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Home My WebLink About01-5424IN THE COURT'~)F COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION EBBETS PARTNERS, LTD, ASSIGNEE OF MBNA AMERICA BANK ARLENE SOLIS Plaintiff, Defendant. COMPLAINT IN CIVIL ACTION FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan, Esquire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR 01871233 IN TIdE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION EBBETS PARTNERS, LTD, ASSIGNEE OF MBNA AMERICA BANK Plaintiff, CASENO: 01- ot"~/,~/ ARLENE SOLIS Defendant. COMPLAINT IN CIVIL ACTION 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: Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 COMPLAINT 1. Plaintiff is a corporation with offices at 323 West Lakeside Avenue, Suite 200, Cleveland, Ohio 44113. 2. Defendant is an adult individual residing at 608 Mallard Road, Camp Hill, CUMBERLAND County, Pennsylvania 17011. 3. Defendant applied for and received a credit card issued by Plaintiff bearing the account number 749 81045 610 757. 4. Defendant made use of said Visa credit card and has currently a balance due and owing to Plaintiff, as of November 23, 1999, in the amount of $2,201.68, as shown by Plaintiff's Statement of Account attached hereto, marked as Exhibit "1" and made a part hereof. 5. Defendant is in default of the terms of the Cardholder Agreement having not made payment to Plaintiff as promised since November 23, 1999, thereby rendering the entire balance immediately due and payable. 6. Plaintiff avers that the written agreement between the parties provides that Plaintiff is entitled to the addition of finance charges at the rate of 26.90 percent per annum on the unpaid balance. 7. Plaintiff avers that finance charges calculated at the aforesaid rate from November 23, 1999 to August 22, 2001 amount to $1,100.12. 8. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed and/or refused to pay the principal balance, finance charges or any part thereof to Plaintiff. WHEREFORE, Plaintiff demands judgment in its favor and against Defendant, Arlene Solis, individually, in the amount of $3,301.80 with continuing finance charges thereon at the rate of 26.90 percent per annum 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. WELTMAN, WEINBERG & REIS CO., L.P.A. William T. Molczan, Esqui,'~ PA I.D. #47437 Attorney for Plaintiff 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434~7955 WWR 01871233 Gateway I 749 81045 610 757 I MBNA AMERICA 22 P.O. BOX 15028 OP WILMINGTON, DE 19886-5028 ARLENE SOLIS P.O. BOX 15026 WILMINGTON DE 19850-261403 S 00000000000000000000000000000000000000000000000000000000074981045610757 S 00022016800014977800000000000000000000000000000000000000074981045610757 PAYMENTS AND CREDITS 1124 CHARGE-OFF ADJUSTMENT 2,201.68 CR TOTAL FOR BILLING CYCLE FROM 10/27/1999 THROUGH 11/24/1999 $.00 $2,201.68 CR IMPORTANT NEWS Balance and Credits Charges INAN¢£ CHARG£ urrent Payment $0.00 Subject to A. ADVANCES .......... 000000~ DLY 00.00~ $0.00 'ForoutauomaedD ectConnectservioe, oall B. ADVANCES .......... 000000~, DLY 00.00~ $0.00 1-888-637-6262 C. OTHER CHARGES ....... 000000~ DLY 00.00% $0.00 .Tos eaktooneo~ouICustomerSaUs~aotionrepresentaUve$.call D. OTHER BALANCES ....... 000000~ DLY 00.00~ $0.00 1-28-637-6262 !ANNUALPERCENTAI~iERATE... SEE ABOVE 1-800-~46-3178 /XACTDURLICATEANDMAYNOTINCLUOEtvlE$~AGEStVHiCHAPPEARiN PAGE 1 OF I WILMINGTON, DE 19850-5027 EXHIBIT i VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA.C.S. §4904 relating unsworn falsifications to authorities, that he/she is Tp~'rT.r,T~-'q ,3'. O'J~,S?. (Name) c-e~era]- t~a_rt~er of k-~m's t~J~t't~s, r.~lD. , plaintiff herein, (Title) (Company) 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. · (Slgnatur)~//~/' ~ SHERIFF'S RETURN - CASE NO: 2001-05424 p COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND EBBERTS PARTNERS LTD VS SOLIS ARLENE REGULAR RICHARD SMITH , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon SOLIS ARLENE the DEFENDANT , at 1805:00 HOURS, at 608 MALLARD ROAD on the 25th day of September, 2001 CAMP HILL, PA 17011 ROSA SOLIS, MOTHER by handing to 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 18.00 Service 9.75 Affidavit .00 Surcharge 10.00 .00 37.75 Sworn and Subscribed to before me this 2~ day of x~'~--o.. 0~'~t A.D. ~ , Prothonotar~ So Answers: R. Thomas Kline 09/26/2001 WELTMAN WEINBERG &~IS By: ~~er ~ iff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION EBBETS PARTNERS, LTD. ASSIGNEE OF MBNA AMERICA BANK Plaintiff VS. ARLENE SOLIS Defendant No. 01-5424 Civil Term PRAEClPE FOR DEFAULT JUDGMENT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan, Esquire PA I.D. #-47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#01871233 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 EBBETS PARTNERS, LTD., ASSIGNEE OF MBNA AMERICA BANK Plaintiff VS. ARLENE SOLIS Defendant Civil Action No. 01-5424 Civil Term PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter Judgment against the Defendant, Arlene Soils, above named, in the default of an Answer, in the amount of $1,998.44 computed as follows: Amount claimed in Complaint Interest from 6/22/01 to 2/1/02 at the contract interest rate of 26.90% per annum Payment less received TOTAL $3,301.80 $396.64 $ -(1,700.00) $1,998.44 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.P.A. William T. Molczan', Esqui~ PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#01871233 Plaintiff's addressis:c/oWeltman, Weinberg & Reis Co., L.P.A.,2601Koppers Building, 436 7th Avenue, Pittsburgh, PA 15219 Andthatthelastknown address ofthe Defendantis:608 Mallard Road, Camp Hill, PA 17011 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION EBBETS PARTNERS, LTD,, ASSIGNEE OF MBNAAMERICA BANK, N.A. Plaintiff VS. ARLENE SOLIS Defendant Civil Action No. 01-5242 IMPORTANT NOTICE TO: Arlene Soils 608 Mallard Road Camp Hill, PA 17011 Date of Notice: (~,/....._. ~_ .~,~'1 '~.~:~:~ ~'4...- YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN THIS CASE. 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 NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: LAWYER REFERRAL SERVICE Cumbeland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 WELTMAN, WEIN,BERG & REIS CO., L.P.A. William T. Molczan /~ PA I.D. ~N-7437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR #01871233 VERIFICATION 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. WELTMAN, WEINBERG & REIS CO, L.P.A. William T. Molczan, Esquire// PA I.D. #47437 ~' WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#01871233 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION EBBETS PARTNERS, LTD., ASSIGNEE OF MBNA AMERICA BANK Plaintiff VS, ARLENE SOLIS Defendant No. 01-5424 Civil Term PRAECIPE FOR SATISFACTION OF JUDGMENT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan, Esquire PA. I.D.#47437 WELTMAN, WEINBERG & REiS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#01871233 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION EBBETS PARTNERS, LTD., ASSIGNEE OF MBNA AMERICA BANK Plaintiff VS. ARLENE SOLIS Defendant Civil Action No. 01-5424 Civil Term 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. Pittsburgh, PA 15219 (412) 434-7955 Sworn to and before me this da of March, 02 I(IOTAR'~'~[~ PA. I.D.#47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue VWVR #01871233 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION EBBETS PARTNERS, LTD., ASSIGNEE OF MBNA AMERICA BANK Plaintiff VS. ARLENE SOLIS - Defendant No. 01-5424 Civil Term PRAECIPE FOR SATISFACTION OF JUDGMENT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan, Esquire PA. I.D.#47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#01871233 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION EBBETS PARTNERS, LTD., ASSIGNEE OF MBNA AMERICA BANK Plaintiff VS. Civil Action No. 01-5424 Civil Term ARLENE SOLIS 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 su.._~d before me this PA. I.D.#47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR #01871233