judgment • Toxic Waste ❑ Ground Rent ❑ Mandamus ❑ Other: ❑ Landlord/Tenant Dispute ❑ Non - Domestic Relations ❑ Mortgage Foreclosure: Residential Retraining Order ❑ Mortgage Foreclosure: Commercial ❑ Quo Waranto ❑ Partition ❑ Replevin PROFESSIONAL LIABILITY ❑ Quiet Title ❑ Other: ❑ Dental Cl Other: ❑ Legal ❑ Medical ❑ Other Professional: Updated 1/1/2011 : r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION MIDLAND FUNDING LLC Plaintiff No. vs. COMPLAINT IN CIVIL ACTION MELANIE COOK Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan, Esquire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434 -7955 M W rr WWR #09823751 �� o — r N) S 7� //'y 7vj /Z 50 i IN THE COURT OF COMMON.PLEAS.OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION MIDLAND FUNDING LLC Plaintiff VS. Civil Action No MELANIE COOK Defendant COMPLAINT 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 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� records show that the Defendant(s) MELANIE COOK is/ are individual(s) residing at 3 VALLEY VIEW DR, MECHANICSBURG, PA 17050 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 Defendant1s WELLS. FARGO BANK, N.A. account XXXXXXXXXXXX5648 (hereinafter "the account "). Midland Credit Management, Inc. (hereinafter "MCM ") services the account on behalf of Plaintiff. 5. MCM� records state that this action is based upon a credit agreement entered into between defendant(s) and the original credit grantor. MCM� 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� records show that the defendant(s) owed a balance of $3295.05 as of 2012- 04 -30. 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 $3295.05, together with interest and costs. By Weltman, Weinberg Reis, Co., LPA Attorney for Plaintiff Page - 1 8551936708 AFFINDEBTMEDIA 09823751 Return Mail Only - No Correspondence M PO Box 603 Oaks. PA 19456 - ---- -- IIIIIIIIIIIIIIII�llllllllllllllllllllllllllllllllllllllllllllllllllllllllllllllll IIIII MCM Account Number 6708 Ori ginal Creditor WELLS FARGO BANK, N.A. CURRENT BALANCE 07- 01.2012 $3,366.57 1662 E976 #BWNHLTH PAYMENT DUE DATE #0000 0 6 7081# 08 -15 -2012 MELANIE G COOK 3 VALLEY VIEW DR MECHANICSBURG, PA 17050 -1537 III Ii 1111111111 t111I11111t111I11111111I It II /11111111111111 /111 NOTICE OF NEW OWNERSHIP AND PRE -LEGAL REVIEW Dear MELANIE G COOK, BENEFITS OF PAYINGI Midland Funding LLC recently purchased your WELLS FARGO BANK. N.A. — account and Midland Credit Management, Inc. ( "MCM "), a debt collection ➢ This may be your last company, is the servicer of this obligation. chance to work with us before the account goes Midland Credit Management, Inc. is considering forwarding this account to an to an attorney. attorney in your state for possible litigation. However, such forwarding will not occur until after the expiration of the time period described an the back of the > No additional interest letter. Upon receipt of this notice please call to discuss your options. will be charged to your account. If we don't hear from you or receive payment by 08 -15 -2012, we may proceed ➢ Get rid of this debt and with forwarding this account to an attorney. get on with your life. What do you need to do to stop this process from continuing? Once your account is paid, 1) Mail in $500.00 and call to set up your remaining payments. 2) Call us today to see how to qualify for discounts and payment plans. 3. All collection calls and letters on Nils account will LET US HELP YOUI If the account goes to an attorney, our flexible options stopl may no longer be available to you. There still is an opportunity to make r We will notify the credit arrangements with us. We encourage you to call us today: (800) 265 -8825. bureaus the debt Is PAID Sincerely; IN FULL' Recovery Department Midland Credit Management, Inc. CALL USTODAYI (800) 265 -8825 (800) 265 - 8825 For ease and convenience, make payments online and view additional offers at: www.midlandcreditonline.com Hours of Operation: M-Th Sam - 7:30pm Fri Sam - 5pm; NOTICE: PLEASE SEE REVERSE SIDE FOR IMPORTANT DISCLOSURE INFORMATION Sat Sam - 11 am Mountain Time Please fear off and retum lower portion with payment in the envelope provided PAYMENT COUP ON Make check payable to: MCM Account No.: 6708 Midland Credit Management, Inc. Original t No.. 15648 EXHIBIT Current B alanc e: $3,366.57 Payment Due Date: 08 -15 -2012 Amount Enclosed: , .. 9823751 R1C m Midland Credit Management, Inc. P.O. Box 60578 Los Angeles, CA 90060 -0578 1111111111tllllllllllllt11111tt t11111,1111t1,11111111111111t1 12 X708 1 0336657 081512 3 I gild u lilt Ilia leg 11111111111011141111111111111111111 Important Disclosure Information Please understand this is a communication from a debt collector. This is an attempt to collect a debt. Any information obtained will be used for that purpose. Calls to and/or from this company may be monitored or recorded. The records associated with the purchase from WELLS FARGO BANK, N.A. reflect that you are obligated on this account, which is in default. As of the date of this letter, you owe $3,366.57. Because of interest, late charges, and other charges that may vary from day to day, the amount due on the day you pay may be greater. To obtain an exact payoff amount, or for further information, please call one of our Account Managers at (800) 265 -8825. As the owner of this account, but subject to the rights described below, Midland Funding LLC is entitled to payment of this account. All communication regarding this account should be addressed to MCM and not the previous owner. Unless you notify MCM within thirty (30) days after receiving this notice that you dispute the validity of the debt, or any portion thereof, MCM will assume this debt to be valid. If you notify MCM, in writing, within thirty (30) days after receiving this notice that the debt, or any portion thereof, is disputed, MCM will obtain verification of the debt or a copy of a judgment (if there is a judgment) and MCM will mail you a copy of such verification or judgment. Communications concerning disputed debts, including an instrument tendered as full satisfaction of a debt, are to be sent to 8875 Aero Drive, Suite 200, San Diego, CA 92123; Attn: Consumer Support Services. If you request, in writing, within thirty (30) days after receiving this notice, MCM will provide you with the name and address of the original creditor. If an attorney represents you with regard to this debt, please refer this letter to your attorney. Likewise, if you are involved in an active bankruptcy case, or if this debt has been discharged in a bankruptcy case, please refer this letter to your bankruptcy attorney so that we may be notified. Please remember, even if you make a payment within 30 days after receiving this notice, you still have the remainder of the 30 days to exercise the rights described above. "You are hereby notified that a negative credit report reflecting on your credit record may be submitted to a credit reporting agency if you fail to fulfill the terms of your credit obligations. Please send any correspondence relating to any credit reporting" of this account to: MCM CREDIT REPORTING DEPARTMENT. 8875 Aero Drive, Suite 200, San Diego CA 92123. PLEASE RETAIN THIS ADDRESS FOR ANY ISSUES RELATING SOLELY TO THE CREDIT REPORTING OF YOUR ACCOUNT. MAIL PAYMENTS TO : P.O. Box 60578, Los Angeles, CA 90060 -0578 MAIL CORRESPONDENCE BUT NO PAYMENTS TO: MGM's business address at 8875 Aero Drive, Suite 200, San Diego, CA 92123 9823751 1 Return Mail Mail O nly - No Correspondence Dept 12421 PO Box 603 Oaks, PA 19456 #BWNHLTH #0000 C: 6 7051# MELANIE G COOK 3 VALLEY VIEW DR MECHANICSBURG. PA 17050 -1537 STATEMENT MCM Account*', X708 Previous Balance: $3,295.05 Original Account #. ;5648 nteres ate: 12.9% Statement Date: 07 -01 -2012 Due Date; 08 -15 -2012 c ad interest: $71.52 Current Owner: Original Creditor: WELLS FARGO BANK N.A. Current Balance: Midland Funding LLC $3,366.57 Due Date Date Received Transactions Amount 08 -15 -2012 07 -01 -2012 The above- referenced account was purchased by $3,366.57 Midland Funding LLC and is serviced by Midland Credit Management, Inc.( "MCM "). The balance of $3,366.57 is due by 08 -15 -2012. Please direct all correspondence to: Midland Credit Management, Inc. 8875 Aero Drive, Suite 200 San Diego, CA 92123 Currant Balance: $3 Please understand this is a communication from a debt collector. This is an attempt to collect a debt. Any information obtained will be used for that purpose, 9823751 1604 - LTty M-8 1 11161 pl I61 x16161 �1�11� 1111161 Ilip IIII ICI Verification Molly Kampa, 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 r penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. - JUL 2 3 2011 Date Molly Kampa OH 14 Weltman, Weinberg & Reis. Co., L.P.A Page - 2 I�IIIIIIIIII I�I�II�IIIIII III�I�I� I�II�IIIIIIII��III�I�IIII IIIIII�I @IIII� III 111111 I�IIIII�IIII ��IIIIIIIIII��I 8551936708 AFFINDEBTMEDIA 09823751 WELTMAN, WEINBERG & REIS CO., L.P.A. BY: William T. Molczan I.D. No. 47437 436 7th Ave Ste 1400 Pittsburgh, PA 15219 Phone: (412) 434-7955 Fax: (412) 338-7130 File # 9823751 WTM/ABR C-3 rr` Attorney for Plaintiff rn- (51 5� `o �� { () MIDLAND FUNDING LLC vs. MELANIE COOK Cumberland County Court of Common Pleas No.: 14-768 CIVIL TERM PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss the above matter without prejudice . WELTMAN, WEINBERG & REIS CO., L.P.A. By William T. Molczan, E ; ire Attorney for Plaintiff 11111111111111111 1111111111111111111111111 IIIII 11111 11111 1111 IIIII 1111