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HomeMy WebLinkAbout07-0619 w NC022135 THIS IS AN ARBITRATION MATTER. ASSESSMENT OF DAMAGES HEARING REQUIRED. GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 PAUL M. SCHOFIELD, JR., ESQUIRE Identification No.: 81894 21 SOUTH 21ST STREET PHILADELPHIA, PA 19103 215/988-9600 NCO/PURCHASER FROM CITIBANK 1804 WASHINGTON BLVD. Baltimore MD 21230 VS. VICTORIA A REISINGER 967 W TRINDLE RD LOT 11 MECHANICSBURG PA 17055-4056 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. C>'7- / ?ft"pi NOTICE 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 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 JUDGEMENT 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. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 At COMPLAINT IN CIVIL-ACTION 1. Plaintiff is a debt buyer and successor in interest to the original creditor as set forth in the caption of this Complaint. 2. At all times relevant hereto, the defendant(s) was the holder of a credit card, which at the request of the defendant(s) was issued to the defendant(s) by the plaintiff under the terms of which the plaintiff agreed to extend to defendant(s)the use of plaintiff's credit facilities. 3. Defendant(s) accepted and used the aforesaid credit card so issued and by so doing agreed to perform the terms and conditions prescribed by the plaintiff for the use of said credit card. 4. The defendant (s) received and accepted goods and merchand- ise and/or accepted services or cash advances through the use of the credit card issued by the Plaintiff. 5. All the credits to which the defendant (s) is entitled have been applied and there remains a balance due in the amount of $5,806.96. 6. Plaintiff has made demand upon the defendant(s)for payment of the balance due of $5,806.96 but the defendant(s)has failed and refused and still refuses to pay the same or any part thereof. 6. Defendant's last payment on account was made on 2/13/03. r WHEREFORE, plaintiff claims of the defendant(s) the sum of $5,806.96 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDERIC I. WTI-d$ERG, ESQUIRE PAUL M. SCHOFIELD, JR., ESQUIRE Attorney for Plaintiff POlA.DB VERIFICATION FREDERIC I. WEINBERG, ESQUIRE, hereby states that he is the attorney for the Plaintiff (s) in this action and verifies that the statements made in the foregoing pleading are true and correct to the best of his knowledge, information and belief. The undersigned understands that the statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities. FREDERIC I. EINBE G, ESQUIRE ? v( ? w \ vv r> N c..J 'Y 7 C r n OV) I GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 PAUL M. SCHOFIELD, JR., ESQUIRE Identification No.: 81894 21 SOUTH 21ST STREET PHILADELPHIA, PA 19103 215/988-9600 NCO/PURCHASER FROM CITIBANK COURT OF COMMON PLEAS CUMBERLAND COUNTY VS. VICTORIA A REISINGER DOCKET NO. : 07-619 PRAECIPE FOR JUDGMENT The Prothonotary will please enter Judgment in the above matter by default for want of an answer against the Defendant, VICTORIA A REISINGER, and assesses the damages as per statement below. FREDERIC I. WEINBERG ES IRE PAUL M. SCHOFIELD, J SQUIRE Attorney for Plaintiff Principal $3,005.09 Interest from 2/13/03 @29.24% $2,915.02 Costs (Complaint & Service) $155.50 Total: $6,075.61 I hereby certify that written notice of the intention to file this Praecipe was mailed or delivered to the parties against whom judgment is to be entered and to his attorney of record, if any, after the default occurred and at least ten (10) days prior to the date of the filing of this Praecipe. FREDERIC I. WEIN , ESQUIRE PAUL M. SCHOFIELD, JR., ESQUIRE Attorney for Plaintiff Filed: By the Prothonotary: AND NOW, this day of `7lZc_4 2007 Judgment is entered in favor of the plaintiff(s) and against defendant, for want of an answer and damages assessed at the sum of , $6,075.61 as per the above certification. ?a / A Prothonotary GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 PAUL M. SCHOFIELD, JR., ESQUIRE Identification No.: 81894 21 SOUTH 21ST STREET PHILADELPHIA, PA 19103 215/988-9600 NCO/PURCHASER FROM CITIBANK Vs. VICTORIA A REISINGER COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 07-619 CERTIFICATION OF ADDRESS I hereby certify that the precise residence of the holder of the within judgment is; NCO/PURCHASER FROM CITIBANK and that the last known address of defendant, VICTORIA A REISINGER, 967 W TRINDLE RD LOT 11, MECHANICSBURG PA 17055-4056. GORDON & WEINBERG, P.C. BY: FREDERIC A. WEI ERG, ESQUIRE PAUL M. CH LD, JR.,ESQUIRE Attorney for Plaintiff J NC022135 GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 PAUL M. SCHOFIELD, JR., ESQUIRE Identification No.: 81894 21 SOUTH 21ST STREET PHILADELPHIA, PA 19103 215/988-9600 NCO/PURCHASER FROM CITIBANK VS. VICTORIA A REISINGER TO/PARA COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 07-619 NOTICE OF INTENTION TO TAKE DEFAULT VICTORIA A REISINGER 967 W TRINDLE RD LOT 11 MECHANICSBURG PA 17055-4056 DATE OF NOTICE/FECHA DEL AVISO: March 2, 2007 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY AN ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. 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 PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 GORDON & WEINBERG, P.C. BY: FREDERIC I. INBER ESQUIRE PAUL M. SCHO ELD, R., ESQUIRE P10D-2 ' GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 PAUL M. SCHOFIELD, JR., ESQUIRE Identification No.: 81894 21 SOUTH 21ST STREET PHILADELPHIA, PA 19103 215/988-9600 NCO/PURCHASER FROM CITIBANK VS. VICTORIA A REISINGER COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 07-619 AFFIDAVIT OF NON-MILITARY SERVICE FREDERIC I. WEINBERG, ESQUIRE, being duly sworn according to law, deposes and says that he represents the plaintiff in the above- entitled case; that he is authorized to make this affidavit on behalf of the plaintiff; and that the above-named defendant is over twenty- one years of age; that the address of the defendant is, 967 W TRINDLE RD LOT 11, MECHANICSBURG PA 17055-4056; that the occupation of the defendant is unknown; and that the defendant is not in the Military Service of the United States, nor any State or Territory thereof or its allies as defined in the Soldiers' and Sailors' Civil Relief Act of 1940 and the amendments thereto. Sworn to and Subscribed Before me this Day 2 0 ?.??? ?? NotAry Public co , ?A4d N 0p' PENNsyLVANIA OTARIA, SEAS b5c CHRISTINE M. COL N, NMary C bf felphia, Phil. GiQ?ty ? E s Novamper 18, 2069 :1?? FREDERIC I. WE , ESQUIRE PAUL M. SCHOFIELD, JR. ESQUIRE Attorney for Plaintiff i t -tJ r c_' C? ra u) Q rj Aai a NC022135 GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 PAUL M. SCHOFIELD, JR., ESQUIRE Identification No.: 81894 21 SOUTH 21ST STREET PHILADELPHIA, PA 19103 215/988-9600 NCO/PURCHASER FROM CITIBANK COURT OF COMMON PLEAS CUMBERLAND COUNTY VS. VICTORIA A REISINGER DOCKET NO NOTICE 07-619 PURSUANT TO RULE 236 OF THE SUPREME COURT OF PENNSYLVANIA, YOU ARE HEREBY NOTIFIED THAT A JUDGMENT BY DEFAULT HAS BEEN ENTERED AGAINST YOU IN THE ABOVE PROCEEDING IN THE AMOUNT OF $6,075.61. IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL GORDON & WEINBERG, P.C. AT 215/988-9600. GORDON & WEINBERG, P.C. BY: FREDERIC LHOFNtD, BERG, ESQUIRE PAUL M. S JR.,ESQUIRE Attorney Plaintiff Dated: March 13, 2007 SHERIFF'S RETURN - REGULAR CASE NO: 2007-00619 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND NCO/PURCHASER FROM CITIBANK VS REISINGER VICTORIA A STEPHEN BENDER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon the REISINGER VICTORIA A DEFENDANT at 1500:00 HOURS, on the 9th day of February-, 2007 at 967 W TRINDLE ROAD LOT 11 MECHANICSBURG, PA 17055-4056 by handing to VICTORIA REISINGER 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: So Answers: Docketing 18.00 Service 15.84 Affidavit 00 Surcharge 10.00 R. Thomas Kline .00 43.84 02/12/2007 GORDON & WEINBERG Sworn and Subscibed to By: before me this day puty Sheriff of A.D.