HomeMy WebLinkAbout02-3664IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
FIRST SELECT, INC.
Plaintiff
VS.
EDWARD E. FRANCK, JR.
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#02610561
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
FIRST SELECT, INC.
Plaintiff
VS.
EDWARD E. FRANCK, JR.
Defendant
Civil Action No. (_..)"~. --~,~,6/'
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 E. FRANCK, JR.
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 E.
Franck, Jr., 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.
17257.
Defendant is an adult individual residing at 294 Bradley Lane, Shippensburg, PA
4. Defendant requested the account and made use of said account and has currently
a balance due and owing to Plaintiff, as of June 27, 2002, in the amount of $3,392.36. 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
E. Franck, Jr. individually, in the amount of $3,392.36 with finance charges thereon at the rate of
6% per annum from June 27, 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.
WILLt,~M T. MOLC~I, 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#: 02610561
FRENICKA SUBLETT EXT 2089 +*+*+*+ 07/18/02
TCSI 001 CODE IHB ACCT 4168100021707607 CYCLE 27 AGENT 0895
( 12 MONTH HISTORY ::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::
SCREEN SELECTION ( 1 2 3 4 ) => FRANCK EDWARD E
CURRENT
PAYMENT 0
.00
MIN pyMT 68.00
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 31.71
LIMIT 1.00
BALANCE 3,392.36
(01) 06/27/02
0
.00
68.00
0
.00
0
.00
0
.00
0
.00
.00
.00
.00
.00
.00
1.00
3,392.36
02) 05/27/02
0
.00
136.00
0
.00
0
.00
0
.00
0
.00
.00
.00
.00
.00
.00
1.00
3,392.36
(03) 04/29/02
0
.00
136.00
0
.00
0
.00
0
.00
0
.00
.00
.00
.00
.00
.00
1.00
3,392.36
(04) 03/27/02
0
.00
136.00
0
.00
0
.00
0
.00
0
.00
.00
.00
.00
.00
.00
1.00
3,392.36
vEP,_ffrlC ANON
The undersized does hereby verf~/subje~ to the per~aities of ',8 PA.C S. {4904. retatmg
to unswom falsifcatioas To authoff~ies, that he is .i'eg Swa~, Designated Agent of First Seiec~ Lac., piain~5
herein, that he is duly authorized to make tifs Verification, and that the facts set forth in the foregoing
Comp[aim are tr'ae ~md cor'rbct to the best ogNs ~hnow[edge, ir~orraattor~ a~nd be!ie£.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
FIRST SELECT, INC.
Plaintiff
VS.
EDWARD E. FRANCK, JR.
Defendant
No. 02-3664 Civil Term
PRAEClPE 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#02610561
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
FIRST SELECT, INC.
Plaintiff
VS.
Civil Action No. 02-3664 Civil Term
EDWARD E. FRANCK, JR.
Defendant
PRAECIPE TO SETTLE, DISCONTINUE
AND END WITHOUT PREJUDICE TO REI-~LE
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.
WELTMAN, WEINBERG & REIS CO., L.P.A.
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR#02610561
SWORN TO AND SUBSCRIBED
before me this _~ day
· ~IO~I"ARY F~ '