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Home My WebLink About02-3559IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION FIRST SELECT, INC. Plaintiff VS. SUZANNE M. KEEHER Defendant No. COMPLAINT IN CIVIL ACTION 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 Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#02585875 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION FIRST SELECT, INC. Plaintiff VS. SUZANNE M. KEEHER Defendant Civil Action No. 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 PA Bar Association P.O. Box 186 Harrisburg, PA 17108 1-800-692~7375 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION FIRST SELECT, iNC. Plaintiff VS, SUZANNE M. KEEHER Defendant Civil Action No. 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, Suzanne M. Keeher, 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 633 Williams Grove Road, Mechanicsburg, Cumberland County, Pennsylvania 17055. 4. Defendant requested the account and made use of said account and has currently a balance due and owing to Plaintiff, as of June 17, 2002, in the amount of $1,663.37. 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, Suzanne M. Keeher individuafly, in the amount of $1,663.37 with finance charges thereon at the rate of 6% per annum from June 17, 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. WILLI~,M T. MOLCZAN, ES,,,,(;~dlRE PA I.D.#47437 Weltman, Weinberg & Reis Co., L.P.A. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#:02585875 ********** RON MCGHEE ********** TCSI 001 CODE IHB ACCT 4168100022467466 CYCLE 16 AGENT 0775 ( 12 MONTH HISTORY :::::::::::::::::::::::::::::::::::::::::::::::::::::::::::: 1 4 ) '' ' => KEENER SUZANNE SCREEN SELECTION ( 1 CURRENT pAyMENT 0 .00 MIN PYMT 33.00 PURCHASE 0 .00 CASH ADV 0 .00 CREDITS 0 .00 MISC CHG 0 .00 INS FEE .00 LATE CHG .00 OVRL FEE .00 PURC F/C .00 CASH F/C .00 LIMIT 1.00 01) 06/17/02 0 .00 33.00 0 .00 0 .00 0 .00 0 .00 .00 .00 .00 .00 .00 1.00 02) 05/16/02 0 .00 33 · 00 0 .00 0 .00 0 .00 0 .00 .00 .00 .00 .00 .00 1.00 03) 04/16/02 0 .00 67.00 0 .00 0 .00 0 .00 0 .00 .00 .00 .00 .00 .00 1.00 04) 03/18/02 0 .00 67.00 0 .00 1 1,663.37 0 .00 0 .00 .00 .00 .00 .00 .00 1.00 BALANCE 1,663.37 1,663.37 1,663.37 1,663.37 1,663.37 ::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::: VERIFICATIO_-N The undersigned does hereby verify subject to the penalties of 1 $ 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 tiffs 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. SHERIFF'S RETURN - CASE NO: 2002-03559 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FIRST SELECT INC VS KEEHER SUZANNE M REGULAR BRIAN BARRICK Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon KEEHER SUZANNE M the DEFENDANT , at 1616:00 HOURS, at 633 WILLIAMS GROVE ROAD MECHANICSBURG, PA 17055 on the 31st day of July , 2002 by handing to KIMBERLY HOFFM_AIq, DAUGHTER 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 18.00 Service 6.21 Affidavit .00 Surcharge 10.00 .00 34.21 Sworn and Subscribed to before me this ~ day of ~ ~ ~b A.D. P~o~hono~ary ' ~ So Answers: R. Thomas Kline 08/05/2002 ~ WELTMAN WEINBER~ REIS Deputy Sheriff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION FIRST SELECT, INC. Plaintiff VS. SUZANNE M. KEEHER Defendant No. 02-3559 Civil Term PRAECIPE FOR DEFAULT JUDGMENT 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#02585875 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. SUZANNE M. KEEHER Defendant Civil Action No. 02-3559 Civil Term PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter Judgment against the Defendant, Suzanne M. Keeher, above named, in the default of an Answer, in the amount of $1,000.01 computed as follows: Amount claimed in Complaint Interest from 6/17/02 to 10/29/02 at the contract interest rate of 6% per annum Less payment received TOTAL $1,663.37 $36.64 -(700.00) $1,000.01 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. PA ;~'~ ¢~7M4~3~zan' Esqye WELTMAN, WEINBERG & REIS CO., LP.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#02585875 Plaintiff's address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2601 Koppers Building, 436 7th Avenue, Pittsburgh, PA 15219 And that the last known address of the Defendant is: 633 Williams Grove Road, Mechanicsburg, PA 17055 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION FIRST SELECT, INC. Plaintiff VS, SUZANNE M. KEENER Defendant TO: Suzanne M. Keener 633 Williams Grove Road Mechanicsburg, PA 17055 Civil Action No. 02-3559 IMPORTANT NOTICE Date of Notice: ~¢' ~-~ 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 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,7/CilNBE~RG~,.REIS CO., LP.A. William 1'. Molczan ' PA I.D. ¢47437 WELTMAN, WEINBERG ~REIS CO. LJ~.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR #02585875 VERIFICATION 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. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#02585875