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Home My WebLink About06-2413 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CACV OF COLORADO Plaintiff No: ()~ -d'-!J3 G0~L T~ vs. COMPLAINT IN CIVIL ACTION JAMES PEDRICK 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 05096428 CEPit KMJ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CACV OF COLORADO Plaintiff vs. Civil Action No JAMES PEDRICK 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: JAMES PEDRICK 6214 WHITEHILL DR MECHANICSBURG, PA 17050 3. Defendant applied for and received a credit card bearing the account number 5462812114903253 . 4. Defendant made use of said credit card and has a current balance due of $1706.00 , as of March 15, 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 15, 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 Pl2intiff, Dpfendant 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 , JAMES PEDRICK , individually , in the amount of $1706.00 with continuing interest thereon at the rate of 6.000% per annum from March 15, 2006 plus costs. YYl~ Warmbrodt, 42524 , WEINBERG & REIS CO., L.P.A. enth Avenue, Suite 2718 pitts rgh, PA 15219 (412) 434-7955 FAx. 412-338-7130 o~ 96428 CEPit KMJ 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. t !)< ../""-..~ '~1/~ .' /.;'.'. .' f./"" ,.,. t 1":> )" c DIRECT MERCHANTS CREDIT CARD BANK LAST STATEMENT DETAILS ACCOUNT# 5462812114903253 PEDRICK ,JAMESE 6214 WHITEHILL DR MECHANICSBURG , PA 170502342 DATE OF LAST $1' A TEMENT 02APR2003 LAST STATEMENT BALANCE $1,706.00 DATE OF PREVIOUS 51' A TEMENT 04MAR2003 PREVIOUS STATEMENT BALANCE $1,667.00 LAST 51' A TEMENT FEES = $0.00 FEE BALANCE = $693.17 CREDIT LINE = $1,300.00 MERCHANT BALANCE = $1,012.83 A V ALABLE BALANCE = NONE CASH BALANCE = $0.00 i AMOirNT '. 'ii, l'iI'iI,', iliI!!HiI' ~ ,',i';",,' i CHARGE OFF TOTAL ACCT $1,706.00 31 MAR2003 31 MAR2oo3 CHARGE OFF ACCOUNT# : 5462812114903253 MERCHANDISE APR : 29.99% LAST STATEMENT BALANCE: $],706.00 CASH APR : 29.99% OVER LIMIT AMOUNT $406.00 E~~IJ~IT .. . V.ERIFICATION 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) of (~rrl- f_ ~ INfAVi C~~:ep't?A ~~")) e-LC 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. C-~- ~/ (Signature - 05096428 CEPit KMJ 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. 0, "0- ~ 1- YA -- ~ ~ \" C/ ",1 ~ ~ -- LV :::: -tJ \)- , 32 L_ f -'-- ----.'\ ( \ ( IJ\ \. ~-i . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DiVISION CACV OF COLORADO, LLC Plaintiff No. 06-2413 CIVIL TERM vs. PRAECIPE FOR DEFAULT JUDGMENT JAMES PEDRICK Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warm brodt, Esquire i;'p,. t.D #42524 '. . IV;!Fbt.~AN, WEINBERG & REIS CO, LPA . ,. L.lji1lJ'koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#05096428 ~ll9grT!ent Amount $ 1733.76 ;' . .. ',:", i..~ '. THIS LAW FIRM IS ATTEMPTING TO COLLECT THIS DEBT FOR ITS CLIENT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. :.! . d."+I' :).,'/j,~ L:i' <:' ".'1' . ,~..'\';;., IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVil DIVISION CACV OF COLORADO, llC Plaintiff vs. Civil Action No. 06-2413 CIVil TERM JAMES PEDRICK Defendant PRAECIPE FOR oEiYff~~'JUDGMENT TO THE PROTHONOTARY: Kindly enter Judgment against the Defendant, JAMES PEDRICK above named, in the default of an Answer, in the amount of $1733.76 computed as follows: ..,r'>... Amount claimed in Complaint $1706.00 Interest from March 15, 2006 to June 22, 2006 at the contract interest rate of 6% per annum $27.76 TOTAL $1733.76 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, WEIt::lBE~S CO, L.PA '", Plaintiffs address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7'" Avenue, Pittsburgh, PA 15219 And that the last known address of the Defendant is: 6214 WHITEHill DR, MECHANICSBURG,PA 17050 , d ~ IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CACV OF COLORADO, LLC Plaintiff Case # lJ.f- 141) ClILI \-e,'flI) JAMES PEDRICK. Defendant(s) IMPORTANT NOTICE TO: JAMES PEDRICK 6214 WHITEHILL DR MECHANICSBURG,PA 17050 Date of Notice: WWR#: 05096428 r () - l (:) -Olp 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 YOpWITHOUT 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 BRODT, ESQUIRE PA I.D. 42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 KO PERS BLDG, 436 7TH AVE. PITTSBURGH, PA 15219 y IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION.,;, <;:J:G:'o CACV OF COLORADO, LLC Case no: 06-2413 CIVIL TERM Plaintiff vs. NON-MILITARY AFFIDAVIT JAMES PEDRICK 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 U.S.C. App. ~ 521. Affiant further states that based upon investigation it is the affiant's belief that the Defendant, JAMES PEDRICK 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, JAMES PEDRICK is not in the military service. Further Affiant sayeth naught. COMMONWEALTH OF PENNSYLVANIA Notarial Seal He; J. Kelly. Notary f , 'r ;IY 01 i ittsbutgh. Alleghel_;~'\Jm~i \fly Corn! ;,Ission Expires Nt.. "'~ _2l'iJ~:~_ !l<"li-~,,~'rJennsylvania Associatk:~ '''')<1t:'rie& 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,t;. R~quest for Military Status Page I of2 J.. Department of Defense Manpower Data Center .. Military Status Report .. Pursuant to the Servicemembers Civil,~*ef Act JUN-22-200606:22:09 '.,1 ,~ -< Last Name First/Middle Begin Date I Active Duty Status I Service/Agency PEDRICK JAMES 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. ~W~~~.. Robert J. Brandewie, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, V A 22209-2593 i ~, ~J )',i The Defense Manpow& Data Center (DMDC) is an\b'rganization ofthe 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. 99 501 et seq] (SCRA) (formerly the-Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does.no.t possess any information indicating that the individual is currently On active duty" responses, 'a~1fihas 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:'por historical information, please contact the Military Service SCRAJpoints-of-contact. " " . "!. } See: http://www.defcJ:lsclink.miJ/fagLpisLPC09SL.DR,html WARNING: This certificate was provided based on a name and Social Security number (SSN) provided ,.,'. H(::'~'l\::.., ' l."lc..:~JKttt)'J" '..; '. ~'c https://www.dmdc.osd.millscralowalscra.prc_Select 6/22/2006 ".,.,., ') Request for Military Status '.'" Page 2 of2 ... by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. I Report ID:IKJFAUSDNW .;'1 1',.;( ,; ~ https://www.dmdc.osd.millscralowalscra.prc_Select 6/22/2006 . . . J. t ^[ (':) ~ t ..Q . D n .:') ,~- .... D -n g- "- ~ --'- .-< ~ " T -U ni ~ ~ , ~ p: C~'l - ~ ~ t; ':tJ - ' . c::' .' r. ~ :-:-:! r,,) :':c.' c..c; .< ~ . , r: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVil DIVISION CACV OF COLORADO, llC , ,~~ ( Plaintiff vs. Civil Action No. 06-2413 CIVil TERM JAMES PEDRICK Defendant NOTICE OF JUDGMENT OR ORDER TO: () Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the following Order or Ju,dgnnntwas entered against you on ,l~. ?"Sj 21)0'= (xx) Assumpsit Judgment in the amount of $1733. 76plus 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 13"0 . .., y: PROTHONOTARY , JAMES PEDRICK 6214 WHITEHill DR MECHANICSBURG,PA 17050 Plaintiffs address is: c/o Weltman, Weinberg & Reis Co., L.PA, 2718 Keppers Building, 436 7'" Avenue, Pittsburgh, PA 15219 1-~88~t~I34-00~5 ".~. SHERIFF'S RETURN - REGULAR CASE NO: 2006-02413 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CACV OF COLORADO VS PEDRICK JAMES CPL. TIMOTHY REITZ I Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon PEDRICK JAMES the DEFENDANT , at 1409:00 HOURS, on the 17th day of May , 2006 at 333 HEINZ STREET" MECHANICSBURG, PA 17050 by handing to JAMES PEDRICK 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 Postage Surcharge So Answers: t}w. fj:JAfOL- 18.00 8.80 .39 10.00 .00 37.19 r~ee<~ R. Thomas Kline 05/18/2006 WELTMAN WEINBERG REIS r--'.-'" Sworn and Subscribed to before --'- By: '- day of me this A.D. Prothonotary