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Home My WebLink About02-3560IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION FIRST SELECT, INC. Plaintiff VS, JASON A. BENNETT 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, Weinberg & Reis Co., L.P.A. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 wwr#02583688 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION FIRST SELECT, INC. Plaintiff VS. JASON A. BENNETT 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 Jf 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 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION FIRST SELECT, INC. Plaintiff VS. JASON A. BENNETT 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, Jason A. Bennett, 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 196 Willow Mill Park Road, Mechanicsburg, Cumberland County, Pennsylvania 17050. 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 $8,375.96. 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, Jason A. Bennett individually, in the amount of $8,375.96 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. PA I.D.~7437 Weltman, Weinberg & Reis Co., L.P.A. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#: 02583688 ********** RON MCGHEE ********** PAYMENT TCSI 001 CODE IHB ACCT 4168100022541880 ( 12 MONTH HISTORY ) CYCLE 11 AGENT 0372 ::::::::::::::::::::::::::::::::::::::::::::::::::::::::::: SCREEN SELECTION ( 1 2 1 4 ) => BENNETT JASON A (01) 06/11/02 (02) 05/13/02 (03) 04/11/02 MIN PYMT PURCHASE CASH ADV CREDITS MISC CHG CURRENT 0 .00 168.00 0 .00 0 .00 0 .00 0 .00 .00 .00 .00 .00 .00 1.00 INS FEE LATE CHG OVRL FEE PURC F/C CASH F/C LIMIT 0 .00 168.00 0 .00 0 .00 0 .00 0 .00 .00 .00 .00 .00 .00 0 0 .00 .00 335.00 335.00 0 0 .00 .00 0 0 .00 .00 0 0 .00 .00 0 0 .00 .00 .00 .00 .00 .00 .00 .00 .00 .00 .00 .00 1.00 1.00 1.00 1.00 BALANCE 8,375.96 8,375.96 8,375 96 8,375 96 8,375 96 : : : ::: : : : : : :: : : : :::::::::::::::::::::::::::::::::::::::::::::::::::::::::::: (04) 03/11/02 0 .00 335.00 0 .00 1 8,375.96 0 .00 0 .00 .00 .00 .00 .00 .00 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., plaintiffherein, that he 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 belie£ (~gnamre) SHERIFF CASE NO: 2002-03560 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND FIRST SELECT INC VS BENNETT JASON A S RETURN - REGULAR ROBERT BITNER , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon BENNETT JASON A the DEFENDANT at 0017:27 HOURS, at 196 WILLOW MILL PARK ROAD MECHANICSBURG, PA 17050 KACY BENNETT (WIFE) a true and attested copy of on the 7th day of August , 2002 by handing to 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 2~w~ day of ~j ~,~e a~ A.D. ~rothonotary So Answers: R. Thomas Kline 08/08/2002 WELTMAN, WEINBERG, REIS · ~ Deputy Sheriff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION FIRST SELECT, INC. Plaintiff VS, JASON A. BENNETT Defendant No. 02-3560 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#02583688 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, JASON A. BENNETT Defendant Civil Action No. 02-3560 Civil Term PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter Judgment against the Defendant, Jason A. Bennett, above named, in the default of an Answer, in the amount of $8,538.43 computed as follows: Amount claimed in Complaint interest from 6/11/02 to 10/7/02 at the contract interest rate of 6% per annum TOTAL $8,375.96 $162.47 $8,538.43 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., L.P.A. William T. Molczan, Esquir~ PA I.D. #47437 WELTMAN, WEINBERG-& REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#02583688 Plaintiff's address is: c/o Weltman, Weinberg & Reis Co., LP.A., 2601 Koppers Building, 436 7th Avenue, Pittsburgh, PA 15219 And that the last known address of the Defendant is: 196 Willow Mill Park Road, Mechanicsburg, PA 17050 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION FIRST SELECT, INC. Plaintiff VS. JASON A. BENNETT Defendant Civil Action No. 02-3560 CIVIL IMPORTANT NOTICE TO: Jason A. Bennett 196 Willow Mill Park Road Mechanicsburg, PA 17050 Date of Notice: :y,,~.~ ~'~'/ 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., L.P.A. Willia~ T.'l~lczan PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR #O2583688 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., LP.A. William T. Molczan, bsquire ~ PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#02583688 IN THE COURT OF FIRST SELECT, INC. Plaintiff VS, JASON A BENNETT Defendant ~MMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION No. 02-3560 CIVIL TERM PRAECIPE FOR SATISFACTION OF 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#02583688 IN THE COURT OF ~;OMMON PLEAS OF CUMBERLANI3 COUNTY, PENNSYLVANIA CIVIL DIVISION FIRST SELECT, INC. Plaintiff VS. JASON A BENNETT Defendant No. 02-3560 CIVIL TERM PRAECIPE FOR SATISFACTION OF JUDGMENT FILED ON BEHALF OF Plaintiff COUNSEL O'F 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#02583688