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HomeMy WebLinkAbout06-5470 IN THE COURT OF COMMON PLEAS OF CUMBl;:RLAND COUNTY, PENNSYLVANIA CIVIL LI'nSION AIS SERVICES, LLC Plaintiff No: Ot- - S'I1D CiDLL 1€tL~ V8. COMPLAINT IN CIVIL ACTION MELISSA M BEERS Defendant FILED ON BEHALF OF Plclintiff COUNSEL OP RECORD OF THIS PARTl: LJalnes C. \\Tarmbrodt,42524 WELTMAN, 'tiTEINBERG & REIS CO., L. P. A. 'dG Sevent.h Avenue, Suite 2718 Pittsburgh, PA 15219 ( 4',2 ) 4 3 4 - 7 9 5 5 FAX: 412-338-7130 05~40876 C A Pit KEB IN THE COURT OF COMMON PLEAS OF CUMB:.:RLAND COUNTY, PENNSYLVANIA CIVIL DrnSION AIS SERVICES, LLC Plaintiff vs. ci viI l\ct ion No MELISSA M BEERS 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 wr~tten appearance personally or by an at:orney and filing in writing with the court your defenses or objections co 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 e~tered against you by the cou~t 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 CAJ'.J 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 COfv]PLA~NT 1. Plaintiff, AIS SERVICES, LLC is a corporation with offices at 6851 JERICHO TURNPIKE #190 SYOSSET , NY 11791 . 2. Defendant is adult individual(s) residing at the address listed below: MELISSA M BEERS 804 ERFORD RD CAMP HILL, PA 17011 3. Defendant applied for and received a credit card bearing the account number 5440455008652193 . 4. Defendant made use of said credit card and has a current balance due of $784.83 , as of September 11, 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 ?laintiff. 6. Plaintiff is entitled to the addLtion of interest at the rate of 9.990% per annum on the unpaid balance ~rom September ~1, 2006 . A copy of Plaintiff's STATMENT is attached her-eta, 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 , MELISSA M BEERS INDIVIDUALLY , In the amount of $784.83 with continuing interest thereon at the rate of 9.990% per annJm from September II, 2006 plus costs. armbrodt,42524 AN, WEINBERG & REIS CO., L.P.A. eventh Avenue, Suite 2718 burgh, PA 15219 l41 ) 434-7955 k : 412-338-7130 /J 340876 C A Pit KEB ~-- -' This law firm is a debt collector at~empting to collect this debt for ouy client and any information obcained will be used for chat purpose. )3~((ft lr; AIS Services LLC CHARGE-OFF STATEMENT ACCOUNT NUMBER PAYMENT PAST DUE MINIMUM NEW AMOUNT OF DUE DATE AMOUNT PAYMENT BALANCE PAYMENT ENCLOSED 5440455008652193 02/15/2005 696.47 237.91 767.19 $ MELISSA M BEERS 804 ERFORD RD CAMP HILL PA 17011-1127 50 CALIFORNIA STREET SUITE 1500 SAN FRANCISCO CA 94111 ACCOUNT NUMBER CREDIT LINE CREDIT A V ALIABLE DAYS IN BILL BILLING CYCLE DATE PAYMENT DUE DATE ~ p~ 5440455008652193 600.00 32 01/31/2005 02/15/2005 237.91 DATE OF 1RANS POST REFERENCE NUMBER DESCRIPTION OF 1RANSACTIONS AMOUNT 0131 0131 0000 0000 OVERLIMIT FEE LATE CHARGE- MINPYMTNOTRECDBYDATE 29,00 35.00 .... FINANCE CHARGE CURRENT PURCHASE 6.72 PREVIOUS NEW PURCHASES DEBIT FINANCE OVERLlNE NEW BALANCE PAYMENTS CREDITS AND ADVANCES ADJUSTMENTS CHARGES AMOUNT BALANCE 696.47 .00 .00 .00 64.00 70.72 167.19 767.19 AN AMOUNT FOLLOWED BY A MINUS SIGN(-) IS A CREDIT BALANCE UNLESS OTHERWISE INDICATED $ TYPES OF CREDIT TO FINANCE DAILY NOMINAL ANNUAL ANNUAL WHICH RATES APPLY CHARGE BALANCES PERIODIC RATE PERCENTAGE RATES PERCENTAGE RATES PURCHASES 696.47 .02737 % 9.99% 9.99% ADVANCES .06299 % 22.99 % % YOU MAY AVOID ADDITIONAL FINANCE CHARGES ON PURCHASES ff YOU PAY THffi AMOUNT BY THE DUE DATE QUESTIONS about account? Credit Card lost or stolen? Call Customer Service 24 hours a day 7 days a week, toll- free at 1-888-920-1300 . Para Servicio al Cliente en espanol: 1-888-920-1300 VERI FICA TION The undersigned does hereby verify subject to the pralties of 18 A. C.~. 4904 relating to unsworn falsifications to authorities, that he/she is ~G\ 0t b I (NAME) of A\S '7-IV:Z/7 (CL , plaintiff herein, that (COMPANY) ~eQ~ (TITLE) 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 ofbis/her knowledge, infonnationz~ ~ (SIGNATURE) WWR# .,..' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION AIS SERVICES, LLC Plaintiff No. 06-5470-CIVIL TERM VS. PRAECIPE FOR DEFAULT JUDGMENT MELISSA M BEERS Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt PA J.D. 42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 Seventh Avenue, Suite 2718 Pittsburgh, P A 15219 (412) 434~7955 FAX: 412-338-71305 WWR#0534Q876 Judgment Amount $ 801.80 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 AIS SERVICES, LLC Plaintiff vs. Civil Action No. 06.5410.CIVIL TERM MELISSA M BEERS Defendant PRAECIP~ 'OJ! DE,AULT JU~9MEN1: TO THE PROTHONOTARY: Kindly enter Judgment against the Defendant, MELISSA M BEERS above named, in the default of an Answer, in the amount of$801.80 computed as follows: Amount claimed in Complaint $184.83 Interest from September 11, 2006 to November 29, 2006 at the legal interest rate of9.990% per annum $16.9'7 TOTAL $801.80 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 &. REfS CO., L.P.A. By: James C. rmbrodt PA LD. 524 WELT N, WEINBERG & RBIS CO., L.P.A. 436 Sev nt Avenue, Suite 2718 Pittsb r ,PA 15219 (412) 3 .7955 FA : 12,,338,,71305 W 05340816 Plaintiff's address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7th Avenue, Pittsburgh, PA 15219 And that the last known address of the Defendant is: 804 ERFORD RD, CAMP HILL, PA 170 II. " IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION AIS SERVICES, LLC Plaintiff Case # &~-9Lj70-tiv((TfU"ff) MELISSA M BEERS Defendant(s) IMPORTANT NOTICE TO: MELISSA M BEERS 804 ERFORD RD CAMP HILL,PA 17011 O~ 8l,d@.e Date of Notice: WWR#: 05340876 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 YOU WITHOUT 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 ESQUIRE PA I. D .At 2524 WELTMAN~ EINBERG & REIS CO., L.P.A. 2718 KOP ERS BLDG, 436 7TH AVE. PITTSB GH, PA 15219 IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY , PENNSYLVANIA CIVIL DIVISION AIS SERVICES, LLC Case no: 06~54 70~CIVIL TERM Plaintiff NON-MILITARY AFFIDAVIT vs. MELISSA M BEERS 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, MELISSA M BEERS 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, MELISSA M BEERS is not in the military service. Further Affiant sayeth naught. SWORN TO AND SU f ED in my presence this '3Of6hy COMMONWEALTH OF PENNSYLVANIA \ Notarial Seal . , Heiol ,.J. Kelly. Notary PublIC , )f PittstJUrgh. Allegheny C':'L\!.~ .mmisSlOp Expires Nov _~~J ~,~.- 8~s,,\vania Associa:.,~.-,-~ . i1"'S 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. Request for Military Status Page 1 of2 Department of Defense Manpower Data Center . Military Status Report Pursuant to the Servicemembers Civil Relief Act NOV -28-2006 13 :50:04 < Last Name First/Middle Begin Date I Active Duty Status T Service/Agency BEERS 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. ~~. ~-~ Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 The Defense Manpower Data Center (DMDC) is an organization of the 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. #167;#167; 501 et seq] (SCRA) (formerly the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information 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 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. For historical information, please contact the Military Service SCRA points-of-contact. See: http://www.defenselink.mil/faq/pisIPC09SLD R.html WARNING: This certificate was provided based on a name and Social Security number (SSN) provided https://www.dmdc.osd.mil/scralowalscra.prc_Select 11/28/2006 .Request for Military Status Page 20f2 by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID:BBSELLCMEDI https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 11/28/2006 c ~ (.::I "'" ~\\-\; ~ 0.- 0 \' ~ 'J f"" W :cJ ~ cS ~ ~ t- r ~s 1'-,) = r:;:;:> 0 <::.0--- ,I g ::;J '-.i fil -n -,.,. ~'a (....) Cl CO IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION AIS SERVICES, LLC Plaintiff vs. Civil Action No. 06.5470.CIVIL TERM MELISSA M BEERS Defendant NOTlQE OF JUDQMENT OR QRD~~ TO: () Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the following ord~.r r JUdgm.e.nt was entered alilainst you on ..J}E,.. . (I, ,)/V'Ic (xx) Assumpsit Judgment in the amount of $80 1,80 plus costs. () Trespass Judgment in the amount of !Ii ~ plus costa, () Ifnot satisfied within sixty (60) days, your motor vehicle operator's license andlor registration will be suspended by the Department of Transportation. Bureau ofTraffie Safety, Harrisburg, PA. (xx) Entry of J\.!dgment of () Court Qrder () Non-Pros () Confession (xx) Default () Verdict () Arbitration Award Prothonotary BY:~ PROT NOTAR ....... ... .' ..'i~ - MELISSA M BEERS 804 ERFORD RD CAMP HILL,PA 17011 Plaintiffs address is: clo Weitman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7th Avenue, Pittsburgh. PA 15219 1.888.434.0085 SHERIFF'S RETURN - REGULAR CASE NO: 2006-05470 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND AIS SERVICES LLC VB BEERS MELISSA M KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon BEERS MELISSA M the DEFENDANT , at 2018:00 HOURS, on the 4th day of October , 2006 at 804 ERFORD ROAD CAMP HILL, PA 17011 by handing to TOM BEERS, HUSBAND 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 18.00 13.20 .00 10.00 .00 41.20~ h/6I.JO~L-,A to So AnSW:r;,'/ _ ~ .~~. R. Thomas Kline 10/06/2006 WELTMAN WEINBERG REIS Sworn and Subscibed By: before me this day of A.D.