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Home My WebLink About02-3561IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PROVIDIAN NATIONAL BANK Plaintiff VS. BETTY J. CALLICH Defendant COMPLAINT IN CIVIL ACTION FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: WILLIAM T. MOLCZAN, ESQUIRE PA I.D.f147437 Weltman, Weinberg & Reis Co., L.P.A. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#02583711 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PROVIDIAN NATIONAL BANK Plaintiff VS. BE'FrY J. CALLICH Defendant Civil Action No. O.2- 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 PROVIDIAN NATIONAL BANK Plaintiff VS. BE'I-FY J. CALLICH Civil Action No. Defendant COMPLAINT AND NOW COMES, Plaintiff, Providian National Bank, by and through its counsel, WELTMAN, WEINBERG & REIS, CO., LPA., and hereby files this Complaint against Defendant, Betty J. Callich, and, in support thereof, Plaintiff avers as follows: 1. The Plaintiff, Providian National Bank, is a corporation with its principal place of business located at 295 Main Street, New Hampshire, 03276. 2. Plaintiff is the owner of this account, which is the subject matter of this action. 3. Defendant is an adult individual residing at 612 Mountain Road, Newville, Cumberland County, Pennsylvania 17241. 4. Defendant applied for and received a credit card issued by Plaintiff bearing the account number 4185-5100-0267-5945. 5. By use of the account, the Defendant became bound by the terms in the Account Agreement. 6. Defendant made use of said account and has currently a balance due and owing to Plaintiff, as of May 30, 2002, in the amount of $3,043.86, as shown by Plaintiff's Statement of Account attached hereto, made a part hereof and marked as Exhibit "1". 7. Defendant is in default of the terms of the Account Agreement having not made payment to Plaintiff as promised, thereby rendering the entire balance immediately due and payable. 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, Betty J. Callich individually, in the amount of $3,043.86 with continuing finance charges thereon at the legal rate of 6% per annum from May 30, 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. WILLIAM T. MOLCZAN, ESI~fOIRE PA I.D.#47437 Weltman, Weinberg & Reis Co., L.P.A. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#:O2583711 ' ' ********** RON MCGHEE ********** TCSI 001 CODE IHB ACCT 4185511002675945 CYCLE 28 AGENT 9626 ( 12 MONTH HISTORY :::::::::::::::::::::::::::::::::::::::::::::::::::::::::::: SCREEN SELECTION ( 1 2 1 4 ) => CALLICH BETTY CURRENT PAYMENT 0 101201 .00 MIN PYMT 91.00 PURCHASE 0 120301 .00 CASH ADV 0 051701 .00 CREDITS 0 061301 .00 MISC CHG 0 .00 INS FEE .00 LATE CHG .00 OVRL FEE .00 PURC F/C 268.51 CASH F/C 21.19 LIMIT 2,600.00 (01) 05/30/02 0 .00 724.00 0 .00 0 .00 0 .00 0 .00 .00 .00 .00 2.32 .18 (02) 05/28/02 0 .00 633.00 0 .00 0 .00 0 .00 0 .00 .00 .00 .00 36.87 2.78 (03) 04/26/02 (04) 0 .00 542.00 1 29.00 0 .00 0 .00 0 .00 .00 29.00 29.00 34.08 2.57 03/27/02 0 .00 453.00 1 29.00 0 .00 0 .00 0 .00 .00 29.00 29.00 33.61 2.53 2,600.00 2,600.00 2,600.00 2,600.00 BALANCE 3,043.86 3,043.86 3,041.36 3,001.71 2,907 06 : : : : :::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::: ~-~-._R~IC__ATIO~N 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 JeffSwan, Designated Agent of Providian National Bank., Plalntiffherein, that he is duly authorized to make this Verification, and that the facts set forth in the foregoing Compl0fint are true and c~orrect to the best of his/her knowledge, information and beliefi SHERIFF,S CASE NO: 2002-03561 p COMMONWEALTH OF PENNSYLVANIA: COUNTy OF CUMBERLAND PROVIDIAN NATIONAL BANK VS CALLICH BETTY J RETURN - REGULAR STEVE WHISTLER Sheriff or Deputy Sheriff of Cumberland CountY, Pennsylvania, who being duly SWorn according to law, says, the within COMPLAINT & NOTICE was served upon CALLICH BETTY j the DEFENDANT , at 1845:00 HOURS, on the l__gt~ day of ~ , 2002 at 612 MOUNTAIN ROAD NEWVILLE, PA 17241 BETTY j CALLICH by handing to a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing ~er attention to the contents thereof. Sheriff,s Costs: Docketing 18 00 Service Affidavit 8.28 .00 Surcharge 10.00 __ ._00 36.28 Sworn and Subscribed to before me this ~ day of ~othonotary ' So Answers: R. Thom---sa Kline 08/20/2002 WELTMAN WEINBERG REIS Deputy Sheriff-- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PROVIDIAN NATIONAL BANK Plaintiff VS. BETTY J. CALLICH Defendant No. 02-3561 PRAECIPE TO SETTLE, DISCONTINUE AND END WITHOUT PREJUDICE TO REFILE 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#02583711 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PROVlDIAN NATIONAL BANK Plaintiff VS. BETTY J. CALLICH Defendant Civil Action No. 02-3561 PRAECIPE TO SETTLE, DISCONTINUE AND END WITHOUT PREJUDICE TO REFILE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: SIR: Settle, Discontinue and End the above-captioned matter upon the records of the Court without prejudice to refile and mark the costs paid. SWORN TO AND SUBSCRIBED before me this ~.~) day o~ .~24~02-.~ I WELTMAN, WEINBERG & REIS CO., L.P.A. Attorney for Plaintiff 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#02583711