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Home My WebLink About06-5471IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL: DIVISION 'CIS SERVICES, LLC ?7'?y Plaintif=f No: OL S l vs. COMPLAINT IN CIVIL ACTION MARY R COX Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt,42524 WEITMAN, WEINBERG & REIS CO., L.P.A. 435 Seventh Avenue, Suite 2718 Pictsburgi, PA 15219 (412) 434-7955 FAN: 422-338-V130 05340894 C A Pit KEB IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION AIS SERVICES, LLC Plaintiff vs. Civil Action No MARY R COX Defendant COMPLAINT AND NOTICE TO DEFEND You have been sued in court. I you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complain! : and notice are served, by entering a written appearance personally or b?,,, an attorney 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 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 mosey 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 CA?! GET LEGAL HELP. IF YOU CANNOT AFFORD TO HIRE A 1,AWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUF` AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A RE'>UCED FEE OR NO FEE. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY 3AR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, -'PA 17013 (717) 249-3166 COMPLALNT 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: MARY R COX 7073 CARLISLE PIKE TRLR 1 CARLISLE, PA 17013 3. Defendant applied for and received a credit card bearing the account number 5440455002531336 . 4. Defendant made use of said credi,:, card and has a current balance due of $993.56 , as of September 11, 2006 . 5. Defendant is in default by failing to make monthly payments when du 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 9.9900 per annum on the unpaid balance from September 11, 2006 . A copy of Plaintiff's STATMENT 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 , MARY R COX , INDIVIDUALLY , in the amount of $993.56 with continuing interest thereon at the rate of 9.990% per annum from September 11, 2006 plus costs. JamE C. 'WMmbrodt, 42524 ,EL, WEINBERG & REIS CO., L.P.A. 43(y S venth Avenue, Suite 2718 P' is urgh, PA 15219 (, 12 434-7955 ,,' . 412-338-7130 0 40894 C A Pit KEB Phis law firm is a debt collector attempting to collect this debt for our client and any information obtained will be used for that purpose. S i `o'(C-f I_/ AIS Services LLc CHARGE-OFF STATEMENT ACCOUNT NUMBER PAYMENT DUE DATE PAST DUE AMOUNT MINIMUM PAYMENT NEW BALANCE AMOUNT OF PAYMENT ENCLOSED 5440455002531336 03/15/2005 898.72 243.74 971.23 $ MARY R COX 7073 CARLISLE PIKE TRLR 100 CARLISLE PA 17013-9761 50 CALIFORNIA STREET SUITE 1500 SAN FRANCISCO CA 94111 ACCOUNT NUMBER CREDIT LINE CREDIT AVALIABLE DAYS IN BILLING CYCLE BILL DATE PAYMENT DUE DATE PAYMENT D 5440455002531336 800.00 32 02/28/2005 03/15/2005 243.74 DATE OF TRANS POST REFERENCE NUMBER DESCRIPTION OF TRANSACTIONS AMOUNT 0228 0000 0228 0000 OVERLRvIlT FEE LATE CHARGE - MIN PYMT NOT RECD BY DATE **** FINANCE CHARGE CURRENT PURCHASE 29.00 35.00 8.51 PREVIOUS BALANCE PAYMENTS CREDITS NEW PURCHASES AND ADVANCES DEBIT ADJUSTMENTS FINANCE CHARGES OVERLINE AMOUNT NEW BALANCE 898.72 .00 .00 .00 64.00 72.51 171.23 971.23 AN AMOUNT FOLLOWED BY A MINUS SIGN(-) IS A CREDIT BALANCE UNLESS OTHERWISE INDICATED YOU MAY AVOID ADDITIONAL FINANCE CHARGES ON PURCHASES IF YOU PAY THIS AMOUNT BY THE DUE DATE TYPES OF CREDIT TO WHICH RATES APPLY FINANCE CHARGE BALANCES DAILY PERIODIC RATE NOMINAL ANNUAL PERCENTAGE RATES ANNUAL PERCENTAGE RATES PURCHASES 898.72 .02737 % 9.99% 9.99% ADVANCES .06299% 22.99% % r 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 r VERIFICATION The undersigned does hereby verify subject to the p ties of 18 A. C.S. 4904 relating he/she is duly authorized to make this verification, and that the facts set forth in the foregoing Complaint to unsworn falsifications to authorities, that he/she is (NAME) of plaintiff herein, that (TITLE) (COMPANY) are true and correct to the best of his/her knowledge, information and belief n (SIGNATURE) WWR# SHERIFF'S RETURN - NOT FOUND CASE NO: 2006-05471 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND AIS SERVICES LLC VS COX MARY R R. Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT COX MARY R but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT & NOTICE , NOT FOUND , as to the within named DEFENDANT , COX MARY R 7073 CARLISLE PIKE TRLR 1 CARLISLE, PA 17013 RESIDENT/OWNER NEVER HEARD OF DEFENDANT. NO RECORD OF DEFENDANT AT POST OFFICE. Sheriff's Costs: So answers Docketing 18.00 Service 4.40 Not Found 5.00 R. Thomas Kline Surcharge 10.00 Sheriff of Cumberland County .00 37.40,/_ WELTMAN WEINBERG REIS alialeG 10/03/2006 l Sworn and Subscribed to before me this day of , A. D. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION AIS SERVICES, LLC Plaintiff vs. MARY R COX Defendant No. 06,6471-CIVIL-TERM FRAECIPE TO REINSTATE COMPLAINT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt, Esquire PA IA #42524 WELTMAN, WEINBERG & REIS CO., L<.P,A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 1 S2 19 (412) 4344955 WWR4053401194 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION AIS SERVICES, LLC Plaintiff vs. MARY R COX Defendant Civil Action No. U6-5471-CIVIL-TERM PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint, in the above captioned matter. WELTMAN, WEINBERG & REIS CO„ L.P.A. BY: - James C. armb dt, Esquire PA 1 2524 WELT 'AN, WE BERG & REIS CO., L.P,A. 2718 ppers B !ding 436 S venth Av nue Pitts r;h, P 15219 (412t4434-7 5 r ? tQ : o r: a. -TI /? ' X71 '°•'?). TIC t7r: J -< SHERIFF'S RETURN - REGULAR CASE NO: 2006-05471 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND AIS SERVICES LLC VS COX MARY R KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE REINST was served upon nnv MTDV D the DEFENDANT at 1513:00 HOURS, on the 31st day of July , 2007 at 7073 CARLISLE PIKE TRLR 100 CARLISLE, PA 17013 by handing to MELINDA GOODMAN (ADULT IN CHARGE) a true and attested copy of COMPLAINT & NOTICE REINST together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 5.76 Affidavit .00 Surcharge 10.00 .00 Q/89f0 33.76 Sworn and Subscibed to before me this day of So Answers: ?,000, ,;re R. Thomas Kline 08/01/2007 WELTMAN WEINBERG & REIS By. A. D. HE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA IN CIVIL DIVISION AIS SERVICES, LLC No. 06-5471-CIVIL- f IRM Plaintiff PRAECIPE. IO SE:I'"I LE, DISCONfINUE vs. & END WITH PREJUDICE MARY R COX Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warrnbrodt, Esquire Pa. I.D. No. 42524 Weltman, Weinberg & Reis, Co, LLC 2718 Koppers Building 436 7"' Avenue Pittsburgh, PA 15219 W W R#05340894 AWw IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY. PF NNSYI,VANIA CIVIL DIVISION AIS SERVICES, LLC Plaintiff vs. MARY R COX Defendant Civil Action No. 06-5471-CIVIL-TERM A TO THE PROTHONOTARY OF COUNTY: C Please kindly Settle Discontinue and End the above captioned matter with Prejudice upon the records of the Court and mark the cost paid. WELTMAN, WEINBERG & REIS CO., L.P.A. By; James C. W Pa. I.D. No Weltman, 2718 Ko e th Sworn to and subscribed AARY in 2007 ?rrnt)r dt, Esquire 42524 einbe & Reis, Co, LLC •s Bu' ding 436 7 venue Pittsbu ghV8 P 15219 WWR 053 94 K"6 . / W(-;1dy L. 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