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Home My WebLink About05-6079A IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREAT SENECA FINANCIAL CORP. No. S ?07? (2t v ASSIGNEE OF AMERICAN DEBT SALES ASSIGNEE OF DIRECT MERCHANTS CREDIT CARD BANK, N.A P.O. BOX 1651 ROCKVILLE MD 20849-1651 Plaintiff VS JEANNINE M SHUTT 820 LISBURN RD #306 CAMP HILL PA 17011 Defendant(s) CIVIL ACTION - LAW Filed on behalf of: Plaintiff, GREAT SENECA FINANCIAL CORP. Counsel of record for this party: Date: Amy F. Doyl 87062 aniel F. Wolfson #20617 Philip C. Warholic #86341 / Andrew C. Spears #87737 David R. Galloway #87326 / Tonilyn M. Chippie #87852 Bruce H. Cherkis #188371 Ronald S. Canter #94000 Ronald M. Abramson #94266 WOLPOFF & ABRAMSON, L.L.P. Attorneys in the Practice of Debt Collection 4660 Trindle Road, 3rd Floor Camp Hill, PA 17011 Telephone: (717) 303-6700 Counsel for Plaintiff W&A File No. 145564721 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION GREAT SENECA FINANCIAL CORP. ASSIGNEE OF AMERICAN DEBT SALES ASSIGNEE OF DIRECT MERCHANTS CREDIT CARD BANK, N.A Plaintiff ARBITRATION DOCKET VS JEANNINE M SHUTT Defendant(s) No. OS - t ,0'7/ Hearing 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 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. LAWYER REFERRAL SERVICE - CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDORD STREET CARLISLE, PA 17013 (717)249-31667(800)990-9108 OU HAVE BEEN SUED IN COURT. The above Notice to Defend explains what you must do to dispute the yo ile the written response referred to in the Notice to Defend, a hearing before a board of arbitrator Room o Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvam _ at 9:00 am. IF FAIL TO FILE THE RESPONSE DESCRIBED IN THE NOTICE TO A JUDGMENT FOR THE RE THE HEARING. AMOUNT CLAIMED TIE-COMPLAINT MAY BE ENTERED AG=ONHEARING H TO APPEAR AT ARBIT If one or more of the Parties is not present at the heihingi- ATTER MAY BE HEARD AT THE SAME TIME AND DATE BEFORE A JUDGE OF THE COURT WITHOUT T IsjVT PARTY OR PARTIES. THERE IS NO RIGHT TO A TRIAL DE NOVO ON APPEAL FROM A DECISION E D BY A JUDHB, . NOTICE: YOU MUST RESP O THIS COMPLAINT WITHIN TWENTY (20) DAYS OR A JUDGMENT-FOR THE AMOUNT CLAIMED E ENTERED AGAINST YOU BEFORE THE HEARING. IF ONE OR MORE OF THE PARTIES IS NOT PRESE T THE HEARING, THE MATTER MAY BE HEARD IMMEDIATELY BEFORE A JUDGE WITHOUT THE.,` AB T PARTY OR PARTIES. THERE IS NO RIGHT TO A TRIAL DE NOVO ON APPEAL FROM A DECISION E?' J 1 EQ 1 A JUDGE. ` place in W&A File No. 145564721 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREAT SENECA FINANCIAL CORP. No. d S- Co U?J 9 l [ v h £Q?, ASSIGNEE OF AMERICAN DEBT SALES ASSIGNEE OF DIRECT MERCHANTS CREDIT CARD BANK, N.A Plaintiff VS CIVIL ACTION - LAW JEANNINE M SHUTT Defendant(s) COMPLAINT AND NOW, comes the Plaintiff, by and through its attorneys and the law firm of Wolpoff & Abramson, LLP, and files this Complaint and in support avers as follows: Plaintiff, Great Seneca Financial Corp., P.O. Box 1651 Rockville, MD 20849-1651 is a business entity doing business within the Commonwealth of Pennsylvania and the other states of the United States. 2. Defendant, Jeannine M Shutt, is an adult individual with a last known address of 820 Lisburn Rd #306 Camp Hill, Cumberland County, PA 17011. 3. It is averred that Defendant(s) was/were issued an open end credit account by Plaintiff (hereinafter "Account"). 4. At all relevant times material hereto, Defendant(s) have/has been regular users(s) of said Account for the purchase of products, goods and/or for obtaining services. 5. Plaintiff provided Defendant(s) with copies of the Statement of Accounts showing all debits and credits for transactions on the aforementioned credit card account to which there was no bona fide objection by Defendant(s). A true and correct copy of the Statement of Account is attached hereto, incorporated herein and marked as Exhibit "A". CCP Cmplt- WOR W&A File No. 145564721 Defendant did not object to the above-mentioned statement submitted by Plaintiff and/or its assignors to Defendant. 7. As of the date of this Complaint, the remaining balance due, owing and unpaid on Defendant's credit card account as a result of the charges made by said Defendant(s) and/or any authorized users is the sum of $7,616.45. Pre-judgment interest has accrued from the charge off date at a rate of 16 %. As of the date of the filing of this Complaint, the amount of interest which has accrued is the sum of $3,333.97. 10. As of the filing of this Complaint, Plaintiff has incurred reasonable attorney's fees from the law office of Wolpoff & Abramson, LLP in the collection of the amounts due from Defendant(s) incident to the within action based upon 25 % of the principal amount due and owing, and Plaintiff shall continue to incur such attorney's fees through the conclusion of the proceedings. 11. The amount of attorney's fees which has accrued is the sum of $1,523.29. 12. Despite reasonable and repeated demands for payment, Defendant(s) has/have refused and continue to refuse to pay all sums due and owing on the aforementioned account balance, all to the damage and detriment of the Plaintiff. 13. Plaintiff performed any and all conditions precedent to the bringing of this action. 14. The amount in controversy is within the jurisdictional amount requiring compulsory arbitration. CCP Cmplt - WOR W &A File No. 145564721 WHEREFORE, Plaintiff respectfully requests this Honorable Court enter Judgment in favor of the Plaintiff and against Defendant(s) in the amount of $7,616.45, plus interest in the amount of $3,333.97, plus attorney's fees in the amount of $1,523.29, plus costs of this action and any other relief as this Court deems just and reasonable. Respectfully Submitted, Date: Amy F. Doylyr 8706 Daniel F. Wolfson #20617 Philip C. Warholic #86341 / Andrew C. Spears #87737 David R. Galloway #87326 ! Tonilyn M. Chippie #87852 Bruce H. Cherkis #18837 / Ronald S. Canter #94000 Ronald M. Abramson #94266 WOLPOFF & ABRAMSON, L.L.P. Attorneys in the Practice of Debt Collection 4660 Trindle Road, 3rd Floor Camp Hill, PA 17011 Telephone: (717) 303-6700 Counsel for Plaintiff CCP Cmplt - WOR W &A File No. 145564721 VERIFICATION The undersigned hereby states that they are the attorney for the Plaintiff who is located outside of this jurisdiction and in order to file the within document in an expedient and timely manner, they are authorized to take this verification on behalf of said Plaintiff in the within action and verifies that the statements made in the foregoing Pleading are true and correct to the best of their knowledge, information, and belief, based upon information provided by the Plaintiff. The undersigned understands that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unworn falsification to authorities. Date: (? l ?l 4?41? Amy F. Doy'44 87064 / Daniel F. Wolfson #20617 'P 1 Philip C. Warholic #86341 / Andrew C. Spears #87737 David R. Galloway #87326 / Tonilyn M. Chippie #87852 Bruce H. Cherkis #18837 / Ronald S. Canter #94000 Ronald M. Abramson #94266 WOLPOFF & ABRAMSON, L.L.P. Attorneys in the Practice of Debt Collection 4660 Trindle Road, 3rd Floor Camp Hill, PA 17011 Telephone: (717) 303-6700 Counsel for Plaintiff CCP Cmplt - WOR W&A File No. 145564721 Exhibit "A" I W a m N W h O h h W o W m Z N O N H N VVjI O !? O m m a a a In o d u z ?d z L H F W F O a V U Q 5 m m m b ti 0 a N N N O H Z N v v N N a b m H N z N r n .Ni m 0 0 v m P ill P II b W 11 W F Z w F U w a xy a m m qyF 2 F o N W N m \ E a P o ? b N \ N O b VI b O II II aF n Q0 W ? ,?`?9 Z U£ a Y Z Sb??? ? U r F O ? vFa? O m r] U m a O F b a £ 'J m H a m h [al N £a N Z E rWl qW H ? a W £ n n u W O T o a e m { z O \ Iai rv o m P z .'L W Oo m0 ° s P ?n %% b F a \ P n [L .hi m % rl (f(?F/j/??? ?a q n II % ? o o °n N? W C 'J% ? N W£ N % a u O? 11 N VUUVV II fl %' O WNW WN 'qN' N N II ? II F W II II II O N fl II N II II a o?, p!py fA VI N N II NI N II II aF a ? ,Z O H g F Q ry a w Z U q o ry R w a a z F w m F c/ w? y Sy y Yy q H F vi p W W W p p F H W p z p W m ff 3 a a' U vi N m 3 N? m W m 4 Q U m N 2 3 ?n ? H 2 O a O m 7 Vt _ 1 GJ `D SHERIFF'S RETURN - REGULAR CASE NO: 2005-06079 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND GREAT SENECA FINANCIAL CORP VS SHUTT JEANNINE ROBERT EITHER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE SHUTT JEANNINE M was served upon the DEFENDANT , at 1405:00 HOURS, on the lst day of December , 2005 at 820 LISBURN ROAD #306 CAMP HILL, PA 17011 by handing to JEANNIE M SHUTT 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 18 .00 Service 14 .40 Affidavit .00 Surcharge 10 .00 .00 42 .40 Sworn and Subscribed to before me this M P, day of c_e ,n d OL,5. D. Prothon ry So Answers: i l R. Thomas Kline 12/05/2005 WOLPOFF & ABRAMSON By: 4? CIA e Deputy Sheriff Curtis R. Long Prothonotary office of the Protbonotarp 10 Renee K. Simpson Cumberfanb Countp Deputy Prothonotary John E. Slike Solicitor 0S- L 07? CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 29TH DAY OF OCTOBER 2008 AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R C P 230.2 BY THE COURT, CURTIS R. LONG PROTHONOTARY ^-- n.....#U--. C^-a • ('arNelP Dnnnevluania 17nvi . (7171 ')A(1 4104 . C.... /717%')AA AG74