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07-1660
Burton Neil & Associates, P.C. By: Brit Suttell, Esquire ID. N0.204140 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 Attorney for Plaintiff WORLDWIDE ASSET PURCHASING,LLC IN THE COURT OF COMMON PLEAS 9911 Covington Cross Dr Las Vegas, NV 89144 Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. DEANETT FLEMING-BENTZEL NO. ~~- „ /` ~~ ~J`v~,~~ 1420 Timber Brook Drive, Mechanicsburg PA 17050 ~/ Defendant :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 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 83436 R Burton Neil & Associates, P.C. By: Brit Suttell, Esquire ID. NO. 204140 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 Attorney for Plaintiff WORLDWIDE ASSET PURCHASING,LLC 9911 Covington Cross Dr Las Vegas, NV 89144 IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. DEANETT FLEMING-BENTZEL ~ NO. ~'I /(~ G fl 1, lv~~~~z~ 1420 Timber Brook Drive, Mechanicsburg PA 17050 Defendant CIVIL ACTION -LAW Complaint 1. The plaintiff is WORLDWIDE ASSET PURCHASING,LLC, abusiness corporation, with place of business located at 9911 Covington Cross Dr, Las Vegas, NV. 2. The defendant is Deanett Fleming-Bentzel, who resides at 1420 Timber Brook Drive, Mechanicsburg, Cumberland County, Pennsylvania. 3. At the defendant's request, Bank of America, N.A. furnished consumer credit to defendant bearing account number 4427115000067481 hereinafter referred to as the credit card account. 4. The defendant accepted the credit card account by making purchases, balance transfers and/or cash advances. 5. Monthly statements were sent to defendant each month which detailed the charges and credits made to the credit card account for the prior month. 6. The balance due on the credit card account is $12,230.08. 7. Defendant did not pay the balance due on the credit card account in full upon receipt of the monthly billing statements and also did not make the required minimum monthly payment set forth in the monthly billing statement. As such, defendant is in default on the credit card account. 8. Plaintiffpurchased the defendant's account from Bank of America, N.A. and is now the holder and owner of the account. 9. Although demand has been made by plaintiff upon defendant to pay the sum of $12,230.08, the defendant failed and refused to pay all or any part thereof. Wherefore, plaintiff demands judgment against the defendant in the sum of $12,230.08 and the costs of this action. Burton Neil & Associates, P.C. By: rit Suttell, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. r ~ ~ Verification -3y.~~ Gayle Dizon is Attorney Relationship Manager for WORLDWIDE ASSET PURCHASING,LLC, the within Plaintiff, and makes this statement on its behalf as to the truthfulness of the facts set forth in the foregoing Complaint subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Date: 4 ~ ~~ ~~ Name Deanett Fleming-Bentzel 4427115000067481 EXHIBIT - ? ~ _.,_ 1 v ,. i_ S i~b r1..'.~ ~, ~-, ^ i]P~~ --~ ~~~ ~ F _' ..~ ~ 'y ~-+. `. J. f`.S ..G Burton Neil & Associates, P.C. By: Burton Neil, Esquire ID. NO. 11348 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorne for Plaintiff WORLDWIDE ASSET PURCHASING,LLC Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA N0.07-1660 DEANETT FLEMING-BENTZEL Defendant CNIL ACTION -LAW Praecipe to Settle, End, & Discontinue To the Prothonotary: Mark the above matter Settled, Ended and Discontinued. Burton Ne' & ociates, P.C. ,' By: Burto Neil, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates is a debt collector. 83436 '~' i ~ ~ ' ~.. ~. ~'~_ `© ~~~ 3 ~` W SHERIFF'S RETURN - REGULAR CASE NO: 2007-01660 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WORLDWIDE ASSET PURCHASING LLC VS FLEMING-BENTZEL DEANETT TIMOTHY REITZ Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE FLEMING-BENTZEL DEANETT DEFENDANT Sheriff or Deputy Sheriff of was served upon the at 2038:00 HOURS, on the 27th day of March 2007 at 1420 TIMBER BROOK DRIVE MECHANICSBURG, PA 17050 KEVIN BENTZEL by handing to ADULT IN CHARGE 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 Service Affidavit Surcharge <~~C4~d,~ (1 / Sworn and Subscibed to before me this of So Answers: 18.0 0 ~/~~ ~;~ ~, 12.4 8 ~, ~,~~~ . 0 0 ~~" 10.00 R. Thomas Kline .00 40.48 03/28/2007 BURTON NEIL & ASSOCIATES day Dep ty Sher ff A.D.