Filing a lawsuit in Allentown Pennsylvania requires a specific document and procedure to be 
followed. You cannot just pull a Michael Scott (protagonist in ‘The Office’) and walk out of your office and “Declare Lawsuit”.
Every debt-buyer lawsuit in Lehigh County Pennsylvania starts with a written document called “The Complaint”.
So what is the complaint? When I was an EMT, I had a partner who used to ask his patient “What is your primary complaint?” When the man with a piece of a picket fence stuck in his shoulder replied “My wife” I knew we needed a better question… I also knew that the man wasn’t going to die that day unless we really screwed up.
In the practice of law, a complaint is a document filed in court claiming that another party has wronged them and they should be allowed to sue and recover monetary damages for that wrong. As mentioned earlier, there are specific procedures that must be filed in filing a complaint, but debt buyers file these many times a month, so it is unlikely that you will catch a debt buyer making a procedural error.
The complaint must be written in numbered paragraphs and requires a proper caption. Each paragraph must contain one specific allegation (allegations are called averment in legalese). Sometimes debt buyers will make a mistake here, but the onus is on the answering party to answer the allegation anyway.
The caption of the complaint will say what court it is in. Most captions will say on line one “In The Lehigh County Court of Common Pleas” and then on line two “Lehigh County, Pennsylvania”. Normally this in all CAPS. The caption of the complaint also names the Plaintiff and the Defendant and has a place for a case number. The case number is not normally typed because you don’t know what case number will be assigned when you walk in the courthouse door.
The first paragraph will normally indicate who the defendant is and that they reside in the county the lawsuit is being filed in. If you live in Lehigh County and are sued, you must handle the matter in Lehigh County’s courts. If you are sued in Lehigh County and live elsewhere, you can file an answer that says that you are disputing that the Lehigh County court has jurisdiction over you and that the case must be dismissed or transferred to the county that you live in. There are specific terms of art that need to be plead, otherwise the court will consider your statement that they lack jurisdiction an answer and then you are trapped in a court outside of where you 
live! If you are sued in Lehigh County and then move to Boston, Massachusetts or even Timbuktu you are stuck, you still have to deal with the Lehigh County courts. Generally speaking, debt buyers already know where you live because presumably they have been trying to collect from you for a while prior to filing a lawsuit.
The second paragraph normally will name the Plaintiff and the location of their business. If a Plaintiff gets this wrong, they should be given ten lashes and sent out of the courthouse. They usually do not get this wrong, although one thing that they sometimes get an objection on is when they fail to put their address in that paragraph. The rule says that the Plaintiff has to identify its business address somewhere, so if its not in the Plaintiff identification paragraph, then check to see if it elsewhere. In the complaint I’m currently looking at, its in the caption of the case.
The following paragraphs will indicate the original creditor, the debt buyer and say that “the loan was not conferred gratuitously”. Of course not, it would be called a gift, not a loan.
There will also be a paragraph indicating the amount of money the Plaintiff thinks is owed.
Finally, at the end there will be a WHEREFORE paragraph demanding relief, usually in the form of a money judgment. If they do not include this, their lawsuit fails as a matter of law because it does not indicate what they want the court to do.
So you’re asking, “What good is this information for me?”
Good question.
The first thing you need to know is this is a serious threat to your financial well-being and is no joke. Secondly you may not recognize who is suing you. Most debt buyers stay below the radar and only become real issues for you when they are trying to sue you. Finally, you may be able to find mistakes in the complaint, information you can give your attorney to help you fight back.
So if you’ve gotten one of these complaints, and you are in Lehigh County or the surrounding area, give me a call at 610-928-1233 to set an appointment, you can all email me at jim@padebt911.com. If you are not in my area, feel free to send an email, I have friends who do this everywhere and I can probably point you in the right direction. You don’t have to fight this alone!
Once in a while I too get tempted to scream at the debt buyers on the phone, don’t give in, just give me a call and I’ll give them what-for where it works, in a court of law!