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Home My WebLink About06-2030 .. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CACV OF COLORADO Plaintiff No: Ot.. - ;;).03C> C I UL'l ~€rL"'I vs. COMPLAINT IN CIVIL ACTION MARY E DIMASI 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 05096460 CEPit VOC IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CACV OF COLORADO Plaintiff vs. Civil Action No MARY E DIMASI 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: MARY E DIMASI 4338 ENOLA RD NEWVILLE, PA 17241 3. Defendant applied for and received a credit card bearing the account number 5458001200026171 . 4. Defendant made use of said credit card and has a current balance due of $7397.07 , as of March 13, 2006 . 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 March 13, 2006 . A copy of Plaintiff's STATMENT OF ACCOU NT 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 , MARY E DIMASI INDIVIDUALLY , in the amount of $7397.07 with continuing interest thereon at the rate of 6.000% per annum from March 13, 2006 plus costs. 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. L.P.A. 2718 ~ DIRECT MERCHANTS CREDIT CARD BANK LAST STATEMENT DETAILS ACCOUNT# 5458001200026171 DIMASI , MARY E 4338 ENOLA RD NEWVILLE , P A 1724] 9789 DATE OF LAST STATEMENT DATE OF PREVIOUS STATEMENT LAST STATEMENT FEES CREDIT LINE A V ALABLE BALANCE 31MAR2004 20FEB2004 $0.00 $8,200.00 NONE PAYMENT CHARGE OFF TOTAL ACCT MERCHANDISE APR, 29.99% CASH APR , 29.99% LAST STATEMENT BALANCE PREVIOUS STATEMENT BALANCE FEE BALANCE , $2,160.23 MERCHANT BALANCE, $7,286.84 CASH BALANCE , $0.00 $9,447.07 $9,239.60 ;:J .. - -.-' (1/ b/" ,t^ .-- : . 't.~ 0 {."-' 1 EXrlT $30.00 22FEB2004 22FEB2004 PAYMENT - THANK YOU LANG*!06 31MAR2004 CHARGE OFF $9.447.07 31MAR2004 ACCOUNT# , 5458001200026171 LAST STATEMENT BALANCE , $9,447.07 OVER LIMIT AMOUNT $],247.07 ~ VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA. C.S. 4904 relating to unsworn falsifications to authorities. that he/she is KENNFTH(1 URBAN . (NAME) :i\uthonzea AQl;::, herein, that ofC.i:lU. c'-) ((1 t,] (( ,( (.LL, plaintiff (TITLE) (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. 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# c')th \g,-\.~ b W "C. 8 ~ -;, ^Jq U( ..,,1 VI , . ~ l.> l/{ -- (" - C; -.:( -.c:.. - C> ~ - \;'" - -.(") \" -:( 01 ~ C> ...._, G' - P- +-. ~ t , SHERIFF'S RETURN - NOT FOUND CASE NO: 2006-02030 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CACV OF COLORADO VS DIMASI MARY E R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT DIMASI MARY E but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT & NOTICE , NOT FOUND , as to the within named DEFENDANT , DIMASI MARY E 4338 ENOLA ROAD NEWVILLE, PA 17241 PER CURRENT RESIDENT, DEFENDANT MOVED OVER A YEAR AGO. J!.JJ!(!(.. 18.00 17.60 5.00 10.00 .00 50.60 C}.. ~~ R. Thomas Kline Sheriff of Cumberland County Sheriff's Costs: Docketing Service Not Found Surcharge WELTMAN WEINBERG REIS 04/25/2006 Sworn and subscribed to before me this day of A.D. Prothonotary . ~ TN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL DIVISION CACV OF COLORADO, LLC Plaintiff No. 06-2030 CIVIL TERM V5. PRAECIPE TO REINSTATE COMPLAINT MARY E DIMASI Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF Tl-IlS PARTY: WILLIAM T MOLCZAN PA J.D. #47437 WELTMAN, WEINBERG & REIS, CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#05096460 I. " IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CACV OF COLORADO, LLC Plaintiff vs. Civil Action No. 06-2030 CIVIL TERM MARY E DIMASI Defendant PRAECIJ>E TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. WELTMAN, WEINBERG & REIS CO., L.P.A. BYW~ WILLIAM T. MO C N PA LD. #47437 WELTMAN, WEINBERG & REIS CO., L.P .A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR #05096460 (') c ~ -or;' r;'"! r -;-.... ~;i ~) ~: -'-;:c P'c ~/ ~ ~ ,.. \ ,..., = g; :J~'" c::: G"') N 0' ~ -I :I:-r1 rnp ......,(Q, ,')l,. CJ(:, :~~~; >:::-rn .:2, ~ " -"'~. "';";" t:..:;' &' SHERIFF'S RETURN - REGULAR CASE NO: 2006-02030 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CACV OF COLORADO VS DIMASI MARY E KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within NOTICE was served upon DIMASI MARY E the DEFENDANT , at 0020:36 HOURS, on the 14th day of September, 2006 at 659 GRAHAMS WOODS ROAD NEWVILLE, PA 17241 by handing to MARY DIMASI a true and attested copy of NOTICE together with REINSTATED COMPLAINT and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 7.92 .00 10.00 .00 35.92/" 09/15/2006 q.a.~-(')l, ~ WELTMAN, WEINBERG f"~,ct:4t!~ R. Thomas Kline & REIS before me this day Sworn and Subscibed to By: of A.D. ... IN THE COURT OF COMMON PLEAS OF CUMBERLANO COUNTY, PENNSYLVANIA CIVIL DIVISION CACV OP COLORAOO. LLC Phlintlff No. 06-~030 CIVIL TERM '11$. PRAECIPE FOR DEFAULT JUOGME"NT MARY E DIMASI Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. W &rmbrodt PA 1.0. 42524 WELTMAN"WEINBERG & REIS CO., L.P.A. 436 Seventh~venue, Suite 2718 Pittsburgh, pIA 15219 (412) 434-7955 FAX: 41Z-338~7130 WWR#OS096460 Judgment Amoullt $ 7680.39 THIS LAW FIRM IS ATTEMPTING TO COLLECT THIS DEBT FOR ITS CLIENT AND ANV INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. -.. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CACV OF COLORADO, LLe Plllintiff 'IS. Civil Action No. 06~2010 CIVIL TERM MARY E DIMASI Defendant TO THE PROTHONOTARY: Kindly enter Judgment against the Defendant, MARY E DlSI above named, in the default of an Answer, in the amount of $7680.39 computed as follows: Amount claimed in Complaint $7397.07 Interest from March 13, 2006 TO November 2, 2006 at the legal interest rate of 6.00% per annum $283.32 TOTAL $7680.39 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. Plaintiff's address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7th Avenue, Pittsburgh, PA 15219 And that the last known address ofthe Defendant is: 659 GRAHAMS WOOD RD, NEWVILLE, P A 17241 >) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CACV OF COLORADO, LLC Plaintiff Case # (L-J6) 0 '-l\/Il-"rl..~ MARY E DIMASI Defendant(s) IMPORTANT NOTICE TO: MARY E DIMASI 659 GRAHAMS WOODS RD NEWVILLE,PA 17241 Date of Notice: /0 Jo / Olf WWR#: 05096460 t < ( 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 BRODT, ESQUIRE 42524 , WEINBERG & REIS CO., L.P.A. PERS BLDG, 436 7TH AVE. GH, PA 15219 " IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CACV OF COLORADO, LLC Case no: 06-2030 CIVIL TERM Plaintiff NON-MILIT ARY AFFIDAVIT vs. MARY E DIMASI 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 10 accordance with the Servicemembers' Civil Relief Act (SCRA), 50 V.S.C. App. S 521. Affiant further states that based upon investigation it is the affiant's belief that the Defendant, MARY E DIMASI 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, MARY E DIMASI is not in the military service. Further Affiant sayeth naught. BED in my presence this~ay OCR. COMMONWEALTH OF PENNSYLVANIA Notarial Seal Wendy L. Gault, Notary Public City Of Pittsburgh. Allegheny County My commission Expires July 15. 201_0 , P nnsylvania Association 01 Notaries Member, e This law firm is a debt collector attempting to collect this debt for ou..,..t. lient and any information obtained will be used for that purpose. ,. " . Request for Military Status Page 1 of2 Department of Defense Manpower Data Center . Military Status Report .. . Pursuant to the Servicemembers Civil Relief Act NOV-01-200614:24:09 -< Last Name First/Middle Begin Date I Active Duty Status I Servicel Agency DIMASI 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. ~}1t. ~-~ Mary M. Snavely-Dixon, 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 Servicemembers Civil Relief Act [50 USCS Appx. #167;#167; 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 ofDOB, 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: llttp-://www.defenselink.millfaq/pisIPC09SLDR.html WARNING: This certificate was provided based on a name and Social Security number (SSN) provided https:/ /www.dmdc.osd.mil/scralowalscra. prc _Select 11/1/2006 . Hequest for Military Status Page 2 of2 by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID: WHTWZAPCAF https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 11/1/2006 -,::) ~ ~ c \ ...0 0 rc:s ~ ~ . c: c::::> \) ~:~~, U'~ .-\ ~ :r:. .-,;, C> \ Inp' -0 r;-1 ~ \ ::JY ~ - --J U) (~)i ~:;, ~ ..,.., \=. 1/ '~~(~) Crt r --:-'" _....'". '~5 $l ~ $J ~ \';-? ..4 '~~,... ~ Q f- .r:- :E!. ~ # ~ -0 cr" ~ J: i~. I IN THE COURT OF COMMON PLEAS CUMBERLAN D COUNTY, PENNSYLVANIA CIVIL DIVISION CACV OF COLORADO, LLC Plaintiff VS. Civil Action No. 06.2030 CIVIL TERM MARY E DIMASI Defendant NOTICE OF JUDGMENT OR CRDER TO: () I'laintiff (xx) Defendant ( ) (,amishee You are hereby notified that the following Order or Judgment was entered against you on fiJ 00 q ;LoO h I (xx) Assumpsit Judgment in the amount of$7680.39 plus costs () Trespass Judgment in tie amount of$_ plus costs. () Ifnot satisfied within si (ty (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 () Confe,sion (xx) Defaut () Verdkt () Arbitration A ward Prothonotary By: A dq PR~ ....~ MARY E DIMASI 659 GRAHAMS WOODS RD NEWVILLE,PA 17241 Plaintiff's address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7th Avenue, Pittsburgh, PA 15219 1-888-434-0085 1