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Home My WebLink About05-4049 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL DIVISION TJT FINANCIAL SERVICES, LLC vs. No. OS- - %1./1 cL~ t-T8L~ COMPLAINT IN CIVIL ACTION Plaintiff MELISSA GUYER Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan, Esquire PA 1.0, #47437 WELTMAN, WEINBERG & REIS CO., L.P,A, 2718 Koppers Building 436 Seventh Avenue Pittsburgh, P A 15219 (4]2) 434-7955 WWR#04328711 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA CIVIL DIVISION TJT FINANCIAL SERVICES, LLC Plaintiff vs, Civil Action No, Of; - Af()!.fC( (1;U~(-FiR....~ MELISSA GUYER 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 mus1 take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by an attomey 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 imporJant 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 MAY BE 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, P A 17013 717-249-3166 COMPLAINT 1. Plaintiff is a corporation with otlices in 6851 Jericho Turnpike #190, Syosset, NY 11791. 2, Defendant is an adult individual residing at 95] Oakville Road, Newville, P A 17241, 3, Defendant applied for and received a credit card issued by Plaintiff's assignor bearing the account numbcr 479] 06003] 378796. 4. Defendant made use of said credit card and has currently a balance due and owing to Plaintiff, as of August 2, 2005, in the amount of$I,709,18, 5, Defendant is in default of the terms 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, Plaintiff demands Judgment in its favor and against Defendant, Melissa Guyer individually, in the amount of $1,709,18 additional interest at the legal interest rate of 6% per annum from the date of judgment plus costs. THIS rs AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED SHALL BE USED FOR THAT PURPOSE. WELTMAN, WEINBERG & REIS, CO" L.P,A. William T, Molczan, PA LO, #47437 WELTMAN, WEINBERG & REIS CO., L.P,A, 2718 Koppers Building 436 Seventh Avenue Pittsburgh, P A 15219 (412) 434-7955 WWR#:0432871l VERIFICA nON The undersigned does hereby verify subject to the penalties of IS P A,C,S, 14904 relating to unsworn falsifications to authorities, that he/she is Dawn Felicciardi .....-- (Name) of 10/ Itlw,c-/i,.,l Serv; 1..'1,5 , LLC- , plaintiff herein, that / (Company) Agent (Title) 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 ofhislher knowledge, information and belief, {'fuJtuJ.eLt;-<,( L4>Z. (SIgnature) WWR# O'-/32-J;7/1 t {Q 8 p U( ~ .U( ~ ~ ~ C> (') = ~ ~ "" ~&, ~ J>" ~ - -ute C ~ p:! ~~' G"l :Bc::J )v , \D ~~ -:2 C/( ~c ~ 0") CY --?'fn ~c, C5 :E -C) \D """ 5c: .' ~ ~ Ul '< ~ c::> SHERIFF'S RETURN - REGULAR CASE NO: 2005-04049 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND TJT FINANCIAL SERVICES LLC VS GUYER MELISSA JASON VI ORAL , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon GUYER MELISSA the DEFENDANT 2005 NEWVILLE, FA 17241 by handing to MELISSA GUYER 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: ~ .__~ i~... ~ ~ ~* -- r 18,00 15,20 ,00 10,00 .00 43.20 R, Thomas Kline 08/12/2005 WELTMAN WEINBERG & REIS Sworn and Subscribed to before me this :/fjllP day of ~ rloAD ~.~' pr~~tary By: CfY~ff o IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION TJT FINANCIAL SERVICES, LLC Plaintiff vs Civil Action No, 05-4049-CIVIL MELISSA GUYER 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 C) c--: ", ~.:l (~.:'::> ("..." o C) ---; o ," :d ~-;-~~ ."'.' ~ I~) ~:1 , (xx) Assumpsit Judgment In the amount of $1 ,709.18 plus costs, (--,) L--) C! 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 MELISSA GUYER 951 OAKVILLE RD NEWVILLE,PA 17241 Y) Plaintiff's address IS cia Weltman. Weinberg & Rels Co, LP A, 2718 Koppers BUilding 436 7th Avenue, PJltsburgh, PA 15219 1-888-434-0085 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA CIVIL DIVISION T JT FINANCIAL SERVICES. LLC Plalnliff No 05-4049-CIVIL vs PRAECIPE FOR DEFAULT JUDGMENT MELISSA GUYER Defendant FILED ON BEHALF OF Plainttff COUNSEL OF RECORD OF THIS PARTY William T. Molczan. Esquire PA 10 #47437 WELTMAN, WEINBERG & REIS CO , L P A 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#04328711 Judgment Amount $ 1,709 18 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 TJT FINANCIAL SERVICES, LLC Plaintiff vs, Civil Action No, 05-4049-CIVIL MELISSA GUYER Defendant PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY Kindly enter Judgment against the Defendant. MELISSA GUYER. above named, in the default of an Answer, in the amount of $1 ,70918 computed as follows Amount claimed in Complaint $1,709.18 Interest from date of judgment at the legal interest rate of 6% per annum TOTAL $1,70918 I hereby certify that appropriate Notices of Default, as attached have been mailed in accordance with PA R.C.P 237.1 on the dates indicated on the Notices. By Wlllia olczan. squire PA I D #47437 WELTMAN. WEINBERG & REIS CO . L PA 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#04328711 Plaintiffs address is: c/o Weltman, Weinberg & Reis Co" LPA. 2718 Koppers Building, 436 i" Avenue, Pittsburgh, PA 15219 And that the last known address of the Defendant is: 951 OAKVILLE RD NEWVILLE,PA 17241 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION TJT FINANCIAL SERVICES LLC, Plaintiff 05-4049-CIVIL MELISSA GUYER, Defendant IMPORTANT NOTICE TO: MELISSA GUYER 951 OAKVILLE RD NEWVILLE,PA 17241 Date of Notice: 9/7/m / 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, WEINBERG & REIS CO., L.PA By wfi-"~~ William T. Molczan, Esquire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.PA 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WVVR #04328711 IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY. PENNSYLVANIA CIVIL DIVISION TJT FINANCIAL SERVICES, LLC Case no: 05-4049-CIVIL Plaintiff NON-MILITARY AFFIDAVIT vs, MELISSA GUYER 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 Ihe 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, MELISSA GUYER 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, MELISSA GUYER. is not in the military service, Further Affiant sayeth naught. SWO of NOTARY 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 _ Military Status Report .. Pursuant to the Service Members' Civil Relief Act OCT-04-200505:58:2l ..;( Last Name First/Middle Begin Date I Active Duty Status I Service/Agency GUYER 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 , ~W~6-~ Robert J, Brandewie, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd" Suite 400 Arlington, V A 22209-2593 The Defense Manpower Data Center (DMDC) is an organization ofthe 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, 99 501 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.defensdink.millfaq/pisil.C09SLDR.html. Report JD:BRPJUVXKOGU https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 10/4/2005 0 r--,,"' 0 c:'> ~~; ~~,) -n 0' ,-1 "'4- C) ::1:-n Z C) n1;:==;; ~ -:-D -, ~ "T) i"'~ ~ ~ ' C;, ...-~{; ~ ,_"'il -V " ')7~ 'S>- ,,:' 1"'f\ (,),J ,,,) 00 .:,:2 ? ~ C...... jJ ~ (..r', .-<. $:). V "'" -;::-- ..s:. ~ ."^ ~ ~ (~ ~ ----------