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Home My WebLink About05-1258IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA UNIFUND CCR PARTNERS, Plaintiff, vs. CINDI REESE, Defendant. CIVIL DIVISION ARBITRATION DIVISION No. US -1d 5p et (-; COMPLAINT IN CIVIL ACTION 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 LIT316033-1 014636-115930 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA UNIFUND CCR PARTNERS, Plaintiff, ) vs. j No. OS -/?s? ?cv ?? CINDI REESE, ) Defendant. ) 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 LISTED DEBE LLEVAR ESTE PAPEL A SU ABOGADO ENSEGUIDA. SI LISTED NO TIENE UN ABOGADO, VAYA O LLAME FOR TELEFONEE LA OFICINA FIJADA AQUI ABAJO. ESTA OFICINA PUEDE PROVEERE CON INFORMACION DE COMO CONSEGUIR UN ABOGADO. SI LISTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE INFORMACION ACERAAGENCIAS. QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (800) 990-9108 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA UNIFUND CCR PARTNERS, Plaintiff, vs. No. OS - / 2S?P CINDI REESE, Defendant. 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, Cindi Reese is an individual and resident of 885 Old Silver Spring Road, Mechanicsburg, PA 17055. 3. On or about November 10, 1997, the Defendant applied for and was approved to receive a Citibank Universal Card Svcs Credit Card (hereinafter "Account'). Such Account was issued at Account Number 5396119020104856. 4. The Defendant utilized such Account and incurred a balance due and owing. 5. As of September 5, 2003, the Defendant owed $6,238.80 in principal, and $1,104.91 in interest. The total amount owed is $7,343.71. 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 $7,343.71 Reasonable Attorney's Fees (20%) $1,468.74 TOTAL: $8,812.45 9. The Account has been assigned by Citibank Universal Card Svcs to the Plaintiff including all rights to collect the amount due from the Defendant. WHEREFORE, the Plaintiff, Unifund CCR Partners demands that judgment be entered in its behalf and against the Defendant, Cindi Reese, in the sum of $8,812.45 plus costs and interest. TUCKER ARENSBERG, P.C. By LjMgikj?, %& anelle F. Miller, quire Pa. I.D. #92856 Counsel for Unifund CCR Partners: TUCKER ARENSBERG, P.C. 1500 One PPG Place Pittsburgh, PA 15222 Attorneys for Plaintiff VERIFICATION The undersigned verifies that the statements made in the foregoing Complaint are true and correct to the best of her knowledge, information and belief and understands the statements therein made are made subject to the penalties of 18 Pa.C.S. §4904 relating to unswom falsification to authorities. C/7? Christina M. Biyan Unifund CCR Partners 0 AFFIDAVIT OF INDEBTEDNESS 0 State of Ohio ) County Of Hamilton ) ss. Jessica Bergholz, being sworn, deposes and says that she is Media Supervisor of Unifund CCR Partners herein called assignor, 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 CINDI REESE, Account Number 5396119020104856,the amount of $7343.71 (principal balance in the amount of $6238.80 plus interest up through 09105/2003 in the amount of $1104.91). By the terms of the agreement between the defendant and the original creditor, interest is accruing from the aforesaid date at the rate of 6.00 percent per annum. This account was originated with Citibank Universal Card Svcs. Unifund CCR Partners purchased this account from Citibank Universal Card Svcs. 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. DATED 05 September 2003 f UNIFIJ DS', ARTNERS By: Jessica Berohollzr?Media Supervisor Title 10625 Techwoods Circle Cincinnati, OH 45242 Address Subscribed and sworn to before me this 5 day of September 2003 Notary Public Client # 215 My commision expires AUTUMN HOPKINS, Notary Public A, in and fer the Slate of Ohio Nv C rr r:i s;on Expires July 18, 20( SHERIFF'S RETURN - REGULAR CASE NO: 2005-01258 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND UNIFUND CCR PARTNERS VS REESE CINDI GERALD WORTHINGTON , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according says, the within COMPLAINT & NOTICE was served upon REESE CINDI t DEFENDANT , at 1539:00 HOURS, on the 17th day of at 885 OLD SILVER SPRING ROAD MECHANICSBURG, PA 17055 CINDI REESE by handing to a true and attested copy of COMPLAINT & NOTICE Ito law, 2005 together with and at the same time directing Her attention to the contents thlereof. Sheriff's Costs: Docketing 18.00 Service 7.40 Affidavit .00 Surcharge 10.00 .00 35.40 Sworn and Subscribed to before meethis la {( day of So Answers: R. Thomas Kline 03/18/2005 TUCKER ARENSBERG By: 1, A Curtis R. Long Prothonotary Off ire of the Vrotbonotarp Cumberrantl Countp Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor -OS ? / 2,,,5'e-CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 29TH DAY OF OCTOBER 2008 AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA RCP230.2 BY THE COURT, CURTIS R. LONG PROTHONOTARY One Courthouse Square • Carlisle, Pennsylvania 17013 • (717) 240-6195 9 Fax (717) 240-657-1