HomeMy WebLinkAbout02-19811N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
AC CREDIT UNION, INC.
Plaintiff
VS.
RONALD P. GUSCHEL, JR. a/k/a
RONALD PAUL GUSCHEL, JR.
Defendant
No.
COMPLAINT IN CIVIL ACTION
FILED ON BEHALF OF
Plaintiff
COUNSEL OF RECORD OF
THIS PARTY:
William T. Molczan, Esquire i
PA I.D. #47437
WELTMAN, WEINBERG & REIS CO., L.P.A.
2718 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR#02235303
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DWISION
AC CREDIT UNION, INC.
Plaintiff
VS.
RONALD P. GUSCHEL, JR. a/k/a
RONALD PAUL GUSCHEL, JR.
Defendant
Civil Action No. 0,~
COMPLAINT IN CIVIL ACTION AND NOTICE TO DEFEND
You have been sued in court. If you wish to defend against the claims set fo~h 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 wlth 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
Plaintiffis a corporation with offices at P.O. Box 400, Bath, Ohio 44210-0000.
2. Defendant is an adult individual residing at 473 Brook Circle, Mechanicsburg,
CUMBERLAND County, PA 17050.
3. Defendant applied for and received a Visa credit card issued by Plaintiff's assignor
bearing the account number 4109-1600-0980-9579..
4. Defendant made use of said Visa credit card and has currently a balanc~ due and owing to
Plaintiff, as of April 22, 2001, in the amount of $2,449.70.
5. Defendant is in default of the terms of the cardholder Agreement having not made monthly
payments to Plaintiff thereby rendering the entire balance immediately due and payable.
6. Plaintiff avers that the Cardholder Agreement between the parties provi~les that Plaintiff is
entitled to the addition of finance charges at the rate of 15.50% per annum on the unpaid balance.
7. Plaintiff avers that finance charges calculated at the aforesaid rate from April 22, 2001 to
March 28, 2002 amount to $353.70.
Plaintiff's reasonable attorneys' fees.
Plaintiff avers that the Contract between the parties provides that IIefendant will pay
9. Plaintiff avers that such attorneys' fees amount to $489.80 and said fees
continue to accrue.
10. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed and/or
refused to pay the principal balance, finance charges, attorneys' fees or any part thereof to Plaintiff.
WHEREFORE, Plaintiff demands Judgment in its favor and against Defendant, Ronald P.
Guschel, Jr. a/k/a Ronald Paul Guschel, Jr. individually, in the amount of $3,293.~0 with continuing
finance charges thereon at the rate of 15.50% per annum plus costs.
THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED
SHALL BE USED FOR THAT PURPOSE.
WELTMAN, WEINBERG & REI;,;, CO., L.P.A.
William T. Molczan, Esq~q)t'e
PA I.D. ~47437
WELTMAN, WE1NBERG & REIs CO., L.P.A.
2718 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR#:02235303
VERIFICATION
The undersigned does hereby verify subject to the penalties of 18 PA.C.S. §4904 relating
to unswom falsifications to authorities, that he/she is JOANNE SAM
(Name)
COLLECTION OFFICEI~ of A/C CliFf, IT Ill, fCiC. f~C. ,pla[ntiffherein, that
(Title) (Company)
he/she is duly authorized to make this Verification, and that the facts set forth in the fo~'egoing
Complaint are true and correct to the best of his/her knowledge, information and belief.
~,T-/- {'Signature~
SHERIFF'S RETURN -
CASE NO: 2002-01981 P
COMMONWEALTH OF PENNSYLVA/qIA:
COUNTY OF CUMBERLAND
AC CREDIT UNION INC
VS
GUSCHEL RONALD P JR AKA RONALD
REGULAR
BRIkN BARRICK , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
GUSCHEL RONALD P JR AKA RONALD PAUL GUSCHEL JR the
DEFENDANT , at 1820:00 HOURS,
at 473 BROOK CIRCLE
MECHANICSBURG, PA 17050
RONALD GUSCHEL JR
a true and attested copy of COMPLAINT
on the 29th day of April , 2002
by handing to
& NOTICE
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing 18.00
Service 9.66
Affidavit .00
Surcharge 10.00
.00
37.66
Sworn and Subscribed to before
me this /7 ~ day of
~0~2~ A.D.
;Prothonotary '
So Answers:
R. Thomas Kline
05/02/2002
WELTMAN WEINB~G REIS
Deputy Sheriff
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
AC CREDIT UNION, INC.
Plaintiff
VS.
RONALD P. GUSCHEL, JR. a/k/a
RONALD PAUL GUSCHEL
Defendant
No. 02-1981 Civil Term
PRAECIPE TO SETI'LE, DISCONTINUE
&END
FILED ON BEHALF OF
Plaintiff
COUNSEL OF RECORD OF
THIS PARTY:
William T. Molczan, Esquire
PA. I.D.g47437
WELTMAN, WEINBERG & REIS CO., L.P.A.
2718 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR#02235303
IN THE cOLrRT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DMSION
AC CREDIT UNION, INC.
Plaintiff
vs. Civil Action No. 02-1981 Civil Term
RONALD P. GUSCHEL, JR. a/k/a
RONALD PAUL GUSCHEL
Defendant
I'P, AECIPE TO SETTLE DISCONTINUE AND END
TO Tgl]~, PROTHONOTARY OF COUNTY:
Please kindly Settle Discontinue and End the above captioned matter upon the records of the Court and
mark the cost paid.
Sworn to and subA~ed
Before me the ~.__~ )
WELTMAN, WEINBERG & REIS CO., L.P.A.
By:
~ViAl. lii7~ T~M4;¢czafi, Esquf
WELTMAN, WEINBERG & REIS CO., L.P.A.
2718 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR~2235303