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Home My WebLink About02-1978 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRIMARY FINANCIAL SERVICES vs. No. 0.2; / if? S? ~ -r-e--.- COMPLAINT IN CIVIL ACTION Plaintiff ALAN C. MCPHERSON Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Mo1czan, Esquire PA LD. #47437 I WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building I 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#02369999 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENN~YL VANIA CIVIL DIVISION ! PRIMARY FINANCIAL SERVICES Plaintiff vs. Civil Action No. 0.2. /97 r ew.u I ~ ALAN C. MCPHERSON Defendant COMPLAINT IN CIVIL ACTION AND NOTICE TO DEFENDI I You have been sued in court. If you wish to defend against the claims set forlh in the following pages, you must take action within twenty (20) days after this complaint and notibe are served, by entering a written appearance personally or by an attorney and filing in writing wtth the court your defenses or objections to the claims set forth against you. You are warned that if you faU 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 TIfIE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, P A 17013 (717) 249-3166 COMPLAINT 1. Plaintiff is a corporation with offices in Phoenix, Arizona 85013. 2. Defendant is an adult individual residing at 6003 Mockingbird Drive, Mechanicsburg, CUMBERLAND County, P A 17055. 3, Defendant applied for and received a MASTERCARD credit card issued by Plaintiff's assignor bearing the account number 5411-1790-0195-3268,. 4. Defendant made use of said MASTERCARD credit card and has curr$tly a balance due , , and owing to Plaintiff, as of April 4, 2001, in the amount of$6,087.18, as shown by P~aintiff's Statement I of Account attached hereto, marked as Exhibit "1" and made a part hereof 5. Defendant is in default of the terms ofthe cardholder Agreement having not made monthly payments to Plaintiffthereby rendering the entire balance immediately due and payable.! 6. Plaintiff avers that the Cardholder Agreement between the parties proviJes that Plaintiff is entitled to the addition of finance charges at the rate of 24.56% per annum on the unpaid balance. 7. Plaintiff avers that finance charges calculated at the aforesaid rate frorrj. April 4, 2001 to March 15,2002 amount to $1,413.09. 8. Although repoaredly "que'ted to do 00 by PI""'tiff, Doren",,", b" WilltUllY f"l,d ""dlo' refused to pay the principal balance, finance charges or any part thereofto Plaintiff I WHEREFORE, Plaintiff demands Judgment in its favor and against Defendant, Alan C, McPherson individually, in the amount of$7,500.27 with continuing finance charges thereon at the rate of 24.56% per annum plus costs, THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED SHALL BE USED FOR THAT PURPOSE. WELTMAN, WEINBERG & REIS, CO., L.P.A. William T. Mo czan, E PA LD. #47437 I WELTMAN, WEINBERG & REI~ CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#:02369999 <D First National Bank Omaha . Account Number: 5411179001953268 First National Bank Omaha P.O, Box 2951 Omaha, NE 68103-2951 Payment Due Date: New Balance: Minimum Payment Due: April 4, 2001 $6,087.18 $6,087.18 L 11150 ALAN C MC PHERSON 6003 MOCKINGBIRD DR MECHANICSBURG, PA 17050-2077 Make chacks p~yeble to 1$ First National Bank Omaha Amount Enclosed Change of Address? Please complete reverse side, 5411179001953268 0000000608718 0000000608718 PLEASE DETACHHEAE AND RETURN TOP PORTION WITH YOUR PAYMENT PLATINUM EDITION MASTERCARD Payment Due Account Number: 5411 1790 0195 3268 Statement Closing Date Days in Billing Cycle Payment Due Date Amount Past Due $ Minimum Payment Due $ 03-12-01 33 04-04-01 6,087,18 6,087.18 Account Summary Previous Balance $ 6,048,23 Payments and Credits - $ 0.00 New Transactions + $ 38.95 Total Billed FINANCE CHARGES New Balance +$ $ Cr~dit Line Total Credit Limit $ Cash Limit t $ Available credil' $ Available Cash, $ 4,900.00 2,750.00 0.00 0.00 0,00 6,087.18 75411171071000071062000 Visit us online! Please see our address below. Average Dally Balance Current Old Dall Periodic Rate Corres 0.0000% 0.0000% $ $ 0,00 $ 0.00 $ 2,313.19 2,691.69 Billed Periodic Rate FINANCE CHARGE $0.00 Online Access www.firstnational.com Issued by First National Bank of Omaha Need Help? Customer Service Toll Free Balance Transfer Hotline TOD Teleco munications Device for the Deal Toll Free Toll Free ~':m"JBIT See reverse for additional information. Page 1 of 1 : . ,- VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA.C~S. ~4g04 relating unsworn falsifications to authorities, that he/she is :::t<,IU[)f1 uJ,qch~ /J. ..... (Name) 5k. )e/Ulte'e;Ic...erJk of r::-~tJa..f,~t3UAtK-dJ~<- , 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. ~~<udk~ (Signature) I I I I # -j:- C)d-fu~~a. C1 .. ~ ~ ~ s\ 0 0 ~ C I'J 0 ,,- -n I ""C.> -~ :coo ...... ~q:; " ::;:1 >-> ;:;0 ;:-;.ifQ -.c:; <><J Gi5~: ,"-' 0- .. -~7f"n i \)0 -<"'7 I'J _';f:) ""'ll ..... ~ r-rc':l i:) '1. i V~ -c <-- " ~..., L) ~ )> ~~S ~E -l:I zO :-1: 0 --0 ~ >c: .,,0 ...:& W iSm ~ co J;! -.I ::rJ -< SHERIFF'S RETURN - REGULAR CASE NO: 2002-01978 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PRIMARY FINANCIAL SERVICES VS MCPHERSON ALAN C BRIAN BARRICK , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon MCPHERSON ALAN C the DEFENDANT , at 2012:00 HOURS, on the 29th day of April at 6003 MOCKINGBIRD DRIVE , 2002 MECHANICSBURG, PA 17055 by handing to ALAN MCPHERSON 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: 18.00 7.59 .00 10.00 .00 35.59 r~~~c:#~ R. Thomas Kline Sworn and Subscribed to before 05/01/2002 WELTMAN WEINBEi7. ~ REII!S By: ~~ ~ 11ft Deputy Sheriff me this J1& day of ~ /" :2&o::u A.D. ()'f'--' a ~ 4tli rothonotary , { IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRIMARY FINANCIAL SERVICES, Plaintiff No. 02-1978-CIVIL TERM V5. SUGGESTION OF BANKRUPTCY ALAN C. MCPHERSON, Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: JAMES P. VALECKO, ESQ. PA ID 79596 WELTMAN, WEINBERG & REIS CO. L.P.A. 2718 KOPPERS BUILDING 436 7TH AVE. PITTSBURGH, PA. 15219 (412) 434-7955 WWR#02369999 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRIMARY FINANCIAL SERVICES, Plaintiff No. 02-1978-CIVIL TERM Vs. ALAN C. MCPHERSON, Defendant SUGGESTION OF BANKRUPTCY TO PROTHONOTARY: AND NOW comes Plaintiff, by counsel, Weltman, Weinberg & Reis, Co., L.PA to advise this Honorable Court that the above named Defendant, Alan C. McPherson, has filed a Chapter 13 Bankruptcy in the United States Bankruptcy Court for the Middle District of Pennsylvania at Bankruptcy Case Number 02-02672, and accordingly, all proceedings in this Court are stayed pursuant to 11 U.S.C. !:i 362. WELTMAN, WEINBERG & REIS CO., L.PA ByQ JamesP. ~ lecko, Esq. Attorney for Plaintiff 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 o c -0;)& nlr"n Z::r.i :zr .. en ",r-. -< ,.c.: ~l.) ~~2 -7 ~ o r'v c... S ;;'.1_ .... .. (~ -'n 1'1 I Co.::' , ~t~r ~-;~) '}~q ~0', ::.; :j; ::< -0 -."'!'.... w :::> co IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRIMARY FINANCIAL SERVICES Plaintiff No. 02-1978-CIVIL TERM vs. PRAECIPE TO SETTLE, DISCONTINUE AND END WITHOUT PREJUDICE TO REFILE ALAN C MCPHERSON Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: JAMES C. WARM BRODT PA 1.0 #42524 WELTMAN, WEINBERG & REIS CO., LPA 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#02369999 ~ IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRIMARY FINANCIAL SERVICES Plaintiff vs. Civil Action No. 02-1978-CIVIL TERM ALAN C. MCPHERSON Defendant PRAECIPE TO SETTLE. DISCONTINUE AND END WITHOUT PREJUDICE TO REFILE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: SIR: Settle, Discontinue and End the above-captioned matter upon the records of the Court without prejudice to refile and mark the costs paid. WELTMAN, WEINBERG & REIS CO, L.PA ,/ of SWORN TO AND SUBSCRIBED NOT "':;'::"c o ...., ;~ = "-'". -,..."'" c::: G") =~ . " (..) ~ --\ :J:-n rJ1p ~p :.:?t; ;s,~A -,1 -"':, c..'? -.-.'" c;, ~