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Home My WebLink About02-3669IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION FIRST SELECT, INC. Plaintiff VS, PAUL GUARINO 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#02605215 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION FIRST SELECT, INC. Plaintiff VS. PAUL GUARINO 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 ctaims 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, PAUL GUARINO 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, Paul Guarino, 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 456 Allenview Drive, 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 July 8, 2002, in the amount of $5,674.97. 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, Paul Guarino individually, in the amount of $5,674.97 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., L.P.A. W- . MO{.CZA~,' ESQUIRE PA I.D.#47437 ~' Weltman, Weinber¢ & Reis Co., L.P.A. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#: 02605215 FRENICKA SUBLETT EXT 2089 +*+*+*+ 07/15/02 TCSI 001 CODE IHB ACCT 4168100022854689 CYCLE 08 AGENT 0679 ( 12 MONTH HISTORY :::::::::::::::::::::::::::::::::::::::::::::::::::::::::::: CURRENT PAYMENT 0 .00 MIN PYMT 113.00 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 BALANCE 5,674.97 SCREEN SELECTION ( 1 2 1 4 ) (01) 07/08/02 (02) 06/10/02 0 .00 113.00 0 .00 0 .00 0 .00 0 .00 .00 .00 .00 .00 .00 1.00 5,674.97 0 .00 113.00 0 .00 0 .00 0 .00 0 .00 .00 .00 .00 .00 .00 1.00 5,674.97 (03) 5,674.97 => GUARINO PAUL 05/08/02 (04) 04/08/02 0 0 .00 .00 227.00 227.00 0 0 .00 .00 0 1 .00 5,674.97 0 0 .00 .00 0 0 .00 .00 .00 .00 .00 .00 .00 .00 .00 .00 .00 .00 1.00 1.00 5,674.97 VEP~IC ATION. The undersigned does hereby verify subject to the penalties of 18 PA.C.S. ~4904 relating t6 unswom falsifications to authorities, that he is left Swan, Designated Agent of Providi~ National Bank, plaintiff herein, that he is duly authorized to make this Verification, and that the facts set forth in the foregoing Complaint are true and correct to the best of his knowledge, L,-zformation and belief. (Signature) SHERIFF'S RETURN CASE NO: 2002-03669 P COMMONWEALTH OF PENNSYLVANIA: cOUNTY OF CUMBERLAND FIRST SELECT INC VS GUARINO PAUL JASON VIORAL Cumberland County,Pennsylvania, says, the within COMPLAINT & NOTICE GUARINO PAUL - REGULAR Sheriff or Deputy Sheriff of who being duly sworn according to law, was served upon the DEFENDANT , at 1813:00 HOURS, on the 14th day of August at 456 ALLENVIEW DRIVE , 2002 MECHANICSBURG, PA 17055 PAUL GUARINO by handing to a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 8.28 Affidavit .00 Surcharge 10.00 .00 36.28 Sworn and Subscribed to before me this ~1~ day of ~. ~02~ A.D. ~r~thonotary So Answers: R. Thomas Kline 08/15/2002 WELTMAN WEINBERG REIS By: ~f IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION FIRST SELECT, INC. Plaintiff VS. PAUL GUARINO Defendant No. 02-3669 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#02605215 IN THE COURT Of COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION FIRST SELECT, INC. Plaintiff VS, Civil Action No. 02-3669 PAUL GUARINO Defendant PRAECIPE TO SE'I-rLE, 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. WELTMAN, WEINBERG & REIS CO., L.P.A. ;;t~);nl~oY~;e rs; uild i rfg 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#02605215 SWORN TO AND SUBSCRIBED before me this ~'~ day