The URL can be used to link to this page

Home My WebLink About06-5512 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION AIS SERVICES, LLC Plaintiff vs. LINDA L PORTER Defendant C~1 CO:~IPLATNT IN CIVIL ACTION FI'.~ED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt,42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 435 Seventh Avenue, Suite 2718 Pittsburgh, PA 15219 (412) 434-7955 FAX: 412-338-7130 U534U998 C A Pit VOC IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION AIS SERVICES, LLC Plaintiff vs. Civil Action No LINDA L PORTER Defendant COMPLAINT AND NO",ICE 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 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 morie.y claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose ncney or property or other rights im;~ortant to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, CUO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CA27 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 REFERRr'1L SERVICE CUMBERLAND COtJNTY F3AR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, i?A 1/C13 (711) 24'~)-3166 CUMPLATNT 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: LINDA L PORTER 384 PIN OAK LN CAiZt ISLE, PA 17013 3. Defendant applied for and received a credit card bearing the account number 5488975014707627 . 4. Defendant made use of said credit card and has a current balance due of $751.44 as of September 08, 2006 5. Defendant is iri default by failing to make monthly payments when due. 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 08, 2006 A copy of Plaintiff's STATEMENT OF ACCO UNT 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 LINDA L PORTER INDIVIDUALLY in the amount of $751.44 with continuing interest thereon at the rat:e of 9.9900 per annum from September O8, 2006 plus costs. ---- --- ~)am ~ C. rm rodt,47.524 '.^1E M , WEINBERG & REIS CO., L.P.A. ~~3 Se enth Avenue, Suite 2718 P ttsb rgh, PA 15219 412) 434-7955 i'AX: 412-338-7130 053 0998 C A Pit VOC This law firm is a debt collector ~empting to co_11ect this debt for our client and any information obtained will be used for that purpose. 5 3~(G~~~ AIS Services LLC CHARGE-OFF STATEMENT ACCOUNT NUMBER PAYMENT DUE DATE PAST DUE AMOUNT MINIMUM PAYMENT NEW BALANCE AMOUNT OF PAYMENT ENCLOSED 5488975014707627 02/15/2005 664.70 305.58 735.14 $ LINDA L PORTER 384 PIN OAK LN CARLISLE PA 17013-7825 50 CALIFORNIA STREET SUITE 1500 SAN FRANCISCO CA 94111 ACCOUNT NUMBER CREDIT LINE CREDIT AVALIABLE DAYS IN BILLING CYCLE BILL DATE PAYMF,NT DUE DATE MINIMUM PAYMENT DUE 5488975014707627 500.00 32 01/31/2005 02/15/2005 305.58 DATE OF TRANS POST REFERENCE NUMBER DESCRII'TION OF TRANSACTIONS AMOUNT 0131 0000 0131 0000 OVERLIIvIIT FEE LATE CHARGE - MIN PYMT NOT RECD BY DATE **** FINANCE CHARGE CURRENT PURCHASE 29,00 35.00 b,qq PREVIOUS BALANCE PAYMENTS CREDITS NEW PURCHASES AND ADVANCES DEBIT ADJUSTMENTS FINANCE CHARGES OVERLINE AMOUNT NEW BALANCE 664.70 .00 .00 .00 64.00 70.44 235.14 735.14 AN AMOUNT FOLLOWED BY A MINUS SIGN(-) IS A CREDIT BALANCE UNLESS OTHERWISE INDICATED YOU MAY AVOID ADDITIONAL FINANCE CHARGES ON PURCHASES IF YOU PAYTHISAMOUNT 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 664.70 .02737 % 9.99% 9.99 % ADVANCES .06299 % 22.99 QUESTIONS about account? Credit Card lost or stolen? Call Customer Service 24 hours a day 7 days a week, toll- free at 1-88&920-1300 . Para Servicio al Cliente en espanol: 1-88&920.1300 EXHIBIT VERIFICATION The undersigned does hereby verify subject to the p a~ties of 18 A.[rC~.S. 4904 relating to unsworn falsifications to authorities, that he/she is ~ LI, -J ~ (NAME) of ,plaintiff herein, that (TITLE) (COMPANY 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 (SIGNATURE) WWR# ~. /.`. /~~2 ~r ~ ~ tf~ .,q ~ ~s~ ~ ~~ C~.~ r ` -c~ ff ; fir; r",~ ~~ ~~~~ r .tF ~ .~_ ~ ~ ~ ~~.~ cx~ IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CNIL DNISION K Plaintiff vs. Civil Action No. 06 CV ~8- S'S'!~ LINDA L PORTER Defendant ~ PRAECIPE FOR JUDGMENT BY CONSENT TO THE PROTHONOTARY: Kindly enter Judgment against Defendant, LINDA L PORTER , in the amount of $756.47 plus costs, based upon the consent of the parties. CONSENTED TO: WELTMAN, WEINBERG & REIS CO., L.P.A., LINDA L PORTER , By: Def dant ~_ "~ ~~ L 4 c~-, ~' .r-. 't'om M .. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION AIS SERVICES, LLC Plaintiff v S. LINDA L PORTER Defendant No.06-5512 CIVIL TERM STIPULATION OF THE PARTIES FOR PAYMENT AND FOR THE ENTRY OF JUDGMENT BY CONSENT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt, Esquire PA I.D. #42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#05340998 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CNIL DNISION AIS SERVICES, LLC Plaintiff vs. Civil Action No. 06-5512 CNIL TERM LINDA L PORTER Defendant STIPULATION OF THE PARTIES FOR PAYMENT AND FOR THE ENTRY OF JUDGMENT BY CONSENT TO THE PROTHONOTARY: Kindly enter Judgment in favor of Plaintiff and against the Defendant, LINDA L PORTER ,above-named, in the amount of $756.47 pursuant to the Stipulation of the Parties for Payment and for the Entry of Judgment by Consent, as follows: 1. Defendant admits indebtedness to Plaintiff in the amount of $756.47 with continuing interest thereon at a rate of 6.00% per annum plus costs from OCTOBER 3, 2006. 2. To secure the repayment of said indebtedness, Defendant agrees that Judgment by Consent will be entered in favor of the Plaintiff and against the Defendant, LINDA L PORTER , in the amount of $756.47 plus continuing interest thereon at the rate of 6.00% per annum from OCTOBER 3, 2006 and costs. 3. Plaintiff agrees not to execute on its Judgment so long as Defendant causes to be delivered to Plaintiff the following payments in full by 12:00 NOON on the following dates: (a) $150.00 due by 10/13/06; (b) $100.00 due on the 13TH day of each consecutive month thereafter until the Judgment amount plus accrued interest and costs are paid in full. .r 4. All payments are to be made payable to the order of "CAPITAL ONE BANK" 5. All payments due under this agreement are to be received at the offices of Weltman, Weinberg & Reis, Co., L.P.A., 2718 Koppers Building, 436 Seventh Avenue, Pittsburgh, PA 15219. 6. In the event of default, each payment received shall be first attributed to costs, interest and then to principal. 7. Time is of the essence of this agreement and should the Defendant fail to have in the hands of Plaintiff or Plaintiff s counsel any payment in full within five (5) calendar days of the stated due date, then Plaintiff shall be immediately free to issue Execution as well as pursue all other remedies, in law or in equity, to collect the full balance of the Judgment entered hereunder plus appropriate additional interest and costs. 8. No act or omission of the Plaintiff, nor of anyone alleged to be acting on its behalf, shall constitute a waiver, estoppel, or any other excuse for non-performance of any duty undertaken by the Defendant in this Stipulation which the parties agree is final and complete. ,~ 9. Intending to be legally bound, the parties set their hands and seals thi~ day of , 20 ~'-~ . WELTMAN, WEINBERG & REIS CO., L.P.A. By: James PA I.D. WELT E 2718 op 436 Sever L25 ~N, armbrodt, Esquire 41 B ~ V~ Y Defendant, LINDA L PORTER & REIS CO., L.P.A. Avenue A 15219 34-7955 No. 05340998 ~ ~ p F ~ +- ~ ~ 0 ~.~~~ ~ ~ ~ ~' ~ C7 ~ ~ ~c~ ~ ~ ~ -rf ' ~~~ ~ ~ `~ ~'; ~r;' ' ~ c.ati ~. ~c~y -MS s ,; L .~~. 'rrt? ,a :~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DNISION AIS SERVICES, LLC Plaintiff vs. Civil Action No. 06-5512 CNIL TERM LINDA L PORTER Defendant NOTICE OF JUDGMENT UR URDEIt TO: ( )Plaintiff (xx) Defendant ( )Garnishee You are hereby notified that the following Order or Judgment was entered against you on ;Z,aC~ (xx) Assumpsit Judgment in the amount of $756.47 plus costs. ( ) Trespass Judgment in the amount of $ plus costs. ( ) If not satisfied within sixty (60) days, your motor vehicle operator's license and/or registration will be suspended by the Department of Transportation, Bureau of Traffic Safety, Harrisburg, PA. (xx) Entry of Judgment of ( ) Court Order ( ) Non-Pros ( ) Confession ( ) Default ( ) Verdict ( ) Arbitration ( ) Award (XX) By Consent Prothonotary Linda L Porter 384 Pin Oak Ln Carlisle,Pa 17013 By: PROT ONOTAR SHERIFF'S RETURN - REGULAR CASE N0: 2006-05512 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND AIS SERVICES LLC VS PORTER LINDA L MICHAEL BARRICK Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon PORTER LINDA L the DEFENDANT at 1955:00 HOURS, on the 28th day of September, 2006 at 384 PIN OAK LANE CARLISLE, PA 17013 by handing to LINDA L PORTER 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: So Answers: Docketing 18.00 A~~ Service 6.16 '%'~ Affidavit .00 Surcharge 10.00 R. Thomas Kline .00 34.16 / 00/00/0000 /o~ia~oL ~~~ Sworn and Subscibed to By: before me this day Deputy riff of A.D. ~ t IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION AIS SERVICES, LLC Plaintiff vs. LINDA L PORTER Defendant No. 06-5512 CIVIL TERM PRAECIPE FOR SATISFACTION OF JUDGMENT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt PA I.D #42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#05340998 ~ - -. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION AIS SERVICES, LLC Plaintiff vs. Civil Action No. 06-5512 CIVIL TERM LINDA L PORTER 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. Sworn to and subs ribed before me th' ~ ~ '~ day o ~ t N RY P WELTMAN, WEINBERG &REIS CO., L.P.A. By: James C armbrodt PA I. D 2 4 WELT AN, EINBERG &REIS CO., L.P.A. 2718 oppe s Building 436 even Avenue Pi sburg PA 15219 ( 12) 43 -7955 #05340998 COMMONW~ALTFi OF PENNSYLVANIA Notarial Seat. i ubll,^ City pi P .' ~urgh~ deny County ~;• ssionExpr,~:: '~~1y15,201C I~etnbe~e^•`$ylva~ss`°:~auon of Notariae= C7 c=-~~ --i ~ t=' -, ; ~^ ~~ ~ ~.. -~ '~ ^.1 . ,~_ -~ ~-+`: ' '- t > -~G