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Home My WebLink About05-4619 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION BROOKVILLE ACQUISITIONS Plaintiff No: Of; - 4t.,! cr (!1~l'(/kVVJ vs. COMPLAINT IN CIVIL ACTION SHAUNA COOK Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt,42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 Seventh Avenue, Suite 2718 Pittsburgh, PA 15219 (412) 434-7955 FAX: 412-338-7130 04305412 C A Pit KMJ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION BROOKVILLE ACQUISITIONS Plaintiff vs. Civil Action No or-IfI.I"/ SHAUNA COOK 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, BROOKVILLE ACQUISITIONS 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: SHAUNA COOK 923 SPRING CIR MECHANICSBURG, PA 17055 3. Defendant applied for and received a credit card bearing the account number 4791060011584918 . 4. Defendant made use of said credit card and has a current balance due of $1866.06 , as of August 09, 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 09, 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 , SHAUNA COOK , individually , in the amount of $1866.06 with continuing interest thereon at the rate of 6.000% per annum from August 09, 2005 plus costs. /~ ~ . Warmbrodt,42524 , WEINBERG & REIS CO., L.P.A. venth Avenue, Suite 2718 urgh, PA 15219 434-7955 412-338-7130 05412 C A Pit KMJ This law firm is a debt collector at empting to collect this debt for our client and any information obtained will be used for that purpose. Brookville Acquisitions Group LLC Please indicate N arne, or address cL\'j)~2- Telephone Changes Home ( ) Work ( ) Charge-Off Statement ACCOUNT NUMBER PAYMRNT PAST DUE MINIMUM NEW AMOUNNT OF DUE DATE AMOUNT PAYMENT BALANCE r A YMENT ENCLOSED 4791 0600 1158 4918 03/18/2002 1152.25 510.53 1231.39 $ SHAUNA COOK 62 W MAIN NEW KINGSTOWN PA 17072 l'IlIlIlIIlLIII.I"IL"Lrl,IIIII",II",I.III'IIIIIl.llIrll 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~ --CRElJIT--- CREDIT DAYS IN BILL PAYMENT MINIMUM LINE AVALIABLE BILLING CYCLE DATE DUE DATE PAYMENT DUE 4791 0600 1158 4918 800.00 32 03/03/2002 03/18/2002 510.53 DATE OF TRANS POST REfERENCE NUMBER DESCRIPTION OF TRANSACTIONS AMOUNT 0303 0303 OVERLIMIT FEE 29.00 0000 0000 LATE CHARGE" MIN PYMT NOT REeD BY DATE 35.00 u~* fiNANCE CHARGE CURRENT PURCHASE 15.14 PREVIOUS NEW PURCHASES DEBIT FINANCE OVERLINE NEW BALANCE PAYMENTS CREDITS AND ADVANCES ADJUSTMENTS CHARGES AMOUNT BAl.ANCE 1152.25 ,00 ,00 ,00 64,00 79.14 431.39 1231.39 AN AMOUNT FOLLOWED BY A MINUS SIGN(-} IS A CREDIT BALANCE UNLESS OTHERWISE INDICATED $ TYPES OF CREDIT TO FINANCE DAYl.Y NOMINAL ANNUAL ANNUAL WHICH RATES APPl. Y CHARGE BAl.ANCES PERIODIC RATE PERCENTAGE RATES PERCENTAGE RATES PURCHASES 1152.25 .04106 % 14.99% 14.99% ADVANCES .06299% 22.99% % YOU MAY AVOID ADDITiONAL FINANCE CHARGES ON PURCHASES IF YOU PAY THIS AMOUNT BY THE DUE DATE QUESTIONS about account? Credit Card lost or stolen? Call Customer Service 24 hours a day 7 days a WL'ek, toll- free at 1w800-277-4431 Para Servicio al Cliente en espafiol: 1-800-277-4431 EXHIBIT I VERIFICATION The undersigned does hereby verify subject to the penalties of 18 P A.C.S. 94904 relating to unsworn falsifications to authorities, that he/she is J.1a.c:~;' ~ ka I la-I" (Name) I of .,;&r DZlJ:..V i II ~ * ~ I); ,<y..,.,' D >'S , plaintiff herein, that (Company) ~je ;q- (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 of his /her knowledge, information and belief. (Signature) WWR# ell 30 5tf,~ * ~ -YJ. t Lrc .01 ...... ~ .... U[ ~ D D 6"- ~ ~ -U 0) ~ ~ ~ t-- '--'- ('1 ",' , ~ 0 c,..) e;...F1 ., (/) ::J f'r-} , ,". .., " il r--';: I :::] ,-n C-j _J -') 1 c:; --J , --.- ~ (;'? :-) , n ;~~l (,.) ~,).j "" ..< (;) SHERIFF'S RETURN - REGULAR CASE NO: 2005-04619 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BROOKVILLE ACQUISITIONS VS COOK SHAUNA RONALD HOOVER Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon COOK SHAUNA the DEFENDANT , at 2000:00 HOURS, on the 14th day of September, 2005 at 923 SPRING CIRCLE MECHANICSBURG, PA 17055 by handing to JOHN COOK, FATHER 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 18.00 8.00 .00 10.00 .00 36.00 So Answers: .,$>?-' ",;7' _ ,~~ '1-;tfl~ ;;~p::~e',(x:':'c'~'_. ~.,"/"'.."..(~~ , ' R. Thomas Kline JG day of 09/15/2005 WELTMAN WEINBERG REIS By: ~~/' Deputy Sher}A'f Sworn and Subscribed to before me this , 4' ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION BROOKVILLE ACQUISITIONS Plaintiff No,05-4619-CIVIL vs, SUGGESTION OF BANKRUPTCY SHAUNA COOK Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt PA I.D #42524 WELTMAN, WEINBERG & REIS CO, L.PA 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#04305412 . , IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION BROOKVILLE ACQUISITIONS Plaintiff vs, Civil Action No 05-4619-CIVIL HAUNA COOK Defendant SUGGESTION OF BANKRUPTCY o PROTHONOTARY: AND NOW comes Plaintiff, by counsel, Weltman, Weinberg & Reis, Co., L.P A. to advise this onorable Court that the above named Defendant, SHAUNA COOK, has filed a Chaper 7 Bankruptcy n the United State Bankruptcy Court for the middle District of Pennsylvania at Bankrupky Case Number 5-08863, and accordingly, all proceedings in this Court are stayed pursuant to 11 U.S.C ,362. WELTMAN, WEINBERG & REIS CO, U A 1 " ," ,I g .c._... -ofr' cp,+'. ~.~~.," <D';' _.~ .., ~\. 2--;C ",-c> J;.c ~ .....> "" = "" ~ '""" I .- ~ $.~, -o}!.i ~"jy 6(') --\......'\ ~c --r (~~-=) ;C,rn ~\ ~ :~ ~ ...p, CI tJ. . . .. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION BROOKVILLE ACQUISITIONS Plaintiff No, 05-4619-CIVIL vs, PRAECIPE TO SETTLE, DISCONTINUE AND END WITHOUT PREJUDICE TO REFILE SHAUNA COOK Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: JAMES C. WARMBRODT PA ID #42524 WELTMAN, WEINBERG & REIS CO, LPA 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#04305412 . . IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION BROOKVILLE ACQUISITIONS Plaintiff vs, Civil Action No. 05-4619-CIVIL SHAUNA COOK 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 SUBSCRIBED before me thiS! t/IJ day of /lJOtfJ I:Mr , 2005 lain If s Building Avenue PA 15219 -7955 305412 IC r-----~----.-.._,--_ I Nolaria! Seal --'-j , , Woody L Gault. Notary Public ,~~ry_Cf P1ttsburgh, Alleghenv,' CO, UAty '" r'n-;m..c,<::,pn Ex;)i~e5 L!ulv 15.2006 -" S;, ~::;'\ - C) o -on ...... :r: C;\ (j\ """"'" - '---~':.? :r C'.