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Home My WebLink About02-3398 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION FIRST SELECT, INC. Plaintiff No, Q.1- .3.19;;> CI'uiL'---r~ vs, COMPLAINT IN CIVIL ACTION STACEY L. WEAVER Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: WILLIAM T, MOLCZAN, ESQUIRE PA 1.0,#47437 Weltman, Weinberg & Reis Co" L.P.A. 2718 Koppers Bldg, 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#02577514 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION FIRST SELECT, INC, Plaintiff vs, Civil Action No. STACEY L. WEAVER Defendant COMPLAINT IN CIVIL ACTION 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 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 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 Lancaster Court Administrator's Office 50 North Duke Street Lancaster, PA 17602 (717) 299-8041 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION FIRST SELECT, INC. Plaintiff vs. Civil Action No. C>,.1- .3J9 P C,~~ L I ~ STACEY L. WEAVER Defendant COMPLAINT AND NOW COMES, Plaintiff, First Select, Inc" by and through its counsel, WELTMAN, WEINBERG & REIS, CO" LPA., and hereby files this Complaint against Defendant, Stacey L. Weaver, and, in support thereof, Plaintiff avers as follows: 1. The Plaintiff, First Select, Inc" is a corporation with its principal place of business located at 4460 Rosewood Drive, Pleasanton, CA 94588, 2. Plaintiff is the owner of this account, which is the subject matter of this action. 3. Defendant is an adult individual residing at 2003 Columbia Avenue, Camp Hill, Cumberland County, Pennsylvania 17011, 4, Defendant requested the account and made use of said account and has currently a balance due and owing to Plaintiff, as of June 11, 2002, in the amount of $2,902.50. A true and correct copy of Plaintiff's Statement of Account is attached hereto, marked as Exhibit "1" and made a part hereof, 5. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed and/or refused to pay the balance, WHEREFORE, Plaintiff demands Judgment in its favor and against Defendant, Stacey L, Weaver individually, in the amount of $2,902,50 with finance charges thereon at the rate of 6% per annum from June 11, 2002, 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. M~7/. WILLIAM T, MOLCZAN, UIRE PA 1.0,#47437 Weltman, Weinberg & Reis Co., L.P.A. 2718 Koppers Bldg, 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#: 02577514 JUL, 5,2002 11: 46AM PROV1DIAN ::N CIS ,~O, 9500 p, 30 TCSI 001 CODE IHB ACCT 4168100022528077 CYCLE 11 AGENl' 03 72 ( 12 MONTH HISTORY I ::::::::::::::::::::::::::::::::::::::::::::::::::::::::::: SCREEN SELECTION 1 123 4 I ~> WEAVER STACEY L CURRENT (01) 06/11102 102) 05/13/02 (03) 04/11102 (04) 03111102 PAYMENT 0 I 0 I 0 I 0 I 0 .00 I .00 I .00 I ,00 I .00 MIN PYMT 5B.00 , 5B,OO I 5B.00 I 116.00 I 116,00 PURCHASE 0 I 0 I 0 I 0 I 0 .00 I .00 I .00 I .00 I .00 CASH AnV 0 I 0 I 0 I 0 I 1 .00 I ,00 I .00 I .00 I 2,902,50 CREDITS 0 I 0 I 0 I 0 , 0 .00 I .00 I ,00 I ,00 I .00 HI SC CHG 0 I 0 I 0 I 0 I 0 .00 I .00 I ,00 I ,00 I ,00 INS FEE .00 I ,00 I ,00 I ,00 I .00 IJ<TE CHG .00 I .00 I .00 I ,00 I .00 OVI\L FEE .00 I ,00 I .00 I ,00 I .00 PURC Flc .00 I ,00 I .00 I ,00 I .00 CASH FIC ,00 I ,00 I ,00 I ,00 I .00 LIMIT 1,00 I 1. 00 I 1. 00 I 1. 00 I 1. 00 BALllNCE 2,902.50 I 2,902.50 , 2,902,50 , 2,902.50 I 2,902.50 . . . . . . . . . . . . . . . . . . . . ~ . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I . . . . . . . . . . . . . . . . . . . . ................ ............................................................... ',{HiSlf VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA.C.S. ~4904 relating to unsworn falsifications to authorities, that he/she is Jeff Swan, Designated Agent of First Select Inc., plaintiff herein, that he 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 (Signature) / -__'^"'h_'~..._.._., '. SHERIFF'S RETURN - REGULAR CASE NO: 2002-03398 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FIRST SELECT INC VS WEAVER STACEY L CPL. TIMOTHY REITZ , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon WEAVER STACEY L the DEFENDANT , at 1428:00 HOURS, on the 22nd day of July at 2003 COLUMBIA AVENUE , 2002 CAMP HILL, PA 17011 by handing to STACEY L WEAVER 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: Docketing Service Affidavit Surcharge 18.00 10,35 .00 10.00 .00 38,35 So Answers: .r'~~ R. Thomas Kline 07/24/2002 WELTMAN WEINBERG REIS Sworn and Subscribed to before By: me this ~ ffi,4( day of ()~ ~1J1) J-..., _ A.D, ,,_ ~_II. , .n:;;-t;' P thonotary , Yf7 , 7Q ~ ~ I[( ()l ~ 0 (-:) fL 1'0 h B s.. c..... "Ur" c: " " ~ ~ ~~J r- ......... 25:' -.J 1(,) jU C/) .,; Cl ~4:, ~ ~c:; c. Ll --,.:,,- -n '" p:J ~8 ::t:i~ ~~~'f f~ D ~ >~ r:- u " -..., ~ :::::> ?s ;; -< '" ~ ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION FIRST SELECT, INC. Plaintiff No.02-3398 VS. STIPULATION OF THE PARTIES FOR PAYMENT AND FOR THE ENTRY OF JUDGMENT BY CONSENT STACEY L. WEAVER Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T, Molczan, Esquire PA 1.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P,A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#02577514 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 FIRST SELECT, INC. Plaintiff vs. Civil Action No. 02-3398 STACEY L. WEAVER Defendant STIPULATION OF THE PARTIES FOR PAYMENT AND FOR THE ENTRY OF JUDGMENT BY CONSENT AND NOW, cOfT!es the Plaintiff, by counsel, and the Defendant to Stipulate to Settlement and the Entry of Judgment by Consent, as follows: 1. Defendant admits indebtedness to Plaintiff in the amount of $2,902.50 with continuing interest thereon at a rate of 6% per annum plus costs from June 11, 2002. 2. To secure the repayment of said indebtedness, Defendant agrees that Judgment by Consent will be entered in favor of the Plaintiff and against lhe Defendant, Stacey L. Weaver, in the amount of $2,90250 plus continuing interest thereon at the rate of 6% per annum from June 11, 2002 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) $100.00 due by July 26,2002; (b) no less than $100.00 per month due on the 25th day of each consecutive month thereafter until the Judgment amount plus accrued interest and costs are paid in full. 4. All payments are to be made payable to the order of "First Select, Inc," 5. The first payment due under this agreement, on July 26, 2002, is to be received at the offices of First Select, Inc. and all subsequent payment 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 fails 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 10 be legally bound, the parties set their hands and seals this ~day Of~-- - 20 CO- THIS LAW FIRM IS ATTEMPTING TO COLLECT THIS DEBT FOR ITS CLIENT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. WELTMAN, WEINBERG & REIS CO., L.P.A. 0'A WWR#02577514 Stacey L. Weaver By: J.b~\i.l.LlleQt~A Defen ant '- G tl (.) ~ 'i 2- b 0. fJ ........ ~ -z) 8- <::::> 0 lU N -" -() ~ "U~ en ~~:n 3 rTJ Q? ~gj -u ~ ~ 635: N .".,I-'T"! f2I c...:. ;:~(:J - <Y ~6 ~'~j~) :< .. J:J ;;:L;::::.b P: ~c ::1t ~ :;;;8 ~-;;:;;c; w i~5f'T1 ~ -..-! i'J ,:::> >- :0 ..... -< ,.. - IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION FIRST SELECT, INC., Plaintiff No. 02-3398 vs. PRAECIPE FOR SATISFACTION OF JUDGMENT STACEY L WEAVER, Defendant 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#02577514 ..... .. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION FIRST SELECT, INC., Plaintiff vs, Civil Action No. 02-3398 STACEY L WEAVER, 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. WELTMAN, WEINBERG & REIS CO., L.P.A. Sworn to and SUrC~rd before me this daYOfM~ .,0 . J . ,'. . ,,~ / . NOTA~'PUBLlC W\NR #02577514 ':~! ~~~,Yi, "~. U) r::.: \. - ~,- (") (~ .....' (.::~ = '-" ::;;; "" :;0 N ~ ~"' :::~1 _I.. -t1 -". ~. .-"~ :;"i. .-, 'irlr~, "0'.--, ~ ;'ll...~ (~\ ~;) -r:: -'l) < ,; ('"j /".....l ~3' c ~:} ,,1 0::: d. -