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Home My WebLink About05-3947 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CACV OF COLORADO, LLC Plaintiff No. or - JCl'-l7 Clu'L ~82-Yl\ vs. COMPLAINT IN CIVIL ACTION DENNIS HAGERICH Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warm brodt, Esquire P A J.D. #42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, P A 15219 (412) 434-7955 WWR#04180280 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CACV OF COLORADO, LLC Plaintiff vs. Civil Action No. DENNIS HAGERICH Defendant COMPLAINT IN CIVIL ACTION 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 SIIOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HA VE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP LA WYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, P A 17013 (717) 249-3166 COMPLAINT PlaintilI is a corporation with offices in 370 17th Street, Suite 5000, Denver, CO 80202. I. 2. 17050. Defendant is an adult individual residing at 6167 Haymarket Way, Mechanicsburg, PA 3. Defcndant applied for and received a credit card issued by Plaintiff bearing the account number 4326820352138192. 4. Defendant madc use of said credit card and has currently a balance due and owing to Plaintiff, as of July 14,2005, in the amount of $2,381.96. A true and correct copy of Plaintiff' s Statement of Account is attached hereto, marked as Exhibit "I " and made a part hereof. 5. Delendant is in default of the tenns ofthc cardholder Agreement having not made monthly payments to Plaintiffthercby rendering the cntire balance immediately due and payable. 6. PlaintitI is entitled to the addition of interest at the statutory rate of 6% pcr annum on thc unpaid balance. 7. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failcd and/or refused to pay thc principal balance, interest or any part thcreof to Plaintiff. WHEREFORE, Plaintiff demands Judgment in its favor and against Defendant, Dennis Hagerich individually, in the amount of $2,38] .96 with interest at the statutory rate of 6% per annum from date of judgment plus costs. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED SHALL BE USED FOR THAT PURPOSE. WELTMAN, WEINBERG & REIS, CO., L.P.A. WWR#:04180280 "- Fleet 1'O....f'M~ ::W:;.DE __43261l203 5213 8192 .00 ~.... $0.00 AUG. 25. 2004 fQracccult/nlblll'8lDllClll: e.....-~..HIQG.4t2-21OO orlOClOllIll hUp:Am/CWd.fIeIlt.COn1 'Rlr~otlll:lrt$S~USI!tllftU(II.1a:k. . Mbdllldl:PMiWeIllFleeCe"-tc:ardStfVIcY. ......c...-c_.... -- WUMIC"_~ H9''&65~6a6821 _JHMIBH --- ~-"'~ !l70S0S2J6678! 4326820352138192 0000000 0000000 DIlEhlt~VlIIl'IIWI\fDfmllblrtlllWOl~ ACCOUNT QlMIMRY FOR DENNIS J HAGERICH .........- 4526 8203 5213 8192 C) Fleet $2,:!81.96 1,954.07 . 0.00 . 0.00 . 0.00 $0.00 $0.00 $319.00 $0.00 $0.00 AUG. 25, 2004 TOIIIcrecntUmlt: $2.000.00 Cam AdYlnCeUmlt: $1,000.00 BUllngCydeaoslrlUD_ 07J2SA)4 AvallablecreGlt: $).00 CUhAcMI1CeAVlIiIIeJe:$O.OO DaYslnBWfngCyde: 50 A RECORD OF '10\12 CHAROES AND CIIEDfTS TfIIflSlIC:fioo~ ~ oats Od Num/)ef ~~ CrrIdIIs ChIrgfS 0749 0749 I'51tQQ01f~ !Il!all 0\ARtI; OfJ:ACCOUNT.p"IIIlCflALS 0749 0741 FS'l9OllOKJOO9SS190 CtWtGE 0PfI AttOUNT '"fUWIC! tMARCES" ..._..___...........c__ 1-8>>412-2500 -- PO ISOX 15480 W1LMINOTON DE 1!18Sg.548tl 1.954.07 471.B9 ANNUAL PERCEflfAGE RATE 1OfIllfthWeslllCibllanCetrlnlflllllndtldesanvtlWlC8t/l1rU11fetS):2U90% ANNUAL. PeRCENTACE RATE ftlI'CldhlllMl""'<Jnc:ludlsiniftnlMed'8f;e'feelk24.99O% W'lOU.....'\IIJlalH,.aecCXl~ VOWI*fCdC"'II'DVWlry. 5!i1! REVPSI! S1D1 ~ IMPCIITAfIi/l' INFOIIIIlATION 5'11 0000 IIml :Xf'.oelofl lUD 0100 H,02 Oloc5311 253401 n !> 11 Ofornn t) L-/( t () ;) CjD 253401 EXHIBIT /'1" .- 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 BethO-r\ lA G-le..p\1.e.YS (NAME) of CPeJJ of Coloat-do . plaintiff herein, that (COMPANY) he/she is duly autllodzed 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. ~~s\E~ WWR#04180280 \J ~ 1- " ~ 8 ~ U( - )-.J r-' c~) 6"- () (2 r---' -r1 c:;:-" Q'" (.;..'-1 .-\ ~ () F! "C t;~1 D ~ V- I .I::. \'.) - lFt ~ ~<" .. - .>: .- .. ~ ", SHERIFF'S RETURN - REGULAR CASE NO: 2005-03947 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CACV OF COLORADO LLC VS HAGERICH DENNIS DAVID MCKINNEY Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within NOTICE was served upon HAGERICH DENNIS the DEFENDANT , at 0019:56 HOURS, on the 5th day of August 2005 at 6167 HAYMARKET WAY MECHANICSBURG, PA 17050 by handing to DENNIS HARGERICH a true and attested copy of NOTICE together with COMPLAINT and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 9.60 .00 10.00 .00 37.60 rq~ l-t:~~ R. Thomas Kline 08/08/2005 WELTMAN, WEINBERG & REIS Sworn and Subscribed to before By: 0/ ~.~ ' Deputy ~ J.ff" '7'" 7 /} ':l. f\P me this 4~ day of "U~ a;; AD ~~~ ar IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CACV OF COLORADO, LLC Plaintiff No 05-3947.CIVIL TERM vs, PRAECIPE FOR DEFAULT JUDGMENT DENNIS HAG ERICH Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY William T, Molczan PA I.D, #47437 WELTMAN, WEINBERG & REIS CO, LPA 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#04180280 Judgment Amount $ 2,381,96 THIS LAW FIRM IS ATTEMPTING TO COLLECT THIS DEBT FOR ITS CLIENT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CACV OF COLORADO, LLC Plaintiff vs, Civil Action No 05-3947-CIVIL TERM DENNIS HAGERICH Defendant PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter Judgment against the Defendant, DENNIS HAGERICH above named, in the default of an Answer, in the amount of $2,381,96 computed as follows: Amount claimed in Complaint $2,381.96 Interest from date of judgment at the legal interest rate of 6% $0,00 TOTAL $2,381,96 I hereby certify that appropriate Notices of Default, as attached have been mailed in accordance with PA R.C,P. 2371 on the dates indicated on the Notices WELTMAN, WEINBERG & REIS CO, LPA ',~//. By , #~ William T, Molczan PA I.D, #47437 WELTMAN, WEINBERG & REIS CO, LPA 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#04180280 Plaintiff's address is: clo Weltman, Weinberg & Reis Co" L,PA, 2718 Koppers Building, 436 7'h Avenue, Pittsburgh, PA 15219 And that the last known address of the Defendant is: 6167 HAYMARKET WAY, MECHANICSBURG,PA 17050 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CACV OF COLORADO, LLC Plaintiff vs, Civil Action No, 05-3947-CIVIL TERM DENNIS HAGERICH Defendant NOTICE OF JUDGMENT OR ORDER TO () Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the following Order or Judgment was entered against you on ~. (~ , ).. O~ (xx) Assumpsit Judgment in the amount of $2,381.96plus costs, Trespass Judgment In the amount of $ plus costs, () If not satisfied within sixty (60) days, your motor vehicle operator's license and/or registration will be suspended by the Department of Transportation, Bureau of Traffic Safety, Harrisburg, PA. (xx) Entry of Judgment of () Court Order () Non-Pros () Confession (xx) Default () Verdict () Arbitration Award By: PROTHO DENNIS HAGERICH 6167 HAYMARKET WAY MECHANICSBURG,PA 17050 Plaintiff's address is: clo Weltman, Weinberg & Reis Co, LPA, 2718 Koppers Building, 436 7" Avenue, Pittsburgh, PA 15219 1-888-434-0085 IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CACV OF COLORADO, LLC Case no: 05-3947-CIVIL TERM Plaintiff NON-MILITARY AFFIDAVIT vs, DENNIS HAGERICH Defendant The undersigned, who first being duly sworn, according to law, deposes and states as follows: That he/she is the duly authorized agent of the Plaintiff in the within matter. Affiant further states that the within Affidavit is made pursuant to and in accordance with the Servicemembers' Civil Relief Act (SCRA), 50 U,SC, App, S 521, Affiant further states that based upon investigation it is the affiant's belief that the Defendant, DENNIS HAGERICH is not in the military service. Affiant further states that this belief is supported by the attached certificate from the Defense Manpower Data Center (DMDC), which states that the Defendant, DENNIS HAGERICH is not in the military service, Further Affiant sayeth naught. lJ,' AFFIANT RI~' m, """'00 Ih'Wy NOT This law firm is a debt collector attempting to collect this debt for our client and any information obtained will be used for that purpose, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CACV OF COLORADO, LLC, Plaintiff 05-3947-CIVIL DENNIS HAGERICH Defendant IMPORTANT NOTICE TO: DENNIS HAGERICH 6167 HAYMARKETWAY MECHANICSBURG,~ 17~ Date of Notice: cq OS YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU, UNLESS YOU ACT WITHIN TEN 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 NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 By: William T, Molczan, Esquire PA I.D, #47437 WELTMAN, WEINBERG & REIS CO" LPA 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR #04180280 Request for Military Status Page I of I Department of Dcfense Manpower Data Center SEP-23-2005 06:29:08 Military Status Report Pursuant to the Service Members' Civil Relicf Act ... Last Name l<'irst!Middle Begin Date I Active Duty Status I Service! Agency HAGERlCH Based on the information you have furnished, the DMDC does not possess any information indicating that the individual is currcntly on active duty. Upon searching the information data banks of the Department of Defense Manpower Data Center, the abovc is the current status of the individual, per the Information provided, as to all branches ofthe Military. r--.--- -_> ,-- ? . ~'WJ \'~6-~ Robert J. Brandewie, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense Enrollmcnt and Eligibility Reporting System (DEERS) database which is thc official sourcc of data on eligibility for military medical care and other eligibility systcms, The Department of Defense strongly supports the enforcement of the Service Members Civil Relief Act [50 USCS Appx. ~~ 501 et seq] (SCRA) (formerly the Soldiers' and Sailors' Civil Relief Aet of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced a small crror rate. In the event thc individual referenced above, or any family member, friend, or representative asserts in any manner that the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are most strongly encouraged to contact us by Fax at (703-696-4156) or by phone at (703-696-6762). W c will then conduct further research, Your failure to re-contact DMDC may cause provisions of the SCRA to be invoked against you. This response ret1ects currcnt active duty status only. For historical information, please contact the military services SCRA point of contact. See: httpjLwww,defellSelink~rni)jfaq/Jlli.!PCQ9SLD R.html. Report ID:BZEISULRNZP https://www.dmdc.osd.mil/scra/owa/scra.prc__ Select 9/23/2005 c ~ p -kj.. () r-' 0l. ....a <;:; (-~ 0 l;':::,') <:,j1 -n 9- C> C> .-. c') :C",'" C> ....; n1f;.;i F - ~ I ="!~!} ~ C' .-'.1'''-"' ~ (~) , ' .0 V, ""'7:J ,'-1 ,',; ~ CI') --a -"... ~ c'! -.D 0- t5t~'1 QJ - ~ ;--\ ~ - -.c:, N .J.,S ~ :.<: -L - .. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CACV OF COLORADO Plaintiff No.05-3947-CIVIL vs. PRAECIPE FOR SATISFACTION OF JUDGMENT DENNIS HAGERICH Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt PA I.D #42524 WELTMAN, WEINBERG & REIS CO, LP.A, 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 VWl/R#04180280 '- . IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CACV OF COLORADO Plaintiff vs. Civil Action No. 05-3947-CIVIL DENNIS HAGERICH Defendant PRAECIPE FOR SATISFACTION OF JUDGMENT At the request of the undersigned attorneys for the Plaintiff, you are d'lrected to satisfy the above-captioned Judgment. WELTMAN, WEINBERG & REIS CO., .A. Sworn to and S~bS 'b d before me this :zr~>-- WWR #04180280 (;8L;, f\:.(':',~V Put:'}-:; I 'i,', h;.."".,'C',.",.,.,',"Y',, J .,.":,,;,,.,.,.jY...-,\"o. '-,:'n::;:.:n ,-/ -- -~ c~ -.\ .-4 -, i-on r-...':: \.r) C:I f-:'" \'" -------