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Home My WebLink About05-6529 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CACV OF COLORADO Plaintiff No: O~ -~r:J..9 C;ull~~ vs. COMPLAINT IN CIVIL ACTION JANICE L JONES 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) 434-79!55 FAX: 412-338-7130 04651859 CEPit VOC - IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CACV OF COLORADO Plaintiff vs. civil Action No JANICE L JONES 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. HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IF YOU DO NOT THE OFFICE SET 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, CACV OF COLORADO is a corporation with offices at 370 17TH ST. ,SUITE 5000 DENVER, CO 80202 . 2. Defendant is adult individual(sl residing at the address listed below: JANICE L JONES 3 KAIL AVE SHIPPENSBURG, PA 17257 3. Defendant applied for and received a credit card bearing the account number 5183373230013004 . 4. Defendant made use of said credit card and has a current balance due of $6004.67 , as of November 30, 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 November 30, 2005 . A copy of Plaintiff's 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 , JANICE L JONES , INDIVIDUALLY , in the amount of $6004.67 with continuing interest thereon at the rate of 6.000% per annum from November 30, 2005 plus costs. > ./ . E1!:!:::V / WELT i WEINBERG & REIS CO., L.P.A. 436 S~?nth Avenue, Suite 2718 pittsburgh, PA 15219 (412) 4/34 -7955 FAX: 4;t2-338-7130 0,4'65159 CEPit VOC This law firm is a debt collector at~ting to collect this debt for our client and any information obtained will be used for that purpose. Pageldl '''';;; iJ"-/06 i :. r , v 0cl121OD5 ACCOUNT NUMBER: 5183 373230013004 PAYMENT DUE DATE I NEWeALANCE I MINIMUM DUE 11/2312003 W.OO $0.00 JANICE L JONES 3 KAIL AVE SHIPPENSBURG PA 17257-8229 Facsimile """ Copy o CHASE Chase Platfnum MasterCard- ACCOUNT NUMBER: 5183 3132 3("" 31J11~ NEW PAYMENT TOTAl. TOTAl STATEMENT BALANCE DUE DATE CREOlT LINE ,",",",'LABLE CREDIT CLOSING D,",TE $0.00 11J2312OO3 S4.5lIO $0.00 1012912003 Here is your At<<>unt Summary: TOTAl ~v1ous; BAhlnce $6.004.61 (-) Payments, Credits 6.004.57 (+) Purchaaea-. Caef"I, Debita 0,00 (.., FINANCE CHARGES 0.00 t=\_llal"""" 0,00 MirimJm PEWment Due $0.00 Here are your Cha"i'" and Credits at" glance: TAAN. fOST REf. DATE DATE NO DESCRIPTION OF TRANSACTIONS CREDITS CHARGES 10129 10/29 99GO CHARGE OFF ACCQUNf-PRINCIPALS 4,_.28 '012. 10f.2& 01100 CHARGE OFF "CCQUNT aFJNANCE CHA~GES. 1.~.39 Here's bow WI: dl:lI:nnined your Finance Charge': TelaI 01 your eredits and charges DRY' in BiDing CyeJc: 30 6,004.67 0.00 NOMINAl O!\IL"I AVERMlE PERIODIC/MIN. TOTAL ANN UAL ANNUAL PERIODIC DAlI.Y fiNANCE FINANCE PERCENTAGE PERCENTAGI RATE SAU\NCE CHARGE CHARGE RATE AATE ea.. 0.06573% 5000 "'.00 $0.00 23.519'!4 0.00" Purchases 0.055731> '0,00 SO.OO $0.00 23.99% O.oar. . PlIKl6e Gee feYerse &id~ tor tNlIanQtt computation method ilJ"ld other rnportant Information. Questions abotR your aceourtr7 Credit Card Ioster 5b:lIen1 CBn Cnase CU$toIl'ler Se-rvice 24 hout'5 a Day, 7 ~ a '""""eft, toll-frliil', .. 1-800-334-0601 Qrwrlte P.O. BOX 15e59. Wilmington, DE 1985B.S659. ParaSerkioal Clienteen Eerpal'lol: 1-800-!545~0464. EXHIBIT / Page faf1 VERIFICATION The undersigned does hereby verify subject to the penalties of 18 P A. C.S. 4904 relating to unsworn falsifications to authorities, that he/she is ::J;;t.,.; &.k,. (NAME) lie",1 Aag-f Exu.wJ;v~ he em, that (TITLE) of cA<-v,;.t- r..1.r~ , plaintiff (COMPANY) he/she is duly authorized to make this verification, and that the facts set forth in the foregoing Complaint are true and correct to the best of his /her knowledge, information and belief. ~~ ~e-- (SIGNATURE) 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. WWR#0465l859 -'C. P (:) Uf. 13 7'i. l0 t if( ,...., ~ c:~ C>J Q ",,, --' <:", <OJ' ~ 'f?, 4:n - "~- (i c- ()J -0' rn -...l ~:';\,.:' c-> :$',C( ~ ~ ~ ~7 - -/')j , ,,'or, ..0 ~:U ""<::J :> ".,-~ ' ~ ;:'-~1(~ b (; '.::-~, (1'\ i;c' 0 - ___l '~_':' c.; - ~PS:, .' ,<jj-) --...c...... - ""- :2 fV - -- SHERIFF'S RETURN - REGULAR CASE NO: 2005-06529 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CACV OF COLORADO VS JONES JANICE L SHANNON SHERTZER Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon JONES JANICE L the DEFENDANT , at 1440:00 HOURS, on the 27th day of December, 2005 at 3 KAIL AVENUE SHIPPENSBURG, PA 17257 by handing to ERIC JONES, HUSBAND a true and attested copy of COMPLAINT - MORT FORE 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 19.20 .00 10.00 .00 47.20 .re>' <:/~ 4''i~ , R. Thomas Kline me this /I"'" / day of 12/28/2005 WELTMAN WEINBERG REIS ic?l~ f C;!~ Deputy Sheriff By: Sworn and Subscribed to before A.D. .. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CACV OF COLORADO, LLC Plaintiff No, 05-6529 CIVIL TERM vs. PRAECIPE FOR DEFAULT JUDGMENT JANICE L JONES Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY William T Molczan PA 10 #47437 WELTMAN, WEINBERG & REIS CO, LPA 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434.7955 WWR#04651859 Judgment Amount $ 6072.78 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 CACV OF COLORADO, LLC Plaintiff vs. Civil Action No 05.6529 CIVIL TERM JANICE L JONES Defendant PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY Kindly enter Judgment against the Defendant, JANICE L JONES above named, in the default of an Answer, in the amount of $6072.78 computed as follows: Amount claimed in Complaint $6004.67 Interest from November 30, 2005 to February 7, 2006 at the contract interest rate of 6% per annum $68,11 TOTAL $6072. 78 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: William T. olczan PA 10 #47437 WELTMAN, WEINBERG & REIS CO, LPA 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434.7955 WWR#04651859 Plaintiff's address is' c/o Weltman, Weinberg & Rei5 Co., LPA, 2718 Koppers Building, 436 th Avenue, Pittsburgh, PA 15219 And that the last known address of the Defendant is: 3 KAIL AVE, SHIPPENSBURG,PA 17257 ~ . IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CACV OF COLORADO Plaintiff Case # OS-(;:,':)C(l c'J\ne[(lil JANICE L JONES Defendant(s) IMPORTANT NOTICE TO: JANICE L JONES 3 KAIL AVE SHIPPENSBURG,PA 17257 Date of Notice: WWR#: 04651859 \- <: '-\ -OeD 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 PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE FOLLOWING 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 CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 ~" _.,.---------:/ '----/' .~ /' .....'''-'-............. BY: JAMES W PA I.D. 42524 WELT~~' WEINBERG & REIS CO., L.P.A. 2718[K PERS BLDG, 436 7TH AVE. PIT\S RGH, PA 15219 " ~ IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CACV OF COLORADO, LLC Case no: 05-6529 CIVIL TERM Plaintiff NON-MILITARY AFFIDAVIT vs. JANICE L JONES 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 the within matter. Affiant further states that the within Affidavit is made pursuant to and in accordance with the Servicemembers' Civil Relief Act (SCRA), 50 US.C App. S 521. Affiant further states that based upon investigation it is the affiant's belief that the Defendant, JANICE L JONES 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, JANICE L JONES is not in the military service. Further Affiant sayeth naught j[' d1 ~ A~T f,; _ SWORN TO AND SUBSCRIBED In my presence thlS..!:L day of ~L'{ cOuw NOTARY'pWBtfC '-l / 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. ~equest for Military Status Page 1 of 1 Department of Defense Manpower Data Center Ei)".' >0;''''.., Military Status Report t>1', ?,', Pursuant to the Service Members' Civil Relief Act 1IIl" .' FEB-07-200607:03:24 ... Last Name First/Middle Begin Date I Active Duty Status -r.~crvicc/ Agency JONES JANICE L 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 ofthe individual, per the Information provided, as to all branches of the Military. -,..,-..-, ---'"~--_... - ~-,/ ..::> .,: . r:-o ~~j. J \":;r. 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 of the 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, SS 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 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 rcf1ects current active duty status only, For historical information, please contact the military services SCRA point of contact. See: http://www.defenselink.millfaq/pis/PC09SL D R,html, WARNING: This certificate was provided based on a name and Social Security number (SSN) provided by the requester. Providing an erroneous name or SSN will cause an erroneous certifieate to be provided. Report /D'RMlfZJRWAWT https:/ /www.dmdc.osd.mil/scra/owa/scra. pre .Select 2/7/2006 ~^i r 3 ~ ~ ~ r--- (:) .t,q. ~~ ~~ U () -,I ~'~ ::J G.J {'il:>:: ,'-- Z~ =r P:i <I -'0 (;'~) r,) en - ., " IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CACV OF COLORADO, LLC Plaintiff vs, Civil Action No 05.6529 CIVIL TERM JANICE L JONES Defendant NOTICE OF JUDGMENT OR ORDER TO () Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the following Order D<.:!.!!dbment was entered against you on J-i:;;)_ I J 2()A(- I ~ (xx) Assumpsit Judgment in the amount of $6072 78plus costs. Trespass Judgment In the amount of $ plus costs () If not satisfied within sixty (60) days, your motor vehicle operator's license andlor 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 JANICE L JONES 3 KAIL AVE SHIPPENSBURG,PA 17257 ::"",:- PRO, ONO} R EPUTY) Plaintiffs address IS c/o Weltman, Weinberg & Reis Co" LP A, 2718 Koppers Building. 4367'" Avenue, Pittsburgh, PA 15219 1-888-434-0085 '" ....) -. , ,I IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CACV OF COLORADO, LLC Plaintiff vs. Civil Action No. 05-6529 CIVIL TERM JANICE L JONES Defendant PRAECIPE FOR SATISFACTION OF JUDGMENT At the request of the undersigned attorneys for the Plaintiff, you are directed to satisfy the above-captioned Judgment. WELTMAN, WEINBERG & REIS CO., L.P.A. By: William T. Molczan, Es PA LO. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh A venue Pittsburgh, P A 15219 (412) 434-7955 WWR #04651859 Sworn to an~ SU~~d ~ before me this . -J day of Jtf11$,' 06 NOT~ Notarial Seal Wendy L. Gault, Notar{ Public City at Pittsburgh, Aileghel'lY COl:lrrty ~lv CO!TIrrission EXD)re:s Jul,:/ 15, 200~_ -_.-.."---~- ... " .,' ;~ ~~.-''''' Q~" <:. --~-: --I 2; (,) c,