The URL can be used to link to this page

Home My WebLink About02-4122IN 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. O~--.../¢/~, ,~ 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. 3. Defendant is an adult individual residing at 294 Bradley Lane, Shippensburg, CUMBERLAND County, Pennsylvania 17257. 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. I-LEIA~ T. MOL(~ZAN,~SQUIRE 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 I~B ACCT 4168100021707607 CYCLE 27 AGENT 0895 ( 12 MONTH HISTORY :::::::::::::::::::::::::::::::::::::::::::::::::::::::::::: 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 SCREEN SELECTION ( 1 2 3 4 ) (01) 06/27/02 (02) 0 .00 68.00 0 .00 0 .00 0 00 0 00 00 00 .00 .00 .00 1.00 3,392.36 => FRANCK EDWARD E 05/27/02 (03) 04/29/02 0 0 .00 .00 136.00 136.00 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 3,392.36 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 VEtLEFICATION The undersigned does hereby verify subject ro the penalties of [8 PA.C S. 94904 relating to unswom falsifications to authorities, that he Jeff Swarm, Designated Agent of First Select Incorporated, plaintiffherein, that he is duly authorized to make this Verification, and that the facts set forth in the foregoing Complaint are true ~nd correct to the best of Fss/her '.~now!edge, information and belief SHERIFF'S RETURN CASE NO: 2002-04122 p COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND - NOT FOUND FIRST SELECT INC VS FR3tNCK EDWARD E JR R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, DEFENDANT FRANCK EDWARD E JR unable to locate H~im COMPLAINT & NOTICE in his bailiwick. but was He therefore returns the the within named DEFENDANT NOT FOUND FP-ANCK EDWARD E JR as to ADDRESS IS LOCATED IN FRANKLIN COUNTy. Sheriff,s Costs: Docketing 18.00 Service .00 Not Found 5.00 Surcharge 10.00 .00 33.00 R.--~Thomas K~ne l~--z2__ Sheriff of Cumberland County WELTMA/~ WEINBERG REIS 09/27/2002 Sworn and ~ubscribed to before me this ~____~ day of 0~ ~ A.D. Prdthonot~ry , /- ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION FIRST SELECT, INC. Plaintiff VS. EDWARD E. FRANCK, JR. PRAECIPE TO SETTLE, DISCONTINUE AND END WITHOUT PREJUDICE TO REFILE Defendant 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. EDWARD E. FRANCK, JR. Defendant Civil Action No. ..PRAECIPE TO SETTLE, DISCONTINUI- AND END WITHOUT PREJUDICE TO REFILF TO THE PROTHONOTARY OF CUMBERLAND COUNTY: SIR: Settle, Discontinue and End the above-captioned matter upon the records of the Court without prejudice to reflle and mark the costs paid. Not. ariai Sea Wendy L, Gault, Notary Public SWORN TO AND SUBSCRIBED before me this ~ day of WELTMAN, WEINBERG & REIS CO., L.P.A. Attor~'ey f~ ~laintiff / 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#02610561