The URL can be used to link to this page

Home My WebLink About05-4133 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION TJT FINANCIAL SERVICES LLC Plaintiff No: oS' - .!fIn (];ulL<-Y~ vs. COMPLAINT IN CIVIL ACTION KENNETH HOY Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt,42524 WELTMAN, WEINBERG & REIS CO., L. P. j 436 Seventh Avenue, Suite 2718 Pittsburgh, PA 15219 (412) 434-7955 FAX: 412-338-7130 04328712 C A pit KMJ l' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION TJT FINANCIAL SERVICES LLC Plaintiff vs. Civil Action No KENNETH HOY 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, TJT FINANCIAL SERVICES LLC is a corporation with offices at 6851 JERICHO TURNPIKE #190 SYOSSET , NY 11791 . 2. Defendant is adult individual(s) residing at the address listed below: KENNETH HOY 100 GERGETOWN ROAD MECHANICSBURG, PA 17055 3. Defendant applied for and received a credit card bearing the account number 4791060010335924 . 4. Defendant made use of said credit card and has a current balance due of $1559.58 , as of August 02, 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 August 02, 2005 . A copy of Plaintiff's Statement of Acco unt 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 , KENNETH HaY , individually , in the amount of $1559.58 with continuing interest thereon at the rate of 6.000% per annum from August 02, 2005 plus costs. This law firm is a debt collector tempting to collect this debt for our client and any information obtained will be used for that purpose. rmbrodt,42524 , WEINBERG & REIS CO., L.P.A. Seventh Avenue, Suite 2718 sburgh, PA 15219 41 ) 434-7955 : 412-338~7130 o 328712 C A pit KMJ Please indicate N arne, or address ~ltlI2~ TJT FINANCIAL SERVICES, LLC Charge-off Statement Telephone Changes Horne ( ) Work ( ) ACCOUNT NUMBER PAYMENT PASfDUE MINIMUM NEW AMOUNT OF DUE DATE AMOUNT PAYMENT BALANCE PAYMENT ENCLOSED 4791 0600 1033 5924 04/19/2002 963,48 316,80 1040,14 $ KENNETH HOY 100 GERGETOWN ROAD HARRISBURG PA 17055 1...11",11I",1,1"11",1"\.1"\1",11",\,\11,,,,,\1,1,,,1I 6851 JERICHO TURNPIKE SUITE 190 SYOSSET NY 11791 1,..111,1"1"1,1..1"11..,1,1,,11,,,1,1,,,11,,1,1,..11,,,,111 ACCOUNT NUMBER CREDIT CREDIT DAYS IN BILL PAYMENT MINIMUM LINE AVAILABLE BILLING CYCLE DATE DUE DATE PAYMENT DUE 4791 0600 1033 5924 800.00 32 04/04/2002 04/19/2002 316,80 DATE OF TRANS POST REFERENCE NUMBER DESCRIPTION OF TRANSACTIONS AMOUNT 0404 0404 OVERLIMI'I' FEE 29.00 0000 0000 LATE CHARGE- MIN PYMT NOT RECD BY DATE 35.00 ..** FINANCE CHARGE CURRENT !'URCHASE 12.66 PREVIOUS NEW PURCHASES DEBIT FINANCE OVER LINE NEW BALANCE PAYMENTS CREDITS AND ADVANCES ADJUSJ'MENTS CHARGES AMOUNT BALANCE 963,48 ,00 ,00 ,00 64,00 76,66 240,14 1040.14 AN AMOUNT FOLLOWED BY A MINUS SIGN(-) IS A CREDIT BALANCE UNLESS OTHERWISE INDICATED >--~----~ $ TIPES OF CREDIT TO FINANCE DAILY NOMINAL ANNUAL ANNUAL WHICH RATES APPLY CHARGE BALANCES PERIODIC RATE PERCENTAGE RATES PERCENTAGE RATES PURCHASES 963.48 .04106 "10 14.99% 14.99 % - .06299% ADVANCES 22.99% "/" >-- .-~ ~-~--,-- ~---- e--- >------ - YOU MAY AVOID ADDITIONAL FINANCE CHARGES ON PURC'HASES IFYOV PAY 1"HIS AMOUNT BY TI lE DUE DATE QUESTIONS about account? Credit Card lost or stolen? Call Customer Service 24 hours a day 7 days a week, toll- free at 1-800~277-4431 , Para Servicio al Cliente en espanol: 1~800-277-4431 EXHiBIT -L- VERIFICA nON The undersigned does hereby verify subject to the penalties of 18 P A.C.S. 14904 relating to Agent (Title) of lV'r Dawn Felicciardi (Name) -F,'rld 1'1<-,11.1 S-erv;(e.s LL<", plaintiff herein, that (Company) unsworn falsifications to authorities, that he/she is 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, infonnation and belief. /1 CaP)I(\!JJ!A-C~'1 ~~- (Signature) WWR# ct> ~ 3 l.-P n- -'0. .-' ~ \.) (1 ~ 8 <r( ~._~; "-" %:n p \ ,- ~ !n. - -c~ \t \~~':.' C'> V{ - ?\ ~ '" ~::l() (f) .- '-r't C> ~ -c........., -- -:J 1;1,('" -r-- '\,~;; -'-~ ,.,.. om ..:t !-J -0 .r:. "-' ~; -C:. ..{) ?=- - '''''' ,... ~ -<. u- - \) ~ 1?- +--- -----z SHERIFF'S RETURN ~ NOT FOUND CASE NO: 2005~04133 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND TJT FINANCIAL SERVICES LLC VS HOY KENNETH R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT HOY KENNETH but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT & NOTICE , NOT FOUND , as to the within named DEFENDANT , HOY KENNETH 100 GERGETOWN ROAD MECHANICSBURG, PA 17055 DEFENDANT HAS NOT BEEN EMPLOYED AT GIVEN ADDRESS FOR OVER 6 MONTHS. THEY HAVE NO HOME ADDRESS FOR HIM. Sheriff's Costs: Docketing Service Not Found Surcharge 18.00 8.00 5.00 10.00 .00 41.00 So answers;., ,,' /~:?;.~..::c--?~:~? _/~p /" R. Thomas Kleine Sheriff of Cumberland County WELTMAN WEINBERG REIS 09/01/2005 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION T JT FINANCIAL SERVICES LLC Plaintiff No, 05-4133-CIVIL vs, PRAECIPE TO REINSTATE COMPLAINT KENNETH HOY Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY William T, Molczan PA LD, #47437 WELTMAN, WEINBERG & REIS, CO" LPA 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#04328712 ;. . IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION TJT FINANCIAL SERVICES LLC Plaintiff vs, Civil Action No 05-4133-CIVIL KENNETH HOY Defendant PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. WELTMAN, WEINBERG & REIS CO, LPA /-// C //{1 By: 11 'I ~. /' t '1 William 1. Molczan PA 1.0 #47437 WELTMAN, WEINBERG & REIS CO, L.PA 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR #04328712 "" ..-' ~ '-;.' C' "n ::;::! " ,.;-~ r-'~' L~;; (,,~ C~) c.,.:' .. I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION T JT FINANCIAL SERVICES LLC Plaintiff No,05-4133-CIVIL vs, PRAECIPE TO SETTLE, DISCONTINUE AND END WITHOUT PREJUDICE TO REFILE KENNETH HOY Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY JAMES C WARM BRODT PA I.D #42524 WELTMAN, WEINBERG & REIS CO, LPA 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#04327128 .. ;N THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION T JT FINANCIAL SERVICES LLC Plaintiff vs, Civil Action No, 05-4133--CIVIL KENNETH HOY 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, LPA SWORN TO AND SU"CRIBED before e t is L)day By Attorney or laintiff 2718 Kopp s Building 436 Seven Avenue Pittsb\Jrg ,PA 15219 (41~) 4;M-7955 WWf3;'i04327128 / ' 1/ , of ,2006 " L_ ,---, ~h ,-1 ...-~ ;'\1 0) r>., , t,,) ('0 ~ SHERIFF'S RETURN ~ OUT OF COUNTY . CASE NO: 2005~04133 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND TJT FINANCIAL SERVICES LLC VS HOY KENNETH R, Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT / to wit: HOY KENNETH but was unable to locate Him in his bailiwick. He therefore deputized the sheriff of DAUPHIN County, Pennsylvania, to serve the within COMPLAINT & NOTICE On December 13th, 2005 , this office was in receipt of the attached return from DAUPHIN Sheriff's Costs: Docketing Out of County Surcharge Dep Dauphin County Postage 18,00 9,00 10.00 29.25 ,37 66.62 12/13/2005 WELTMAN WEINBERG So an~~:c-s ~ . ~;.~ ?-t::~~ ../ R, Thomas Kline Sheriff of Cumberland ......,.. County REIS Sworn and subscribed to before me this /\pI-'-' day of Lh(.",bv- /"'\ .r-' iX ex'}) A.D ~ ??~9tar t ,.. In The Court of Common Pleas of Cumberland County, Pennsylvania TJT Financial Services LLC VS. Kenneth Hoy No. 05-4133 civil Now, December 1, 2005 , I, SHERIFF OF CUMBERLAND COUNTY, P A, do hereby deputize the Sheriff of Dauphin County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. r~4~~ Sberiff of Cumberland County, FA Affidavit of Service Now, , 20_, at 0' clock M. served the within upon at by handing to a copy of the original and made known to the contents thereof. So answers, Sheriff of County, P A Sworn and subscribed before methis_dayof ,20_ COSTS SERV1CE MILEAGE AFFIDAV1T $ $ ~ @iiite of t1r~ ~4~:riff r William T. Tully Solicitor Charles E. Sheaffer Chief Deputy Mary Jane Snyder Real Estate Deputy Michael W. Rinehart Assistant Chief Deputy Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 780-6590 fax: (717) 255-2889 Jack Lotwick Sheriff Commonwealth of Pennsylvania TJT FINANCIAL SERVICES LLC vs County of Dauphin HOY KENNETH Sheriff's Return NO.2043-T - ~2005 OTHER COUNTY NO. 05~4133 CIVIL AND NOW:December 7, 2005 at 8: 15AM served the within REINSTATED NOTICE & COMPLAINT upon HOY KENNETH by personally handing to DEFENDANT 1 true attested copy(ies) of the original REINSTATED NOTICE & COMPLAINT and making known to him/her the contents thereof at 301 CHESTNUT ST APT 1603 HARRISBURG, PA 17101-0000 Sworn and subscribed to So Answers, Jf~ before me this 7TH day of DECEMBER, 2005 Sheriff of ~phin Cotyl.j:y, Pa. ::J:',i"1T,r~..- tv O'd-' ~~ By NOTARIAL SEAL MARY JANE SNYDER, Notary Public Highspire, Dauphin County My Commission Expires Sept. 1, 2006 Deputy Sheriff Sheriff's Costs:$29.25 PD 12/05/2005 RCPT NO 212776 WONG