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Home My WebLink About06-0760IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CACV OF COLORADO Plaintiff vs. LISA CURTIS Defendant No: U, - 110 COMPLAINT IN CIVIL ACTION 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 04534222 C E Pit NMS IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CACV OF COLORADO Plaintiff VS. Civil Action No LISA CURTIS 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, CACV OF COLORADO is a corporation with offices at 370 17TH ST.,SUITE 5000 DENVER , CO 80202 2. Defendant is adult individual(s) residing at the address listed below: LISA CURTIS 70 MANADA CREEK CIR CARLISLE, PA 17013 3. Defendant applied for and received a credit card bearing the account number 5491041770096195 . 4. Defendant made use of said credit card and has a current balance due of $4441.70 , as of December 22, 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 0.240% per annum on the unpaid balance from December 22, 2005 . A copy of Plaintiff's is attached hereto, marked as Exhibit 111" 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 , LISA CURTIS , INDIVIDUALLY , in the amount of $4441.70 with continuing interest thereon at the rate of 0.240°% per annum from December 22, 2005 plus costs. o 4252 BERG & REIS CO., L.P.A. venue, Suite 2718 A 15219 55 -7130 T12-338-7130 Pit NMS ollect this debt for This law firm is a debt collector attempting to c our client and any information obtained will be used for that purpose. page 1 of 1 PAYMEMTOUE DATE `` NEW BALANCE MINIMUM DUE O9NG@004 1 $0.00 I 90.00 - j Nov 612005 ACCOUNT NUM9ER_ 5491 0417 7009 6195 Facsimile LISA CURM Im 70 MANADA CREEK CIR CARLISLE PA 17073-9668 Copy O CHASE Chao Plaunum MasterCard- ACCOUNT NUMBER: 5491 (1417 70" 6195 NEW PAYMENT TOTAL TOTAL STATEMENT BALANCE DUE DATE CREDIT LINE AVAILABLE CREW CLOSING DATE 50.00 tw1la 2004 53.300 $0-00 D8725y2004 Here is your Account Summary: TOTAL Pmvbua Balance 5/.441.70 (-) PaynleMa, Credta 3,238.81 (+) Purohons s. Cash, Dab" 0.00 I+) FINANCE CHARGES CAM (z) New Balance 0.00 Maamum Payment Due SO W Here are your Charges and Credits at a glance: TRAN. REF. OATF DATE DATE DATE NO DESCRIPTION OF TRANSACTIONS CREDITS CHAROE9 Dg23 0825 9980 CHARGE OFF ACCOUNT-PRINCIPALS 3,256.81 08223 08;25 9900 CHARGE OFF ACCOUNT `FINANCE CHARGES* 1,784.E I oral a your erepas am charges 3,236.81 0.00 Here's IoW we determined Your Finance Charge*: Ilavs I. RMliau \0 NOMINAL • DAILY AVERAGE PERIODh:/MIN. TOTAL ANNUAL ANNUAL PERIODIC DAILY FINANCE FINANCE PERCENTAGE PERCENTAGE RATE BALANCE CI4ARGE CHARGE RATE RATE Cash 007189% 5400 $MOD $0.00 26.24% 0.0096 Purchases 0.0718996 50.00 $0-00 $0.00 26.24% 0.00% Qlasaf Wns about yaa 0c ht? CMdt Card bd a stWen7 Call Chase Customer SaMm 24 ham a Day,? dWw a week, idl-hea, at 1-800-394-0801 "write, P ,O. BOX ISWS. Wilmitgtat DE 198895858. Para SerAtio al Clisrde an Esp%W: 1-800-545-0484. EXHIBIT Pape 1 of 1 VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA.C.S Section 4904 relating to unsworn falsifications to authorities, that he/she is Authorized Agent (Title) GA (Name) of 00 14 ) L? C ompany) plaintiff herein, that 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. 04534222 C E Pit NMS 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. _ (Z) 7? is in vi (Vi ?. r C'-v fa ?n c y IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CACV OF COLORADO, LLC Plaintiff vs. LISA CURTIS Defendant No. 06-760 CIVIL TERM PRAECIPE FOR DEFAULT JUDGMENT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#04534222 Judgment Amount $ 4444.97 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. LISA CURTIS Defendant TO THE PROTHONOTARY: Civil Action No. 06-760 CIVIL TERM PRAECIPE FOR DEFAULT JUDGMENT Kindly enter Judgment against the Defendant, LISA CURTIS above named, in the default of an Answer, in the amount of $4444.97 computed as follows: Amount claimed in Complaint $4441.70 Interest from 12/22/05 to 4/03/06 at the contract interest rate of 0.24% per annum $3.27 TOTAL $4444.97 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. WELTMAN, W NBERG & REIS CO., L.P.A. By. William T. Molczan PA I. D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#04534222 Plaintiff's address is: c/o Wellman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7`h Avenue, Pittsburgh, PA 15219 And that the last known address of the Defendant is: 70 MANADA CREEK CIR CARLISLE,PA 17013 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CACV OF COLORADO Plaintiff LISA CURTIS Defendant(s) IMPORTANT NOTICE TO: LISA CURTIS 70 MANADA CREEK CIR CARLISLE,PA 17013 Date of Notice: WWR#: 04534222 Case # ?l[; '?'U (_`y TLT?ah 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 TH:LS 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 s / n BY: JAMES WARMBRODT, ESQUIRE PA I.D. #42524 WELTMAN,/WEINBERG & REIS CO., L.P.A. 2718 KOPPERS BLDG, 436 7TH AVE. PITTSBURGH, PA 15219 IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CACV OF COLORADO, LLC Plaintiff vs. LISA CURTIS Defendant Case no: 06-760 CIVIL TERM NON-MILITARY AFFIDAVIT 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 U.S.C. App. § 521. Affiant further states that based upon investigation it is the affiant's belief that the Defendant, LISA CURTIS 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, LISA CURTIS is not in the military service. Further Affiant sayeth naught. f. J AFFIANT SWORN TO AND SUBSCRIBED in my of aw(-. NSTTARY P LI r presence this.-3- day 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. Request for Military Status Department of Defense Manpower Data Center w' Military Status Report Pursuant to the Servicemembers Civil Relief Act Page I of" APR-03-2006 09:41:24 d Last Name First/Middle Begin Date Active Duty Status Service/Agency CURTIS LISA 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, based on the information that you provided, the above is the current status of the individual as to all branches of the Military. Robert J. Brandewie, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd.. Suite 400 Arlington, VA 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 Servicemembers Civil Relief Act [50 USCS Appx. §§ 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 strongly encouraged to obtain further verification of the person's active duty status by contacting that person's Military Service via the "defenselink.mil" URL provided below. If you have evidence the person is on active-duty and you fail to obtain this additional Military Service verification, provisions of the SCRA may be invoked against you. If you obtain further information about the person ( e.g., an SSN, improved accuracy of DOB, a middle name), you can submit your request again at this Web site and we will provide a new certificate for that query. This response reflects current active duty status only. For historical information, please contact the Military Service SCRA points-of-contact. See: httj)-://www.defenselink.mil/faq/pis/PC09SLDR.htmi This certificate was provided based on a name and Social Security number (SSN) provided https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 4/3/2006 Request for Military Status Page 2 of 2 by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID. BSQPNICUPNL https://www.dmde.osd.mil/scra/owa/scra.prc_Select 4/3/2006 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CACV OF COLORADO, LLC Plaintiff vs. LISA CURTIS Defendant Civil Action No. 06-760 CIVIL TERM NOTICE OF JUDGMENT OR ORDER TO ( ) Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the following Order or J dgment was ent red against you on >q UFO (xx) Assumpsit Judgment in the amount of $4444.97plus costs. ( ) Trespass Judgment in the amount of $ plus costs. ( ) If not satisfied within sixty (60) days, your motor vehicle operator's license and/or 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 LISA CURTIS 70 MANADA CREEK CIR CARLISLE,PA 17013 c/o Weltman, Weinberg & Reis Co., L.P.A., Prothonotary By: 1 PROTHOf OTARY : UT Plaintiff's address is: 2718 Koppers Building, 436 7" Avenue, Pittsburgh, PA 15219 1-888-434-0085 9- SHERIFF'S RETURN - REGULAR CASE NO: 2006-00760 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CACV OF COLORADO VS CURTIS LISA DOUGLAS RUZANSKI , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon S LISA the DEFENDANT , at 0906:00 HOURS, on the 25th day of February , 2006 at 70 MANADA CREEK CIRCLE CARLISLE, PA 17013 LISA CURTIS by handing to 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 4.40 Affidavit .00 Surcharge 10.00 .00 32.40 Sworn and Subscribed to before me this aiak day of A. D. rotho r So Answers??JJ R. Thomas Kline 02/27/2006 WELTMAN WEINBERG REIS By. / eputybr eri :i r.? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CACV OF COLORADO, LLC Plaintiff vs. LISA CURTIS Defendant No. 06-760 CIVIL TERM PRAECIPE FOR WRIT OF EXECUTION FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan, Esquire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (41.2) 434-7955 WWR#04534222 M x ? . IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CACV OF COLORADO, LLC Plaintiff vs. LISA CURTIS Defendant Civil Action No. 06-760 CIVIL TERM PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Kindly issue a Writ of Execution in the above matter... 1. directed to the Sheriff of Cumberland County: 2. against Lisa Curtis, Defendant l (J E-tc?n"8' , C ek C? fc?e. } C? ??e P ?4 -40 3. Judgment Amount $ 4,444.97 Interest $ 122.75 Costs $ 96.90 SUBTOTAL: $ 4,664.62 Costs (to be added by Prothonotary): $ WELTMAN, WEINBER-G & REIS CO., L.P.A. By: (N / ) William T. Molczan, Esqui?y? PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#04534222 o? n? 1 -tL1 ° ? w w w R Sri .c by WRIT OF EXECUTION and/or ATTACHMENT I , . COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-760 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CACV OF COLORADO, LLC, Plaintiff (s) From LISA CURTIS, 70 MANADA CREEK, CIRCLE, CARLISLE, PA 17013 (1) You are directed to levy upon the property of the defendant (s)and to sell ALL PERSONAL PROPERTY. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $4,444.97 L.L. $.50 Interest $122.75 Atty's Comm % Atty Paid $114.40 Plaintiff Paid Due Prothy $1.00 Other Costs $96.90 Date: NOVEMBER 28, 2006 (Seal) CurtKs R. Long, P notary By: Deputy REQUESTING PARTY: Name WILLIAM T. MOLCZAN, ESQUIRE Address: WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 KOPPERS BUILDING 436 SEVENTH AVENUE PITTSBURGH, PA 15219 Attorney for: PLAINTIFF Telephone: 412-434-7955 Supreme Court ID No. 47437 ?- -. Thomas Kline, Sheriff, who being duly sworn according to law, states ?is writ is returned STAYED. ? eriff's Costs: Advance Costs: 150.00 Sheriff's Costs: 44.77 i? ? cketing 18.00 $ 105.23 Poundage .87 Advertising Law Library .50 Prothonotary 1.00 Refunded to Atty on 01/11 Mileage 4.40 Surcharge 20.00 Levy Certified Mail Post Pone Sale Garnishee Postage ? TOTAL $ 44.77 So Answers; mv?homas KIiS n ?f .. Cf-.. Al By Claudia A. Irewbaker 0 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-760 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CACV OF COLORADO, LLC, Plaintiff (s) From LISA CURTIS, 70 MANADA CREEK, CIRCLE, CARLISLE, PA 17013 (1) You are directed to levy upon the property of the defendant (s)and to sell ALL PERSONAL PROPERTY. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof, (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $4,444.97 L.L. $.50 Interest $122.75 Atty's Comm % Atty Paid $114.40 Plaintiff Paid Due Prothy $1.00 Other Costs $96.90 Date: NOVEMBER 28, 2006 (Seal) REQUESTING PARTY: Name WILLIAM T. MOLCZAN, ESQUIRE Address: WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 KOPPERS BUILDING 436 SEVENTH AVENUE PITTSBURGH, PA 15219 Attorney for: PLAINTIFF Telephone: 412-434-7955 Curti . Long, Pr oiary By: Deputy Supreme Court ID No. 47437 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CACV OF COLORADO, LLC Plaintiff No. 06-760 CIVIL TERM vs. 04534222 Defendants PRAECIPE FOR EXEMPLIFIED RECORD TO THE PROTHONOTARY: Kindly provide an exemplified record in order to transfer the judgment entered in the above captioned case. WELTMAN, WEINBERG & REIS CO., L.P.A. By: James C. brodt, Esquire PA I.D. 4 524 WELT F AN, EINBERG & REIS CO., L.P.A. 436 Se?enth venue, Suite 2718 Pittsb, rgh, A 15219 (412,' 434- 955 FAk 41 -338-71305 04534222