HomeMy WebLinkAbout02-3626IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVIStON
FIRST SELECT, INC.
Plaintiff
VS.
EDWARD JOSEPH COOK
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#02605194
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
FIRST SELECT, INC.
Plaintiff
VS.
EDWARD JOSEPH COOK
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
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.
EDWARD JOSEPH COOK
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, Edward
Joseph Cook, 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 200 Acre Drive, CarLisle, Cumberland
County, Pennsylvania 17013.
4. Defendant requested the account and made use of said account and has currently
a balance due and owing to Plaintiff, as of July 8, 2002, in the amount of $1,491.36. 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, Edward
Joseph Cook individually, in the amount of $1,491.36 with finance charges thereon at the rate of
6% per annum from July 8, 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., LP.A.
T. MOL. CZ~, 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#: 02605194
FRENICKA SUBLETT EXT 2089 +*+*+*+ 07/15/02
TCSI 001 CODE IHB ACCT 4168100022849804 CYCLE 08 AGENT 0679
( 12 MONTH HISTORY ) :::::::::: ............................. ::::::::::::::::::::
1 4 ) ............................. => COOK EDWARD JOS
SCREEN SELECTION ( 1
CURRENT
pAYMENT 1
071102 20.00
MIN pYMT 30.00
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) 07/08/02 (02)
0
.00
30.00
0
.00
0
.00
0
.00
0
.00
.00
.00
.00
.00
.00
1.00
06/10/02
0
.00
30.00
0
.00
0
.00
0
.00
0
.00
.00
.00
.00
.00
.00
1.00
03) 05/08/02
0
.00
60.00
0
.00
0
.00
0
.00
0
.00
.00
.00
.00
.00
.00
1.00
04) 04/08/02
0
.00
60.00
0
.00
1
1,511.36
0
.00
0
.00
,00
.00
.00
.00
.00
1.00
BALANCE 1,491.36 1,511.36 1,511.36 1,511.36 1,511.36
:::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::
SHERIFF'S
CASE NO: 2002-03626 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
FIRST SELECT INC
VS
COOK EDWARD JOSEPH
RETURN - 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
COOK EDWARD JOSEPH the
DEFENDANT , at 2200:00 HOURS, on the 1st day of August
at 200 ACRE DRIVE
2002
CARLISLE, PA 17013 by handing to
LINDA COOK, MOTHER
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 3.45
Affidavit .00
Surcharge 10.00
.00
31.45
Sworn and Subscribed to before
me this ~2~ day of
So Answers:
R. Thomas Kline
Deput'y Sheri[~
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
FIRST SELECT, INC.
Plaintiff
VS.
EDWARD JOSEPH COOK
Defendant
No. 02-3626
PRAECIPE FOR DEFAULT JUDGMENT
FILED ON BEHALF OF
Plaintiff
COUNSEL OF RECORD OF
THIS PARTY:
William T. Molczan, Esquire
PA I.D. ff47437
WELTMAN, WEINBERG & REIS CO., L.P.A.
2718 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR#02605194
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.
EDWARD JOSEPH COOK
Defendant
Civil Action No. 02-3626
PRAECIPE FOR DEFAULT JUDGMENT
TO THE PROTHONOTARY:
Kindly enter Judgment against the Defendant, Edward Joseph Cook, above named, in the default
of an Answer, in the amount of $1,507.30 computed as follows:
Amount claimed in Complaint $1,491.36
Interest from 7/8/02 to 9/11/02
at the contract interest rate of 6% per annum $15.94
TOTAL $1,507.30
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.
2718 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR#02605194
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: 20O Acre Drive, Carlisle, PA 17013
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
FIRST SELECT, INC.
Plaintiff
VS,
Civil Action No. 02-3626
EDWARD JOSEPH COOK
Defendant
IMPORTANT NOTICE
TO: Edward Joseph Cook
200 Acre Drive
Carlisle, PA 17013
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., L.P.A.
2718 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR #02605194
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.
pW~'l i,~ ¢~ 7~14~1¢za ~ "E ~¢
WELTMAN, WEINBERG & REIS CO., LP.A.
2718 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR#02605194