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Home My WebLink About06-2953 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CACV OF COLORADO) LLt.1 Plaintiff No: Ole. -;;),953 CiuiL ~E/L~ vs. COMPLAINT IN CIVIL ACTION ERIC C PEFFER 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 04471285 CEPit SGM IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CACV OF COLORADO) LlL" Plaintiff Civil Action No 6L -;29.5',] ~L ~~ vs. ERIC C PEFFER 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 c' , 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(sl residing at the address listed below: ERIC C PEFFER 331 W MAIN ST MECHANICSBURG, PA 17055 3. Defendant applied for and received a credit card bearing the account number 5542851600747935 . 4. Defendant made use of said credit card and has a current balance due of $2760.74 , as of April 17, 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 April 17, 2006 . A copy of Plaintiff's STATEMENT 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 , ERIC C PEFFER , INDIVIDUALLY , in the amount of $2760.74 with continuing interest thereon at the rate of 6.000% per annum from April 17, 2006 plus costs. L.P.A. 2718 This law firm is a debt collector aftempting to collect this debt for our client and any information obtained will be used for that purpose. .1 t I DVI!); 1 ( ~~~) CACV of Colorado, LLC 370 17th Street Suite 5000 Denver, CO 80202-5690 ~\lilllll~li\lllll~ 5542851600747935 rnl\l\\l\la........ailli~5Ialill\lltlll~ $3,723.77 PEFFER, ERIC C PO BOX 42872 PHILADELPHIA, PA 19101 CACV of Colorado, LLC has purchased this PROVIDIAN BANK account and is now the owner of this account. EXHIBIT ('i'l Payments received at the above listed address will be posted that buslne.s day Please .end Inquiries or corr..pondence to 370 17th SI Sulla 5000 Denver, CO 80202-5690 or call toll-fre. 1-877-248-8343 VERIFICATION The undersigned does hereby verify subject to the penalties of 18 P A. C.S. 4904 relating to unsworn falsifications to authorities, that he/she is KENNETH D. URBAN Authorized Agent herein, that (NAME) of f f:JCIJ ~ {'t<J, ~m.JO I UL , 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 est 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#04471285 1 (:) ~ \ Crt Y't ~ 2 G F! '" Irt = ~ = cS "" ::!l: :II > ~ -< rn :!J r- J I"\,) -C'/Ill W :r)O ~, l '~'::'fCJ > ~'C -'r ::J:: i::>:D ">-C) 'f? i:;rr1 :::;.--1 (,l1 :Xi 0. -< II II III .. "i i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CACV OF COLORADO, LLC vs. No. 06-2953 CIVIL TERM PRAECIPE FOR DEFAULT JUDGMENT Plaintiff ERIC C PIi'FFEiR Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: 'I , ,I James C. Warm brodt, Esquire PA 1.0. #42524 WELTMAN, WEINBERG & REIS CO., L.PA 2718 Koppers Buildin!jl 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#04471285 Judgment Amount $ 2797.05 il , I'I I " THIS LAW FIRM IS JtTTEMPTING TO COLLECT THIS DEBT FCl>R ITS CLIENT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. . ':1 ': :1 i, III . I i IIN THE F I I I , ' URT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSY~VANIA CIVIL DIVISION I CACV OF COLORADO, LC V5. Civil Action No. 06-2953 CIVIL TE~M Plaintiff ERIC C PEFFER Defendant PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter Judgment against the Defendant, ERIC C PEFFER above named, in the default of an Answer, in the amount of $2797.05 computed as follows: Amount claimed in Complaint Inje~e~t.from ~ il17, 2006 to July 6,2006 atlth'e ~ontractl i terest rate of 6% per annum TOTAL $2760.74 $36.31 $2797.05 I hereby certify hat 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. 11:1 :'1 11 WELTMAN, WEINBE G & REIS do., L.P.A. Plaintiff'S~ddr~sliS: . I c/o Weltm Iir; elhberg '. Reis Co., L.P.A., 2718 Koppers Building, 4367'" AVi',' nue, Pittsburgh, PA 15219 And that t ,e la t known a dress of the Defendant is: 331 W MAIN ST, MEC ANICSBURGlpA 17055 , , ' i I . 1'1 !: :1 III .. IN THE COURT OF COMMON PLEAS CUMBERLAND CO~TY, PENNSYLVANIA CIVIL DIVISION CACV OF COLORADO, LLC Plaintiff Ca~e # fJVJ - 7...q S'.3 (lUll Tt/A1 ERIC C PEFFER Defendant(s) IMPORTANT NOT;!:CJi;i' ',J., TO: ERIC C PEFFER 331 W MAIN ST MECHANICSBURG,PA 17055 Date of Notice: WWR#: 04471285 0- "Z.. 1 ~~ 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 OBJECTIONST~ 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.I!1',~QUDO NOT HAVE A LAWYER, GO TO OR ,\j- 4 . 0' .iI,. >_.,<("'.' ~:; ,;. 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 #42524 , WEINBE O)?PERS BL URGH, PA G & REIS CO., L.P.A. G, 436 7TH AVE. 5219 I. III . I , I IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNS~LVANIA CIVIL DIVISION , CACV OF COLORADO, LLC Case no: 06-2953 OIVIL TERM Plaintiff vs. NON-MILITARY AFlFIDAVIT ERIC C PEFFER Defendant Tilt !lIn~~Sign, Th~t hJ/she is lh within matter. who first being duly sworn, according to law, deposes and states as follows: duly authorized agent of the Plaintiff in the Affiant further st tes that the within Affidavit is made pursuant to and in acco dance with the Servicemembers' CivillRelief Act (SCRA), 50 U.S.C. App. ~ 521. Affiant further states that based upon investigation it is the affiant1s belief that the Defendant, ERIC C PEFFER is not in the military service. Affiant further states that this belief is supported by the attached certificate fr~m the Defense Manpower Data Center. (DMDC), which states that the Defendant, ERIC C PEFFER is not in the military service. Further Affiant sayeth naught. '1 j;.,:i 1 BSCRIBE;rz; my presenc~ this ~ d~y . (). COM ONWEALTH F PENNSYLVANIA Notarial Seal ;idi J. Kelly, otOI)' Pul , Pittsburgh, II8\1honv 1mission Exlfltres NO.: cJnnsylvanla l' ..oeiahr ' 'lei nt and any information obtained , II This law firm is a debt collector attempting to collect this debt for our cl will be used for that purpose. III Request for Military Status - Page I of2 . Department of Defense Manpower Data Center JUL-06-200608:16:59 ~ilitary S atus Report Pursuant ~ the Servicemembers Civil Relief Act I <Last Name FirstlMiddle Begin Date I Active Duty Status I I Service! Agency PEFFER ERICe Based on the information you have furnished, the D~C does not possess any information indicating that the individual is currently on active duty. i e Upon searching the information data banks ofthe Department of Defense Manpower Data Center, based on the information that you provided, the above is the current status of tlhe individual as to all branches ofthe Military. ~W~CI-~ Robert J. Brandewie, Director . Department of Defense - Manpower Data Center 1600 Wilson Blvd., Slte 400 Arlingtop,jYA 22209iJ1593 The Def~n~e Manpow~r Data Center (DMDC) is an organization oftht1 Department of Defense that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data qn eligibility for military medical care and other ieligibility sistems. The Department of Defense strongly supports the enforcement of the Servicemembllrs Civil Relief Act [50 USCS Appx. ~~ 501 et seq] (SCRA) (formerly the Soldiers' and Sailors' Civil ~elief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any infdrmation 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 represellitative asserts in any manner that the individual is on active duty, or is otherwise entitled to the protectiojls 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 . n~e), you can submitiyour request again at this Web site and we will provide a new certificate for that query. . .1 ' 1'1 " ' . ' oj,! ,: I This respo~s~ r~flects urrent active duty status only. For historical in4>rmation, please contact the Military Service SeM points-of-contact. I I I See: http://www.,flefenselink.miJ/faq/pis/pC09SLDR.btmJ i I WARNING: This certificate was provided based on a name and SOCi~ Security nmfber (SSN) provided I . , https;//www.dmdc.osd.millscra/owa/scra.prc_Select 7/6/2006 III , ~equest 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:KMAEDEGBJK iill ,. ; I https://www.drndc.osd.il/scra/owa/scra.prc _Select I 7/6/2006 ~ . t 1- ~ ~ II ~ \) f~1 r'",) ~ ~ C> ) -. .." ~ r .-1 ~ b) ,.. t.t ;lc\~l ~ ty - ., " ,.. 9J ~ :t> -. : (\., ~ - t- - --r -". - .. (.'1 :;:::i _.1 -< ~r III . . IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY. PENNSYLVANIA CIVIL DIVISION ' CACV OF COLORADO, LLC Plaintiff "I,', I,'! " 'I vs. ERie C F1J~~~R i DJfenJant Civil Action No. 06-2953 CIVIL TEf1.M II NOTICE OF JUDGMENT OR ORDER :1 ;'~ j !L 1,1' TO: () Plaintiff , (xx) Defendant ( ) Garnishe~ You are hereby notified that the following Order or J\ldgr.ent was entered against you on.... )/-1 .., /41 ~oc>r; ( (xx) Assumpsit Judgment in the amount of $2797.05plus costs. Trespass Judgment in the amount of $ plus costs. j ,'II ; I , , I '. , _. I' :"""1' () If not satisfied within sixty (60!) , days, your motor vehicle operator's Iiljense and/or registration will be suspended by the Department of Tra$sportation, Brreau of Traffic Safety, Harrisburg, PA. . I I I I (xx) Entry of Judgment of () Court Order () Non-Pros () Confession (xx) Default () Verdict () Arbitration Award 'I I Iii 1/ 1'1 Iii ERIC C PEFFER 331 W MAIN ST 1 ' . MECHANICSBURG,PA 17055 I Plaintiffs address is: , c/o Weltman, Weinberg & Reis Co., L.PA, 2718 Koppers Building, 43 7'" Avenue, pittsburgh, PA 15219 , i 1-888-434-0085 I ! i I II SHERIFF'S RETURN - REGULAR CASE NO: 2006-02953 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CACV OF COLORADO LLC VS PEFFER ERIC C CPL. TIMOTHY REITZ , Sheriff or Deputy Sheriff of Cumberland County, pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon PEFFER ERIC C the DEFENDANT , at 1806:00 HOURS, on the 30th day of May , 2006 at 331 W MAIN STREET MECHANICSBURG, PA 17055 by handing to KAREN PEFFER, MOTHER 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 Service Affidavit Surcharge 18.00 8.80 .00 10.00 .00 36.80;:1 05/31/2006 0- 1./7- 01, WELTMAN WEINBERG REIS By, J#;l?!f So Answers: .?,,~~<~ R. Thomas Kline Sworn and Subscibed to before me this day of A.D.