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Home My WebLink About02-3479GOLDBERG, KATZMAN & SHIPMAN, P.C. Paul $. Esposito - I.D. #25454 Attorneys for Plaintiff 320 Market Street, Slxawben3~ Square Post Office Box 1268 Harrisburg, PA 17108-1268 (717) 234-4161 SUE ELLEN HASSINGEK, Plaintiff, V. KIRK R. HASSINGER, Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION- LAW NO. 02-3489 - CIVIL TERM IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) ) SS: COUNTY OF DAUPHIN ) Personally appeared before me, a Notary Public, in and for said Commonwealth and County, PAUL J. ESPOSITO, ESQUIRE, who being duly sworn according to law deposes and says that on July 26, 2002, he sent a copy of a Complaint in Divorce filed with the Cumberland County Court of Common Pleas, by certified mall, return receipt requested, restricted delivery, to Kirk R. Hassinger, and the return receipt card signed by Kirk Hassinger and shown as being delivered July 27, 2002, is attached hereto and made a part hereof. PAUL J. gSP, C ITO, ESQUn Sworn to and subscribed before me this 1st day of August, 2002. ~ot~ Public My Commission Expires: _.. NOTARIAL MY COMMI$$1 G, DAUPHIN COUNIY g_} ON EXPIRES AN' 13, ~ Kirk R. lt~ssinier 238 l~est Simpson Street l~echanicsburg, PA 17055 I~TRIC'I'EO DELIVERY PS Form 3811, ~ 200~ ~ Imur~ MM E) C.O,D. ; Dome~lc Return Receipt IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION OSI FUNDING, L.L.C., ASSIGNEE OF FIRST USA BANK, N.A. Plaintiff VS. PATRICIA SMITH Defendant COMPLAINT IN CIVIL ACTION FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan, Esquire PA I.D. #47437 WELTMAN, WE1NBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#02546842 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION OSI FUNDING, L.L.C., ASSIGNEE OF FIRST USA BANK, N.A. Plaintiff VS. PATRICIA SMITH Defendant Civil Action No. Oi,~ -2q7 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 Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 COMPLAINT 1. Plaintiff is a corporation with offices at Building 2100, Suite 100, 2425 Commerce Avenue, Duluth, GA 30096. 2. Defendant is an adult individual residing at 19 Big Spring Terrace, Newville, Cumberland County, Pennsylvania 17241. 3. Defendant applied for and received a credit card issued by Plaintiff's assignor beating the account number 4417-1226-1897 4605 4. Defendant made use of said credit card and has currently a balance due and owing to Plaintiff, as of February 28, 2001, in the amount of $941.03. A true and correct copy of Plaintiff's Statement of Account is attached hereto, marked as Exhibit "1" and made a part hereof.. 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 provides that Plaintiff is entitled to the addition of finance charges at the rate of 6.0% per annum on the unpaid balance. 7. Plaintiff avers that interest calculated at the aforesaid rate from February 28, 200~ to June 20, 2002 amounts to $73.79. 8. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed and/or refused to pay the principal balance, finance charges or any part thereof to Plaintiff. WHEREFORE, Plaintiff demands Judgment in its favor and against Defendant, Patricia Smith individually, in the amount of $1,014.82 with continuing finance charges thereon at the rate of 6.0% per annum 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. PA I.D. ~47437/' -~ .... WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#:02546842 APRIL 11, 2002 OSI Funding, LLC LITIGATION NETWORK Post Office Box 2388 Doraville, Georgia 30362-2388 800-945-0007 PATRICIA SMITH 19 BIG SPRING TER NEWVILLE, PA 17241-9129 STATEMENT OF ACCOUNT Debtor's Name: OSI Funding LLC Acct Number: Original Creditor: Original Account Number: Write OffDate (Charge OffDate): Principle Balance: Balance Due: Interest Rate: PATRICIA SMITH 3950859572 FIRST USA BANK N.A. 4417122618974605 02/28/01 $941.03 $941.03 6.% WWW VER~ICATION 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 Helena Hobbs ~ --, , plaintiff herein, that (Title) (Company) t9 he/she is duly authorized to make this Verification, and that the facts set forth in the foregoing Complaint are tree and correct to the best of his/her knowledge, information and belief. (Signature) SHERIFF'S RETURN - REGULAR CASE NO: 2002-03479 P COMMONWEALTH OF PENNSYLVANIA: cOUNTY OF CUMBERLAND OSI FUNDING LLC VS SMITH PATRICIA VALERIE WEARY ' Cumberland County,Pennsylvania, says, the within COMPLAINT & NOTICE was served upon SMITH PATRICIA Sheriff or Deputy Sheriff of who being duly sworn according to law, the DEFENDANT , at 1310:00 HOURS, at 19 BIG SPRING TERRACE NEWVILLE, PA 17241 JEREMY MIXELL, NEPHEW on the 31st day of July , 2002 by handing to 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 18.00 Service 8.28 Affidavit .00 Surcharge 10.00 .00 36.28 Sworn and Subscribed to before me this 2~ day of ~r6thonotary / ' So Answers: R. Thomas Kline o8/ol/2OO2 WELTMAN WEINBERG REIS By: Deputy Sher~f IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION OSI FUNDING L.LC., ASSIGNEE OF FIRST USA BANK, N.A. Plaintiff No. 02-3479 VS. PATRICIA SMITH PP-.AECIPE FOR DEFAULT JUDGMENT Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan, Esquire PA I.D. #-47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#02546842 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 OSI FUNDING L.L.C., ASSIGNEE OF FIRST USA BANK, N.A. Plaintiff VS. PATRICIA SMITH Civil Action No. 02-3479 Defendant TO THEPROTHONOTARY: PRAECIPE FOR DEFAULT JUDGMENT Kindly enter Judgment against the Defendant, Patricia Smith, above named, in the default of an Answer, in the amount of $1,026.67 computed as follows: Amount claimed in Complaint Interest from 6/20/02 to 9/11/02 at the contract interest rate of 6% per annum TOTAL $1,014.82 $13.85 $1,028.67 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 & REIS CO., LP.A. m T. Molczan, Esquire/~' -- PA I.D. #47437 ~,' WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#02546842 Plaintiff's addressis:c/oWeltman, WeJnberg & Reis Co.,LP.A.,2601Koppers Building, 436 7th Avenue, Pittsburgh, PA 15219 Andthatthelastknown address ofthe Defendantis:19 Big Sprng Ter, Newville, PA 17241 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION OSI FUNDING, EEC., ASSIGNEE OF FIRST USA BANK, N.A. Plaintiff VS. PATRIClA SMITH Defendant TO: Patricia Smith 19 Big Spring Ter Newville, PA 17241 Civil Action No. 02-3479 ,IMPORTANT NOTICF Date of Notice: _ ~"¢' YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN THIS CASE. 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 NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE 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 WELTMAN, WEINBERG & REIS CO., LP.A. ilJiam T. Molczan PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., LP.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR #02546842 VF:R FICATION The undersigned does hereby verify subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities, that the parties against whom Judgment is to be entered according to the Praecipe attached are not members of the Armed Forces of the United States or any other military or non-military service covered by the Soldiers and Sailors Civil Relief Act of 1940. The undersigned further states that the information is true and correct to the best of the undersigned's knowledge and belief and upon information received from others. WELTMAN, WEINBERG & REIS CO., L.P.A. WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#02546842