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Home My WebLink About05-3961 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL DIVISION ASSET ACQUISITIONS GROUP, LLC Plaintiff No. OS. 3q~ I (!uil Ttv---. vs. COMPLAINT IN CIVIL ACTION SHARON E. VIA Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. MoIczan, Esquire PA!.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 27 I 8 Koppers Building 436 Seventh Avenue Pittsburgh, P A 15219 (412) 434-7955 WWR#04328693 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION ASSET ACQUISITIONS GROUP, LLC PIaintifJ vs. Civil Action No. 0.:, -. 3q~ I Cw-i.t {II-<- SHARON E. VIA 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 f{)r 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 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. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAYBE ABLE TO PROVIDE YOU WITH INFORMATION ON AGENICES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LA WYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 717-249-3166 COMPLAINT 1. Plaintiff is a corporation with offices in 6851 Jericho Turnpike #190, Syosset, NY 11791. 2. Defendant is an adult individual residing at 13 Campbell Place, Camp Hill, P A 17011. 3. Defendant applied for and received a credit card issued by Plaintiffs assignor bearing the account number 5440450053734541. 4. Defendant made use of said credit card and has currently a balance due and owing to Plaintiff, as of August 1,2005, in the amount 01'$1,729.98. 5. Defendant is in default of the tenns of the cardholder Agreement having not made monthly payments to Plaintiff thereby rendering the entire balance immediately due and payable. 6. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed and/or refused to pay. WHEREFORE. Plaintift'demands Judgment in its favor and against Defendant, Sharon E. Via individually, in the amount 01'$1.729.98 additional interest at the legal interest rate 01'6% per annum li'om the date ofj udgment plus costs. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED SHALL BE llSED FOR THAT PURPOSE. WELTMAN, WEINBERG & REIS, CO., L.P.A. ~.- William T. Molcza , PA!.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, P A 15219 (412) 434-7955 WWR#:04328693 VERIFICATION The undersigned does hereby verifY subject to the penalties of I 8 P A.C.S. 14904 relating to unsworn falsifications to authorities, that he/she is Agent (Title) of A:-SS~t- Dawn Felicciardi (Name) Ar 1;; ,;; 5;' 'I,' P.....s &"--0 v/, plaintiff herein, that (Co pany) , l-I....c.. he/she is duly authorized to make this Verification, and that the facts set forth in the foregoing Complaint in Civil Action are true and correct to the best of his /her knowledge, information and belief. c.a~J~/-~{~h~ (Signature) WWR# ()qjJ.. 3b9) () r"'" C) ,-.--..., c--. ,-~-) -n c;jl .l. l>-..'--' r;~ ~ F- ~ , t) (,.,,) -- -"- _. '"q b<> -" c- '" v.. .. ~ l::, ~ C~ <:> CJ ~ d ~ -- - SHERIFF'S RETURN - REGULAR CASE NO: 2005-03961 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ASSET ACQUISITIONS GROUP LLC VS VIA SHARON E BRIAN BARRICK Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon VIA SHARON E the DEFENDANT , at 1711:00 HOURS, on the 29th day of August , 2005 at 13 CAMPBELL PLACE CAMP HILL, PA 17011 by handing to SHARON VIA 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 So Answers: 18.00 12.00 .00 10.00 .00 40.00 :?,,,,'};;/tC,=,.-,c: ,~ ',r -' R. Thomas Kline 08/30/2005 WELTMAN WEINBER Sworn and Subscribed to before By: !It Deputy Sheriff me this of IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLV ANIA CIV1L DIVISION ASSET ACQU1S1TIONS. LLC Plaintiff No. 05-3961 CIVIL TERM vs. PRAECIPE FOR DEFAULT JUDGMENT SHARON E. VIA Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THlS PARTY: WILLIAM T. MOLCZAN, ESQUIRE P A I.D.#47437 Weltman, Weinberg & Reis Co., LP.A. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#04328693 Judgment Amount $ !, 729.98 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 ASSET ACQUISITIONS, LLC Plaintitf YS. Civil Action No. 05-3961 CIVIL TERM SHARON E. VIA Defendant PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter Judgment against the Defendant, SHARON E. VIA above named, in the default of an Answer, in the amount of $1,729.98 computed as follows: Amount claimed in Complaint $1,729.98 Interest from date of judgment at the legal interest rate of 6% per annum $0.00 TOTAL $1,729.98 I hereby certifY that appropriate Notices of Default, as attached have been mailed in accordance with I' A R.CP. 237.1 on the dates indicated on the Notices. WELTMAN. WEINBERG & REIS CO.. L.PA .J ~/~,A ~ By: /../ A -(..1 -<,/lj' WILLIAM T. MOLCZAN, SQUIRE PA 1.0.#47437 Weltman. Weinberg & Reis Co., L.P.A. 2718 Koppers Bldg. 436 Seventh A venue Pittsburgh, P A 15219 (412) 434-7955 WWR#04328693 Plaintiffs address is: c/o Weltman. Weinberg & Reis Co., L.P.A., 2718 Koppers Building. 436 7'" Avenue, Pittsburgh. PA 15219 And that the last known address of the Defendant is: 13 CAMPBELL PL CAMP HILL,PA 17011 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION ASSET ACQUISITIONS GRP LLC Plaintiff 05-3964-CIVIL SHARON E VIA Defendant IMPORTANT NOTICE TO: SHARON E VIA 13 CAMPBELL PL CAMP HILL,PA 17011 Date of Notice3f \;)\-' 21J I }J::C,;'-') 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 WELTMAN. WEIN S CO, LPA IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION ASSET ACQUISITIONS, LLC Case no: 05-3961 CIVIL TERM Plaintiff NON-MILITARY AFFIDAVIT vs, SHARON E. VIA 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 Aftidavit is made pursuant to and in accordance with the Servicemembers' Civil Relief Act (SCRA), 50 U.S,c, App. S 521. Affiant further states that based upon investigation it is the affiant's belief that the Defendant, SHARON E. VIA 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, SHARON E, VIA is not in the military service, Further Affiant sayeth naught ! I /.,I.~/~/___ /!/M''{- 1-- (., lA, AFFIANT '/ ) N TO AND SUBSCRIBED in 11])' presence thl ~ r . C'\:, Notanal Seat Wendy L Ga"~, Notary Public City Of Pittsburgh, Allegheny Co.OW lo1y CommiSSion El<pire& July 1<;, 2006 ~ ,:.-,-_-"--'--:_-:~::'.,:... d;'.,,,,~Of~ 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. Request for Military Status Page I of I Department of Defense Manpower Data Center OCT-IO-200507:04:09 Military Status Report Pursuant to the Service Members' Civil Relief Act <' Last Name First/Middle Begin Date I Active Duty Status I Service/Agency VIA Based on the information you have furnished, the DMDC does not possess any information indicating that the individual is currently on active duty. Upon searching the information data banks of the Department of Defense Manpower Data Center, the above is the current status of the individual, per the Information provided, as to all branches of the Military. ~'J~Cl-~ 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 Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The Department of Defense strongly supports the enforcement of the Service Members Civil Relief Act [50 USCS Appx. ss 501 et seq] (SCRA) (formerly the Soldiers' and Sailors' Civil Relief Act 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 error rate. In the event the 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). We will then conduct further research. Your failure to re-contact DMDC may cause provisions of the SCRA to be invoked against you. This response reflects current active duty status only. For historical information, please contact the military services SCRA point of contact. See: http://www.def~!1seJink.mil/faq/pis/PC09SLDR.html. Report ID'BUDMFQKULQV https:/ /www.dmdc.osd.mil/scralowalscra. prc _Select 10/10/2005 CN(::J~ L#-1:-G - () D' ~ "\n D- 1" ~ ?v ~.} ~ ~ t ~ k t~t IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY. PENNSYL VANIA CIVIL DIVISION ASSET ACQUISITIONS, LLC Plaintitr vs. Civil Action No. 05-3961 CIVIL TERM SHARON E. VIA Defendant NOTICE OF JUDGMENT OR ORDER TO: () Plaintitr (xx) Defendant ( ) Garnishee You are hereby notified that the following Order or Judgment was entered against you on_~I.;l,DCJ>.S (xx) Assumpsit Judgment in the amount of$I,729.98 plus costs. () Trespass Judgment in the amount of$~ plus costs. () If not satistied 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 Prothonotary SHARON E VIA 13 CAMPBELL PL CAMP HILL,PA 17011 Plaintiff's address is: c/o Weltman, Weinberg & Reis Co.. LP.A., 2718 Koppers Building. 436 7'h Avenue, Pittsburgh. PA 15219 1-888-434-0085 (', -~-4 r-,,; , " C) .< ~ .. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION ASSET ACQUISITIONS GRP LLC Plaintiff No. 05-3961-CIVIL vs. PRAECIPE FOR SATISFACTION OF JUDGMENT SHARON E VIA Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt P A I. D #42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 VVWR#04328693 l ~ .. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION ASSET ACQUISITIONS GRP LLC Plaintiff VS. Civil Action No. 05-3961-CIVIL SHARON E VIA Defendant PRAECIPE FOR SATISFACTION OF JUDGMENT At the request of the undersigned attorneys for the Plaintiff, you are directed to satisfy the above-captioned Judgment. WELTMAN, WEINBERG & REIS CO., L.P.A. EINBERG & REIS CO., L.P.A. WWR #04328693 Sworn to and subsCjiQed before me this \"U y of January, 07- COMMONWEALTH OF PENNSYLVANIA Notarial Sea! Heidi J. Kelty. Notary Public City Of Pittsburgh, Allegheny County My commission expires No\!.-'. ~~09 M"....b". ;:;;;'Jlvanla ASSOCi"i,v:' aridS .....11. v. _. .......... (") f;. 3J~ r~S 'I 'f ~:/ -~: "::" I o ~;',~ ~ i::> ,,'~_ :"~ ~~.~ >c,~: ~ ....., = = --J '- :r.- % ^-lllo;" -J -0 3;: ~ :r, :n fl,- -o~ ';-J '-" ".:jC1 ~j-r; ~.t,.... -T, ;::>6 2m ~?t ~ - .. N CT\