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Home My WebLink About07-0774Burton Neil & Associates, P.C. By: Yale D. Weinstein, Esquire ID. NO. 89678 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 Attorney for Plaintiff MIDLAND FUNDING LLC 8875 Aero Drive, Suite 200, San Diego, CA Plaintiff V. BEATRICE H MCCOMBS 9 Richland Lane Apt 105, Camp Hill, PA Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. Q 7 Y ? CIVIL ACTION - LAW Complaint - 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 (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 claim 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. 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 AGLNCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERENCE AND INFORMATION SERVICE Cumberland County Bar Assoc. 32 South Bedford Street Carlisle, PA 17013 Telephone No. 717-249-3166 or 800-990-9108 82297 Burton Neil & Associates, P.C. By: Yale D. Weinstein, Esquire ID. NO. 89678 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 Attorney for Plaintiff MIDLAND FUNDING LLC 8875 Aero Drive, Suite 200, San Diego, CA Plaintiff V. IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 0 7, 17 y ?-1 ? BEATRICE H MCCOMBS 9 Richland Lane Apt 105, Camp Hill, PA Defendant CIVIL ACTION - LAW Complaint 1. The plaintiff is Midland Funding LLC with place of business located at 8875 Aero Drive, Suite 200, San Diego, California. 2. The defendant is Beatrice H McCombs, who resides at 9 Richland Lane Apt 105, Camp Hill, Cumberland County, Pennsylvania. 3. First North American National Bank furnished consumer credit to defendant bearing account number 4146820002695599 hereinafter referred to as the credit card account. 4. The defendant made purchases, balance transfers and/or cash advances on the credit card account. 5. The balance due on the credit card account is $11,492.57. 6. Defendant did not pay the balance due on the credit card account as required by the credit card agreement. As such, defendant is in default on the credit card account. 7. Plaintiff purchased the defendant's account from First North American National Bank and is now the holder and owner of the account. 8. Although demand has been made by plaintiff upon defendant to pay the sum of $11,492.57, the defendant failed and refused to pay all or any part thereof. Wherefore, plaintiff demands judgment against the defendant in the sum of $11,492.57 and the costs of this action. Burton Neff Asskfates. P.C. By; ( Yale Weinstein, Esquire for Plaintiff The law firm of Burton Neil & Associates, P. C. is a debt lti Verification I, ejY av) am an employee of Midland Credit Management, Inc. which is by contract the servicer for plaintiff Midland Funding LLC retained to collect delinquent debt. I am authorized to make this verification pursuant to a servicing agreement from plaintiff to Midland Credit Management, Inc. The foregoing averments of fact in the within pleading are true and correct to the best of my knowledge, information and belief. I understand that the statements made herein are subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to the authorities. Date: 1 I J ? O/1 Beatrice H McCombs 4146820002695599 rri l MIDLAND FUNDING LLC 8875 Aero Drive Suite 200, San Diego CA 92123 Plaintiff V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-774 BEATRICE H MCCOMBS 9 Richland Lane Apt 105 Camp Hill PA 17011 Defendant : C17VEL ACTION - LAW Praecipe for Default Judgment To the Prothonotary: Please enter judgment by default for want of an answer in the above case in favor of the plaintiff and against the defendant, and assess damages as follows: Principal: $11,492.57 TOTAL $11,492.57 Understanding that false statements herein made are subject to penalty under 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities, I verify that: 1. The above are the precise last-known addresses of the judgment debtor and creditor. 2. The annexed notice of intention to file this praecipe was mailed to all parties against whom judgment is to be entered and to their record attorneys, if any, after the default occurred, and at least ten days prior to the date of the filing of this praecipe. 3. Pursuant to Section 201(b)(1)(A) of the Servicemembers Civil Relief Act of 2003 (SCRA), the defendant is not in the military service of the United States based on information received fr?e defendant and/or the Department of Defense website. JUDGMENT BY DEFAULT ENTERED AND DAMAGES ASSESSED AS ABOVE. ER PA.R.CIV.P. 236 NOTIC GIVEN Iff Pro thonot The law firm of Burton Neil & Associates is a debt collector. Burton Nafl_&Wociates. P.C. BY: Yal . NT-einstein, Esquire A ev for Plaintiff If #89678 1060 Andrew Drive, Suite 170 W. Chester, PA 19380 82297 MIDLAND FUNDING LLC Plaintiff V. BEATRICE H MCCOMBS Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 07-774 : CIVIL ACTION - LAW Notice of Intention to File Praecipe for Default Judgment TO: Beatrice H McCombs 9 Richland Lane Apt 105 Camp Hill PA 17011 IlVIPORTANT NOTICE 82297 You are in default because you have failed to enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) 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 notice to your lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help. 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. LAWYER REFERENCE AND INFORMATION SERVICE Cumberland County Bar Assoc. 32 South Bedford Street Carlisle, PA 17013 Telephone No. 717-249-3166 or 800-990-9108 DATE OF NOTICE: March 14, 2007 P.C. In making this communication, we advise our office is a debt collector. Yale D. instein, Esquire Attorney or Plaintiff Identifi tion No. 89678 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 INl?ll?llll???l?lllll?l lll???l?ll?l?illllll?I?III?II?III?III?IAIINII? IV nij; /??• 1 O r Burton Neil & Associates, P.C. By: Yale D. Weinstein, Esquire ID. N. 89678 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 ATTORNEY FOR: Plaintiff MIDLAND FUNDING LLC : IN THE COURT OF COMMON PLEAS Plaintiff V. BEATRICE H MCCOMBS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 07-774 Defendant : CIVIL ACTION - LAW Rule of Civil Procedure NO. 236 (Revised) Notice is given that a JUDGMENT in the above captioned matter has been entered against you on flr,_? L a Prothonotary By: If you have any questions concerning the above, please ontact: Yale D. Weinstein, Esquire Attorney for Party Filing 1060 Andrew Drive, Suite 170 West Chester, PA 19380 Phone: 610-696-2120 The law firm of Burton Neil & Associates is a debt collector. SHERIFF'S RETURN - REGULAR CASE NO: 2007-00774 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MIDLAND FUNDING LLC VS MCCOMBS BEATRICE H KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon MCCOMBS BEATRICE H the DEFENDANT , at 2000:00 HOURS, on the 20th day of February-, 2007 at 9 RICHLAND LANE APT 105 CAMP HILL, PA 17011 by handing to BEATRICE MCCOMBS 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: Docketing 18.00 Service 13.20 Affidavit .00 Surcharge 10.00 .00 3)n /67 ? 41.20 Sworn and Subscibed to before me this day of , So Answers: je??- R. Thomas Kline 02/21/2007 BURTON NEIL & ASSOCIATES By: A. D.