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Home My WebLink About05-2560 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CACV OF COLORADO Plaintiff No: 05 - ,;)51..6 ClU{~ffl-Vlj vs. COMPLAINT IN CIVIL ACTION ROBERT S COVER Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt WELTMAN, WEINBERG & REIS CO., L.P.A. 436 Seventh Avenue, Suite 2718 Pittsburgh, PA 15219 (412) 434-7955 FAX: 412-338-7130 04180173 CEPit SES IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CACV OF COLORADO vs. Civil Action No 05' - ~Sl..b Cru,ll0ov Plaintiff ROBERT S COVER 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 . COMPLAINT 1. Plaintiff, CACV OF COLORADO is a corporation with offices at 370 17TH ST. ,SUITE 5000 DENVER, CO 80202 . 2. Defendant is an adult individual(s) residing at the address listed below: ROBERT S COVER 6204 PAXTON RUN RD SHIPPENSBURG, PA 17257 3. Defendant applied for and received a credit card bearing the account number 5458001410019461 . 4. Defendant made use of said credit card and has a current balance due of $11760.41 , as of April 05, 2005 . 5. Defendant is in default by failing to make monthly payments when due. As such, the entire balance is immediately due and payable to Plaintiff. 6. Plaintiff is entitled to the addition of interest at the rate of 6.000% per annum on the unpaid balance from April 05, 2005 . A copy of Plaintiff's statement is attached hereto, marked as Exhibit "1" and made a part hereof. 7. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed and/or refused to pay the balance due to Plaintiff. Wherefore, the Plaintiff prays for judgment in its favor and against Defendant , ROBERT seaVER , individually in the amount of $11760.41 with continuing interest thereon at the rate of 6.000% per annum from April 05, 2005 plus costs. This law firm is a debt collector at mpting to collect this debt for our client and any information obtained will be used for that purpose. . Warmbrodt , WEINBERG & REIS CO., L.P.A. enth Avenue, Suite 2718 ts rgh, PA 15219 2) 434-7955 : 412-338-7130 1 0173 CEPit SES j\ ,I ((" [) l-1 / 1'73 1 DIRECT MERCHANTS CREDIT CARD BANK LAST STATEMENT DETAILS ACCOUNT# 5458001410019461 COVER . ROBERT S 6204 PAXTON RUN RD SHIPPENSBURG . PA 1725791]8 DATEOF LAST STATEMENT DATE OF PREVIOUS STATEMENT LAST ST A YEMENT fEES CREDIT LINE A V ALABLE BALANCE 23JUL2003 23JUN2003 $0.00 " $9.800.00 NONE LAST STATEMENT BALANCE $11,760Al PREVIOUS STATEMENT BALANCE $\1.760.4\ FEE BALANCE $2.234.4] MERCHANT BALANCE" $7.676.00 CASH BALANCE "51.850.00 MERCHANDISE APR: 25.49% CASH APR : 29.491'/0 ACCOUNT# : 5458001410019461 LAsrSTATEMENTBALANCE: $11.760.41 OVER LIMIT AMOUNT $\,960.41 EXHIBIT .r111 VERIFICATION The undersigned does hereby verify subject to the penalties of 18 P A. C.S. 4904 relating to unsworn falsifications to authorities, that he/she is :::r;t..v B,clLt.,r (NAME) fJ'./ Aa(!u(~Tfit,I-;"''- of c;/!..,j ilmNr,,,- , plaintiff herein, that (COMP ANY) he/she is duly authorized to make this verification, and that the facts set forth in the foregoing Complaint are true and correct to the best of his/her knowledge, information and belief. 9'w 8ui2- (SIGNA TURE) WWR# 04180173 p ~ t:J U\. 8 "- VI r;;; ~- \\:- ~i <..:..:-< -,1 \J\ t;.!'l "-"~ ~ ~', - ~ ~ ~ --~ ~ ~ C'} CY ~ P- -t'" . 1:'- t:? - ~ (..,,) --- . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CACV OF COLORADO, Plaintiff No. 05-2560 CIVIL TERM vs. PRAECIPE TO SETTLE, DISCONTINUE AND END WITHOUT PREJUDICE TO REFILE ROBERT S COVER, Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt PA I.D#42524 WELTMAN, WEINBERG & REIS CO. LPA 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#04180173 . IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CACV OF COLORADO, Plaintiff vs. Civil Action No. 05-2560 CIVIL TERM ROBERT S COVER, Defendant PRAECIPE TO SETTLE. DISCONTINUE AND END WITHOUT PREJUDICE TO REFILE TO THE PROTHONOTARY OF CUMBERLAND COUNTY SIR: Settle, Discontinue and End the above-captioned matter upon the records of the Court without prejudice to refile and mark the costs paid. WELTMAN, WEINBERG & REIS CO, L.PA SWORN TO AND Sl{!lS.GRIBED befo~e m this ( ") day ..,I V of , 2005 N . /,/ '~''iiOt~,,, ,;'j!, '.J:)" '"J "', 0:':".::> < ;;~., (:.;1 '~ .-1 :r; ". c'; -1-; '-.) u, ('".:)