HomeMy WebLinkAbout05-4395
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WELLS FARGO BANK NA,
a National Banking Association
Plaintiff,
vs.
THEODORE HILL and KIMBERLY
HILL,
Defendants.
JURY TRIAL DEMANDED
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CIVIL DIVISION
NO.: OS - .Lf]9..s C;<.JL~>-Vl
COMPLAINT IN CIVIL ACTION
Filed on behalf of Plaintiff
WELLS FARGO BANK, a National
Banking Association
Counsel of Record for This Party:
REBECCA KEATING LEVENTOPOULOS
PA!.D. # 90439
Payne, Welsh & Klingensmith
105 Penn Plaza
Turtle Creek, PA 15145
FIRM #658
(412)823-8100
THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION
OBTAINED SHALL BE USED FOR THAT PURPOSE.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WELLS FARGO BANK NA,
a National Banking Association
Plaintiff.
vs.
THEODORE HILL and KIMBERLY
HILL,
Defendants.
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CIVIL DIVISION
/' -'0 .J~
NO.: 05 - o/:3<j.:.~ ~
COMPLAINT- CIVIL ACTION
AND NOW, comes the Plaintiff, Wells Fargo Bank, NA, a National Banking
Association by and through its attomeys, Rebecca Keating Leventopoulos, Esquire, and Payne,
Welsh & Klingensmith, and files the within Complaint in Civil Action and in support thereof
avers as follows:
L Plaintiff is a corporation with an office located at Wells Fargo Plaza, 100 W.
Washington Street, Phoenix, Arizona 85003 and is engaged in the business of consumer and
commercial credit.
2. Defendant, Theodore Hill, is an individual believed to be residing at 162 Ken Lin
Drive, Carlisle, PA 17013.
3. Defendant, Kimberly Hill, is an adult individual believed to be residing at 162 Ken
Un Drive, Carlisle, P A 17013.
4. Defendants applied for a business line of credit in the amount of $20,000.00 from
Plaintiff on or about December 12, 2002. A true and correct copy of said application and the
BusinessLine Customer Agreement is attached hereto marked as Exhibit "A" and is incorporated
by reference.
5. Plaintiff approved said application and extended a line of credit in the amount of
$20,000.00 to Defendants at or near that same date and time.
6. The terms of the extension of credit issued by Plaintiff to Defendants was for the
aforesaid amount of $20,000.00, at an interest rate of 14.5% per annum, payable in monthly
installments of principal and interest.
7. Defendants are in default of the terms of the extension of credit, having not made
payment to Plaintiff as promised since September 9, 2004 thereby rendering the entire unpaid
balance immediately due and payable.
8. The current balance owed by Defendants on this matter is $21,273.43 as of October
30,2004 as evidenced by an Affidavit signed by an agent of Plaintiff marked as Exhibit "B".
9. Plaintiff avers that per the Agreement between the parties that Defendants will pay
Plaintiffs attorney's fees.
10. Plaintiff avers that such attorney's fees will amount to $1,500.00 should this matter
proceed to triaL
II. Although repeatedly requested to do so by Plaintiff, Defendants have willfully failed
and/or refused to pay the principal balance, finance charges, attorney's fees or any part thereof
owed to Plaintiff regarding this account.
12. Plaintiff has suffered damages in the amount of $22,773.4 3 as a result of the breach by
Defendants.
WHEREFORE, Plaintiff, Wells Fargo Bank, demands Judgment in its favor and against
the Defendants in the amount of $22,773.43 with continuing finance charges thereon plus costs,
fees and any other relief this Court deems proper.
THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION
OBTAINED SHALL BE USED FOR THAT PURPOSE.
Respectfully submitted,
By:
Rebecca Keating Leventopoulo
Pa. LD. #90439
Attorney for Plaintiff
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EXHIBIT
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Wells Fargo Terms and Conditions
By signing the front ofthis application, I accept on behalf of the Business named on reverse ("Applicantj the terms and conditions
of this offer,induding the terms and conditions of the Customer Agreementthatwill be sent to the Applicant. I understand that jf I
am not already enrolled in the Wells Fargo Onlinefll banking service,an online password will be ordered and mailed to my home
address upon final credit approval.l also accept in my individual capacity the terms of guaranty appearing below. By selecting the
Electronic Funds Transfer option and signing on the reverse, I authorize Wells Fargo to issue a draft, on my behalf, against my
BusinessLine account in the form of an electronic funds transfer or a check made payable to my business, which will be deposited in
my business checking account orsent to me after my BusinessLine account is approved. I agree that a facsimile of my signature, in any
capacity, may be used to evidence my acceptance of these agreements. I certify that I am authorized to submit this application on
behalf of the Applicantand that all information and documents made in connection with this application, including federal and state
income tax returns (if any),aretrue,correct,and complete. I authorizeWelis Fargo Bank,N.A.("Bank')toobtain balance and payoff
information on all accounts requiring payoff asa condition of approving this application and to obtain consumer and business
reports from and to report credit information to others, including the Internal Revenue Service and state taxing authorities, about me
and my business, I agree to notify Bankprornptly of any material change in surn information. I acknowledge that (i) this application I,
subject to fin.1 approval of the Applicant and Its owners,.nd that (il) additional inform.tion may be required in order forthe B.nk to
makeafinal credit decision. I uncerstand that Iftfle"Appllcant is not approvecffor a ~Bus;nessLlne account, Wells Fargo may request
addltionai inform.tion from the Applicant in order to qualifyth. Applicant for another Wells Fargo credit.ccount.l.gree to pay
Bank's costs and attorneys'fees in enforcing the Customer Agreement.l further agree that use of any feature of the BusinessLine
account or Bus;nessLine MasterCard' may be used as evidence of the foregoing authorizations, acceptances and agreements. I
understand that if Applicant is a leg.1 entity,.1I owners are asked to sign the front of this application and include their tides.
Except in Arizona,if the business owner is married, a spouse's signature is not required unless he or she is a co-owner of the business.
I also,in my individual capacity (even though I m~y place a title or other designation next to my signature),jointly and severally
unconditionally guarantee and promise to pay to Bank all indebtedness of the Applicant atany time arising under or relating to this
application andlor the Customer Agreementas well as any extensions, increases,or renewals ofthat indebtedness.As guarantor, I
waive (0 presentment,demand, protest, notice of protest, and notice of non~payment;(ii) any defense arising by reason of any
defense of the Applicant or other gu.rantor;and (Iii) the right to require Bank to proceed against Applicant or any other gu.r.ntor, to
pursue any remedy in connection with the guaranteed indebtedness, or to notify guarantor of any additional indebtedness incurred
by the Applicant.or of any changes in the Applicant's financial condition. I also authorize Bank, without notice Of prior consent, to (i)
extend, mOdify,compromise,accelerate, renew, increase or otherwise change the terms of the guaranteed indebtedness;(ii) proceed
against one or more guarantors without proceeding against the Applicant or another guarantor;and (iii) r~ease or substitute any
Applicant,Co-Applicant andlor any guarantor.! agree (i) I will pay Bank's costs and attorneys'fees in enforcing this guaranty; (iil this
gu.ranty is made in California and will be governed by California law; and (Iii) this guaranty shall benefit the Bank and its successors
and assigns.
Cl2002WeltsFargo&m.NA
Ail rights rest'ried.Member FOIC
52057(12102)
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~-'-'''':;;'-
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WELLS FARGO BANK NA,
a National Banking Association
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CIVIL DIVISION
NO.:
Plaintiff,
vs.
THEODORE HILL and KIMBERLY
HILL,
Defendants.
AFFIDAVIT
.Jlb1\IJ, ~ .
I, ilW~ ,an employee of WELLS FARGO do affirm that the amount owed by
Theodore Hill and Kimberly Hill is $21,273.43 as of October 30, 2004 plus interest
Date:~
~. ~./'---
.J~ an employee of
Wells Fargo
SWORN TO AND SUBSCRIBED
y:.~ ME, THIS J1 DAY OF
2005.
Notary Public
i'~-..-'~--
I ~SHARON PABLD-EMERSON
NOTARYPUBUC-~ONA
MARlCOPA COUNTY
My Commission ExpI.....
Sept 16. 2008
VERiFICATION
..ll..1'30i\..J. vJ.
I, Al-lPG~ , an employee of Wells Fargo Bank, N.A., a National Banking
Association have read the foregoing COMPLAINT and verify that the statements therein are
correct to the best of my personal knowledge, information and/or belief
This verification is made subject to the penalties of 18 PA. C.S.A. Section 4904, relating
to unswom falsification to authorities, which provides that if! make knowingly false statements I
may be subject to criminal penalties.
G /17 loG
Date
~ke-J' E!./ ___
We Fargo Bank, N.A., a NatIOnal
Banking Association
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SHERIFF'S RETURN - REGULAR
CASE NO: 2005-04395 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
WELLS FARGO BANK N A
VS
HILL THEODORE ET AL
KENNETH GOSSERT
, Sheriff or Deputy Sheriff of
Cumberland County, Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE
was served upon
HILL THEODORE
the
DEFENDANT
, at 2043:00 HOURS, on the 8th day of September, 2005
at 162 KEN LIN DRIVE
CARLISLE, PA 17013
by handing to
THEODORE HILL
a true and attested copy of COMPLAINT & NOTICE
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
So Answers:
18.00
4.00
.00
10.00
.00
32.00
r~~~~
R. Thomas Kline
09/09/2005
PAYNE WELSH & KLINGENSMITH
A.D.
Sworn and Subscribed to before By:
,J~
day of
me this
SHERIFF'S RETURN - REGULAR
CASE NO: 2005-04395 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
WELLS FARGO BANK N A
VS
HILL THEODORE ET AL
KENNETH GOSSERT
Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE
was served upon
HILL KIMBERLY
the
DEFENDANT
, at 2043:00 HOURS, on the 8th day of September, 2005
at 162 KEN LIN DRIVE
CARLISLE, PA 17013
by handing to
THEODORE HILL, HUSBAND
a true and attested copy of COMPLAINT & NOTICE
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
So Answers:
6.00
.00
.00
10.00
.00
16.00
~a-':~~"'f'(
.r ...r:..."7"~>.~,." " '..
R. Tnomas Kline
" ,x'
...(~.~><::...<
/.Ii""-k';:;"""~
"./ .'" .~~.
09/09/2005
PAYNE WELSH & KLINGENSMITH
Sworn and Subscribed to before By:
me this 23 day of
S:1'~. AD
,Pro ota
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WELLS FARGO BANK NA,
a National Banking Association
Plaintiff,
vs.
THEODORE HILL and KIMBERLY
HILL,
Defendants.
JURY TRIAL DEMANDED
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CIVIL DIVISION
NO.: 05-04395
PRAECIPE FOR DEFAULT
JUDGMENT
Filed on behalf of Plaintiff
WELLS FARGO BANK, a National
Banking Association
Counsel of Record for This Party:
REBECCA KEATING LEVENTOPOULOS
PA LD. # 90439
Payne, Welsh & Klingensmith
105 Penn Plaza
Turtle Creek, PA 15145
FIRM #658
(412)823-8100
THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION
OBTAINED SHALL BE USED FOR THAT PURPOSE.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
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Defendants. )
PRAECIPE FOR DEF AUL T JUDGMENT
WELLS FARGO BANK NA,
a National Banking Association
Plaintiff,
vs.
THEODORE HILL and KIMBERLY
HILL,
CIVIL DIVISION
NO.:
TO: Cumberland County Prothonotary
1 Courthouse Square
Carlisle, P A 17013
Kindly enter judgment in favor of the Plaintiff and against the above named Defendants in
the amount of$22,773.43, plus costs and interest. An Important Notice was served upon Defendants
on September 29,2005 and is hereby attached as Exhibit "A".
Date: /0-1)-05
Respectfully Submitted,
Payne, Welsh & Klingensmith,
By: ~~~1
Rebecca Keating LeventlJpoulos
Pa. LD. No. 90439
Attorney for Plaintiff
l-z-
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WELLS FARGO BANK N.A.,
a National Banking Association
Plaintiff,
vs.
THEODORE HILL and KIMBERLY
HILL,
Defendants.
JURY TRIAL DEMANDED
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CIVIL DIVISION
NO.: 05-04395
IMPORTANT NOTICE
Filed on behalf of Plaintiff
WELLS FARGO BANK, a National
Banking Association
Counsel of Record for This Party:
REBECCA KEATING LEVENTOPOULOS
PA LD. # 90439
Payne, Welsh & Klingensmith
105 Penn Plaza
Turtle Creek, PAl 5 145
FIRM #658
(412)823-8100
TillS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION
OBTAINED SHALL BE USED FOR THAT PURPOSE.
EXHIBIT
I~
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WELLS FARGO BANK NA,
a National Banking Association
Plaintiff,
vs.
THEODORE liLL and KIMBERLY
liLL,
Defendants.
TO:
Kimberly Hill
162 Ken Lin Drive
Carlisle, P A 17013
tf- 21- 07
DATE OF NOTICE:
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CIVIL DIVISION
NO.:
IMPORTANT NOTICE
YOU ARE IN DEF AUL T BECAUSE YOU HAVE FAILED TO ENTER A
WRITTEN APPEARANCE PERSONALLY OF BY ATTORNEY AND FILE IN
WRITING WITH THE COURT DEFENSES OR OBJECTIONS TO THE CLAIMS SET
FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE
OF THIS NOTICE, A JUDGMENT MAYBE ENTERED AGAINST YOU WITHOUT A
HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT
RIGHTS.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU
DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH
BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT
HIRING A LAWYER.
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
4th Floor, Cumberland County Conrthouse
Carlisle, PA 17013
(717) 240-6200
66:i~
Attorney for Plaintiff
DATE: 4.- 21--0?,
CERTIFICATE OF SERVICE
I hereby certifY that a true and correct copy of the within IMPORTANT NOTICE was
served by O.S, Mail, first class, postage prepaid, upon the following:
Kimberly Hill
162 Ken Lin Drive
Carlisle, P A 17013
Theodore Hill
162 Ken Lin Drive
Carlisle, PA 17013
q~ 2q- 05
~l::'4+~~
DATE
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA
WELLS FARGO BANK N.A.,
a National Banking Association
Plaintiff,
vs.
THEODORE HILL and KIMBERLY
HILL,
Defendants.
JURY TRlAL DEMANDED
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CIVIL DIVISION
NO.: 05-04395
IMPORTANT NOTICE
Filed on behalf of Plaintiff
WELLS FARGO BANK, a National
Banking Association
Counsel of Record for This Party:
REBECCA KEATING LEVENTOPOULOS
PA LD. # 90439
Payne, Welsh & Klingensmith
105 Penn Plaza
Turtle Creek, PA 15145
FIRM #658
(412)823-8100
THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION
OBTAINED SHALL BE USED FOR THAT PURPOSE.
EXHIBIT
I ~ II"
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA
WELLS FARGO BANK NA,
a National Banking Association
Plaintiff,
vs.
THEODORE HILL and KlMBERL Y
HILL,
Defendants.
TO: Theodore HilI
162 Ken Un Drive
Carlisle, PA 17013
DATE OF NOTICE:
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CIVIL DIVISION
NO.:
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A
WRITTEN APPEARANCE PERSONALLY OF 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 TillS NOTICE, A JUDGMENT MAYBE ENTERED AGAINST
YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER
IMPORTANT RIGHTS.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU
DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH
BELOW. TillS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT
fiRING A LAWYER.
IF YOU CANNOT AFFORD TO fiRE 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.
DATE:
Lawyers Referral Service
4th Floor, Cumberland County Courthouse
Carlisle, P A 17013
(7 17) 240-6200
r -- )&J~o 5
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the within IMPORTANT NOTICE was
served by U.8. Mail, first class, postage prepaid, upon the following:
Kimberly Hill
162 Ken Lin Drive
Carlisle, P A 17013
Theodore Hill
162 Ken Lin Drive
Carlisle, P A 17013
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DATE /
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Rebecca Keating Leventopoulos, Esquire
CERTIFICATE OF SERVICE
I hereby certifY that a true and correct copy of the within PRAECIPE FOR DEFAULT
JUDGMENT was served by U.S. Mail, first class, postage prepaid, upon the following:
Kimberly Hill
162 Ken Lin Drive
Carlisle, PA 17013
Theodore Hill
162 Ken Lin Drive
Carlisle, P A 17013
(tJ - (1 - e;5"
DATE
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WELLS FARGO BANK N.A.,
a National Banking Association
Plaintiff,
vs.
CIVIL DIVISION
NO.: OS-04395
NOTICE OF INTENTION TO
FILE PRAECIPE FOR ENTRY OF
DEFAULT JUDGMENT OF REVIVAL
Filed on behalf of Plaintiff
WELLS FARGO BANK, a National
Banking Association
THEODORE HILL and KIMBERLY
HILL,
Defendants.
Counsel of Record for This Party:
ANTHONY S. POSA, ESQUIRE
PA I.D. # 89777
Payne, Welsh & Klingensmith
105 Penn Plaza
Turtle Creek, PA 15145
FIRM #658
(412)823-8100
JURY TRIAL DEMANDED
THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION
OBTAINED SHALL BE USED FOR THAT PURPOSE.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WELLS FARGO BANK N.A.,
a National Banking Association
CIVIL DIVISION
NO..
Plaintiff,
vs.
THEODORE HILL and KIMBERLY
HILL,
Defendants.
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION
REQUIRED OF YOU IN THIS CASE. 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
4`" Floor, Cumberland County Courthouse
Carlisle, PA 17013
(717) 240-6200
DATE: ~D '05 ~o ~ / U '~~°~ ~
Anthony S. Posa, Esquire
Attorney for Plaintiff
` 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WELLS FARGO BANK N.A.,
a National Banking Association
CIVIL DIVISION
NO..
Plaintiff,
vs.
THEODORE HILL and KIMBERLY
HILL,
Defendants.
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the within NOTICE OF INTENTION
TO FILE PRAECIPE FOR ENTRY OF DEFAULT JUDGMENT OF REVIVAL was
served by U.S. Mail, first class, postage prepaid, upon the following:
Kimberly Hill
162 Ken Lin Drive
Carlisle, PA 17013
Theodore Hill
162 Ken Lin Drive
Carlisle, PA 17013
DATE Anthony S. Posa, Esquire