HomeMy WebLinkAbout06-2260BURTON NEIL & ASSOCIATES, P.C.
By: Burton Neil, Esquire
Identification No. 11348
1060 Andrew Drive, Suite 170
West Chester, PA 19380
(610) 696-2120
Attorney for Plaintiff
HARVEST CREDIT MANAGEMENT
600 17th Street, Suite 800 North
Denver, Colorado
Plaintiff
V.
LEONARD H CRAMER
318 Charles Road, Mechanicsburg PA 17050
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. nL - ?2, (Lo? l_., ,
CIVIL ACTION - LAW
COMPLAINT
NOTICE
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 (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 claim 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. 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 REFERENCE AND
INFORMATION SERVICE
Cumberland County Bar Assoc.
32 South Bedford Street
Carlisle, PA 17013
Telephone No. 717-249-3166 or 800-990-9108
66473
BURTON NEIL & ASSOCIATES, P.C.
By: Burton Neil, Esquire
Identification No. 11348
1060 Andrew Drive, Suite 170
West Chester, PA 19380
(610) 696-2120
Attorney for Plaintiff
HARVEST CREDIT MANAGEMENT IN THE COURT OF COMMON PLEAS
600 17th Street, Suite 800 North
Denver, Colorado
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. I 1 t?
O. .aL
?la - (P U Ot U'LIL l
LEONARD H CRAMER N
318 Charles Road, Mechanicsburg, PA
Defendant CIVIL ACTION - LAW
Complaint
1. The plaintiff is HARVEST CREDIT MANAGEMENT , with place of business located at 600
17th Street, Suite 800 North, Denver, Colorado.
2. The defendant is Leonard H Cramer, who resides at 318 Charles Road, Mechanicsburg, Cumberland
County, Pennsylvania.
3. At the defendant's request, Direct Merchants Credit furnished consumer credit to defendant bearing
account number 5458003702340407 hereinafter referred to as the credit card account
4. The defendant accepted the credit card account by making purchases, balance transfers and/or cash
advances.
5. Monthly statements were sent to defendant each month which detailed the charges and credits made to
the credit card account for the prior month.
6. The balance due on the credit card account is $11,609.91
7. Defendant did not pay the balance due on the credit card account in full upon receipt of the monthly
billing statements and also did not make the required minimum monthly payment set forth in the monthly
billing statement. As such, defendant is in default on the credit card account.
8. Plaintiff purchased the defendant's account from Direct Merchants Credit and is now the holder and
owner of the account.
9. Although demand has been made by plaintiff upon defendant to pay the sum of $11,609.93, the
defendant failed and refused to pay all or any part thereof.
Wherefore, plaintiff demands judgment against the defendant in the sum of $11,609.93and the costs of this
action. y
BURTON NE/ & ASSOCIATES, P.C.
By:
Burton Neil, Esquire
Attorney for Plaintiff
The law firm of Burton Neil & Associates, P.C. is a debt collector.
Verification
?D 8,,\1I11 T.c+?l is?1A?a n
is
(Name of authorized representative)
(Title or Position)
for HARVEST CREDIT MANAGEMENT , the within Plaintiff, and makes this statement on its
behalf as to he truthfulness of the facts set forth in the foregoing Complaint subject to the penalties
of 18 Pa. C.S. Section 4904, relating to unworn falsificatio to auth ties.
0? o'1-0 f
Date:
U -
Name
Leonard H Cramer
5458003702340407
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SHERIFF'S RETURN - REGULAR
CASE NO: 2006-02260 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
HARVEST CREDIT MANAGEMENT
VS
CRAMER LEONARD H
WILLIAM CLINE Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
CRAMER LEONARD H the
DEFENDANT
at 2052:00 HOURS, on the 8th day of May , 2006
at 318 CHARLES ROAD
MECHANICSBURG, PA 17050
LEONARD CRAMER
by handing to
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 18.00
Service 31.68
Affidavit .00
Surcharge 10.00
`? b -9 6
L4 .v-? 4/04
Sworn and Subscribed to before
me this day of
A. D.
So Answers:
?0P, if
R. Thomas Kline
05/09/2006
BURTON NEIL
By:
Deputy Sheriff
Prothonotary
Curtis R. Long
Prothonotary
office of the Protbonotarp
uCumberlanb Countp
Renee K. Simpson
Deputy Prothonotary
John E. Slike
Solicitor
-j 2 L n CVIL TERM
ORDER OF TERMINATION OF COURT CASES
AND NOW THIS 28TH DAY OF OCTOBER, 2009, 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
One Courthouse Square • Carlisle, Pennsylvania 17013 • (717) 240-6195 • Fax (717) 240-6573