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Home My WebLink About06-2324 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NATIONAL CITY BANK K-AI16-2J Plaintiff No: 0& ~ cJjJC{ ~ vs, COMPLAINT IN CIVIL ACTION DARLENE V GROFF DONALD L GROFF Defendants 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 05069020 C A Pit WLG IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NATIONAL CITY BANK K-AI16-2J Plaintiff vs. Civil Action No DARLENE V GROFF DONALD L GROFF Defendants 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, NATIONAL CITY BANK is a corporatioK-AI16-2Jfices at 1 NATIONAL CITY PARKWAY KALAMAZOO , MI 49009 . 2, Defendants are adult individual(s) residing at the address listed below: DARLENE V GROFF 99 ICKES LN NEWVILLE, PA 17241 DONALD L GROFF 99 ICKES LN NEWVILLE, PA 17241 3. Defendants applied for and received a credit card bearing the account number 4489000404268247 , 4, Defendants made use of said credit card and has a current balance due of $8094,37 , as of April 05, 2006 5. Defendants are 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 April 05, 2006 , A copy of Plaintiff's STATEMENT OF ACCO UNT is attached hereto, marked as Exhibit "1" and made a part hereof, 7. Although repeatedly requested to do so by Plaintiff, Defendants have willfully failed and/or refused to pay the balance due to Plaintiff. Wherefore, the Plaintiff prays for judgment in its favor and against Defendants , DARLENE V GROFF AND DONALD L GROFF , INDIVIDUALLY , in the amount of $8094.37 with continuing interest thereon at the rate of 6,000% per annum from April 05, 2006 plus costs. ='\ ______1 ~ /' Warmbrodt, 42524 WEINBERG & REIS CO" L,P.A, venth Avenue, Suite 2718 urgh, PA 15219 (41 ) 434-7955 : 4l2-338-7130 5069020 C A pit WLG 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, PO BO;t: 2349 #KA16F5 KALAMAZOO Mr 49003-2349 New Balance Minimum Payment Due Date Account Number $8.094.37 $1.336.37 10112105 4489 0004 0426 8247 4489000404268247000809437000133637 Total Enclosed $ I Address or EmlllJ change? Print new address on back of statement By mail, your payment may take 5-7 days to reach us. PLEASE MAKE CHECK PAYABLE TO: DARLENE V GROFF DONALD L GROFF 99 ICKES LN NEWVILLE PA 17241-8631 ",11'",1,.1.'.'..'","1.,1,,11"1.11111111111111.1,,1,1'1 NATIONAL CITY P.O. BOX 856176 LOUISVILLE. KY 40285-6176 ,'"'//",..',1"1',,',',.1',,,..1111111.11'111111 ....8 5000 0080 ~000~0"2~82~? 00. 91atUwm- 11921 Credit Card Account 44890004 0426 8247 NationalCity .com/CardServices Make payments, review transactions and more! At Your Sennce: 800-282-7541 Mail payments to: National City P.O. BOX 856176 , LOUISVilLE, KY 40285-6176 Account SummarY Previous Balance Payments/Credits PurchasesJDeblts Cash Advances Finance Charges New Balance $7,933.84 $0.00 $39.00 $0.00 $121.53 $8,094.37 Credit Limit Available Credit Available for Cash Advance Statement Closing Date Payment Due Date Minimum Payment = Past Due Amount + + + . CONTINUED DELINQUENCY MAY ADVERSELY AFFECT YOUR CREDIT RA. TING. TO AVOID FURTHER COLLECTION ACTION, PAY THE TOTAL AMOUNT DUE. Transactions TranDate PostDate Reference Number 09/15 09/15 09/15 09/15 Description LATE FEE .FINANCE CHARGE" Debits 39.00 121.53 Finance Charae Summary Corresponding Annual Daily Percentage Periodic Rate Rate (APR) (may vary) Avg. Daily Balance Subject to Finance Charge X Days in BillinQ Period x Purchases Previous Cycle Purchases Current Cycle Purchases Cash Advances Cash Advances 18.49% 18.49% .05066% x .05066% x 32 30 x x $0.00 $7.996.29 18.49% Annual Percentage Rate = 18.49% .05066% x 30 x $0.00 Total Finance Charge 5170 0006 9FD ? 10 050915 EXPage 1 of 1 4215 0000 vllR 01AN517a $7,500.00 $0.00 $0.00 09/15/05 10/12/05 $1,336.37 $636.00 Credits Finance Charge for This Period $0.00 $121.53 $0.00 $121.53 i;:,XHiBi7 11921 VERIFICATION to unsworn falsifications to authorities, that he/she is The undersigned does hereby verify subject to the penalties of 18 PA. C.S. 4904 relating _OIl. HII_ (NAME) NlIIoIIlII CIr AgltllCy Auditor ~.1pII of , plaintiff herein, that (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. 9t\'~ ( I NA RE) 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#05069020 ~~' ~.,_.._,j _. ')... \- ~ ~ <1 A~ _ \ '-..) (', "'-J c>,<:::...5;' ~ '1--' . 0'\ '"' .' .....) C (y. j ~ ~' \.>J J" <::y ,--' r;--::... if\\ , ') " .-< >....' l., ' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NATIONAL CITY BANK K-AI16-2J Plaintiff 01. - ~).l{ No. 16" 51: 1679 vs. PRAECIPE FOR DEFAULT JUDGMENT DARLENE V GROFF DONALD L GROFF Defendants FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY James C. Warmbrodt Paid# 42524 Weltman, Weinberg & Reis Co. 2718 Koppers Bldg 436 Seventh Avenue Pirtsb~rgh, P A 15219 (412) 434-7955 WWR#05069020 Judgment Amount $ 8184.85 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 NATIONAL CITY BANK K-AI16-2J Plaintiff vs. Dl, - '-32'1 Civil Action No. ~64-32- 10/;;" DARLENE V GROFF DONALD L GROFF Defendants PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter Judgment against the Defendants, DARLENE V GROFF AND DONALD L GROFF, above named, in the default of an Answer, in the amount of $8184.85 computed as follows: Amount claimed in Complaint $8094.37 Interest from 04/05/06 at the legal interest rate of 6.00% per annum $90.48 TOTAL $8184.85 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, WEINBERG & REIS CO.. L.PA Plaintiffs address is: c/o Weltman. Weinberg & Reis Co., L.PA, 2718 Koppers Building, 436 7'" Avenue, Pittsburgh, PA 15219 And that the last known address of the Defendants is: 99 ICKES LN NEWVILLE,PA 17241 , NATIONAL CITY BANK K-AI16-2J CI.. - ;z.3:1.'{ Case no: 104 52-16Te Plaintiff vs. NON-MILITARY AFFIDAVIT DARLENE V GROFF DONALD L GROFF Defendants 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 Service members' 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, DARLENE V GROFF DONALD L GROFF 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, DARLENE V GROFF DONALD L GROFF is not in the military service. Further Affiant sayeth naugh . COMMONWEALTH OF PENNSYLVANIA Notarial Seal Heidi J. Kelly, Notary Public City 01 Pit1sbuIgh, Allegheny County My Commission Expires Nov. 4, 2009 Member, Pennsylvania Aaeloclatlon of Notaries 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. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NATIONAL CITY BANK Plaintiff Case # () f.,,'-,)?:l~ Cl.JiV DARLENE V GROFF Defendant(s) IMPORTANT NOTICE TO: DARLENE V GROFF 99 ICKES LN NEWVILLE,PA 17241 Date of Notice: WWR#: 05069020 sf 1,L 1i!?V I r; 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 ASSOCIATIO~ 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 .....-~ BY: JAMES W PA LD. #42524 WELT ,WEINBERG & REIS CO., L.P.A. 2718 PPERS BLDG, 436 7TH AVE. PITT$ URGH, PA 15219 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NATIONAL CITY BANK Plaintiff Case # ()~ _ J. ~,:J l..( (l J l '-- DONALD L GROFF Defendant(s) IMPORTANT NOTICE TO: DONALD L GROFF 99 ICKES LN NEWVILLE,PA 17241 >/)/( O~ Date of Notice: WWR#: 05069020 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 CO~TY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 BY: J,N!I:E:$ PA I. WELT 2718 PITT BRODT, ES #42524 , WEINBERG & REIS CO., L.P.A. PPERS BLDG, 436 7TH AVE. URGH, PA 15219 . Request for Military Status Page lof2 Department of Defense Manpower Data Center .A Military Status Report . Pursuant to the Servicemembers Civil Relief Act JUN-12-200613:46:16 ~(Last Name First/Middle Begin Date T Active Duty Status I Service/Agency GROFF DARLENE V 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. ~~WJ~6-~ Robert J. Brandewie, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 II,' 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. SS SOl 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 DaB, 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: http://www.defenselink.mil/taqipis/PC09SLDR.html WARNING: This certificate was provided based on a name and Social Security number (SSN) provided https://www.dmdc.osd.mil/scra/owa/scra. prc _Select 6/12/2006 . Rj)quest for Military Status Page 2 of2 by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report lD:GMXVXNOHYG , ','.,' https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 6/12/2006 . . VERIFICATION \\ j' The undersigned does hereby verify subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities, that the parties against whom Judgment is to be entered according to the Praecipe attached are not members of the Armed Forces of the United States or any other military or non-military service covered by the Soldiers and Sailors Civil Relief Act of 1940. The undersigned further states that the information is true and correct to the best of the undersigned's knowledge and belief and upon information received from others. WEl.TMAN, WEINBERG & REIS CO, I..P.A. WWR#5069020 ~ ~~ \ ~ r~~-cJ ~ ~ P- \r t; V\ 1- ,,-.... -;, r' r:': !"',,) _..::'" '-'0 ~~ ~ {J.... ._... ::1:,-: rn~ .....- r-,) . '.,. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NATIONAL CITY BANK K-AI16.2J Plaintiff vs. 01..- :J.J:J.'f Civil Action No. 16-4 5l1-le7~ DARLENE V GROFF DONALD L GROFF Defendants NOTICE OF JUDGMENT OR ORDER TO () Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the following Order or Judgment was entered against you on (xx) Assumpsit Judgment in the amount of $8184.85 plus 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 Judgrnent of () Court Order () Non-Pros () Confession (xx) Default () Verdict () Arbitration Award DONALD L GROFF 99 ICKES LN NEWVILLE,PA 17241 By PROT TV) IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION . . IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY. PENNSYLVANIA CIVIL DIVISiON NATIONAL CITY BANK K-AI16-2J Plaintiff vs. C;k-.:2.32.Y Civil Action NO.<1ii4 .2 1679- DARLENE V GROFF DONALD L GROFF Defendants NOTICE OF JUDGMENT OR ORDER TO: () Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the following Order or Judgment was entered against you on (xx) Assumpsit Judgment in the amount of $8184.85 plus costs. Trespass ~udgment in the amount of $ '. . plu.s 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) Defauit () Verdict () Arbitration Award By: PROT Y) DARLENE V GROFF 99 ICKES LN NEWVILLE,PA 17241 Plaintiffs address is: c/o Weltman. Weinberg & Reis Co., L.P.A., 2718 Koppers Building. 436 7'" Avenue, Pittsburgh, PA 15219 1-888-434-008 .. 10 ) . IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NATIONAL CITY BANK Plaintiff vs. Civil Action No. 06-2324 CIVIL DARLENE V GROFF DONALD L GROFF 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. ..-......",.. ,.<' / ........' ..." .-' Sworn to and subscribed before me this I.>' day of AU9USt/6 Q _ 5dv1u~ HW NNS~VAN~ NotarIlIJ 8eeI WI1t/08 A. Jonee. NoIIJy Public CIty Of p~ AIegheny Cou1ly My Corm ,18eion Expns JlBlEl29. 2010 Member, PennSylvanle Association of Notaries VWl/R #05069020 ~. -om mrr, ~t~;'.i (J) JI; -< r:' <::: 1> -.~ Z(i :.,-'c) ,..>~ ~ . << ~ ~ co C" >- c:: G") N W ~ ~ nl:D ,..... -om :09 0- --tU "...-t'. ~..ll_ """II ~.;:o am .:-1 .~ -0 :x N .. W -.I I ~ SHERIFF'S RETURN - REGULAR CASE NO: 2006-02324 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND NATIONAL CITY BANK K-Al16-2J VS GROFF DARLENE V ET AL ROBERT BITNER , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon GROFF DARLENE V the DEFENDANT , at 1100:00 HOURS, on the 3rd day of May , 2006 at 99 ICKES LANE NEWVILLE, PA 17241 by handing to DAONDL GROFF, HUSBAND 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 Service Affidavit Surcharge So Answers: Cf-51;7/~ 18.00 10.56 .00 10.00 .00 38.56 ~;/ y'A' .r%;~~~~~;.(/ ff~ , / R. Thomas Kline 05/04/2006 WELTMAN WEINBERG REIS Sworn and Subscribed to before day of BY'~ i -t~ M~'-: Deputy Sheriff me this A.D. Prothonotary ~, -'\, SHERIFF'S RETURN - REGULAR CASE NO: 2006-02324 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND NATIONAL CITY BANK K-Al16-2J VS GROFF DARLENE V ET AL ROBERT BITNER , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon GROFF DONALD L the DEFENDANT , at 1100:00 HOURS, on the 3rd day of May , 2006 at 99 ICKES LANE NEWVILLE, PA 17241 by handing to DONALD GROFF 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 Service Affidavit Surcharge So Answers: 6j~</JD~ 9- 6.00 .00 .00 10.00 .00 16.00 ~a:;.'~~-" .J,....;v ,f" .,~., _.- '" h. .. ,.~ ~'_"".' ..& ,,\ _A::-~""-J ~"...I . R. Thomas Kline 05/04/2006 WELTMAN WEINBERG REIS me this day of BY'4-rr5~ eputy Sheriff Sworn and Subscribed to before A.D. Prothonotary