The URL can be used to link to this page

Home My WebLink About07-1940Burton 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 IN THE COURT OF COMMON PLEAS 8875 Aero Drive, Suite 200, San Diego, CA Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. SHARON ROQUE 200 Gull Court, Mechanicsburg, PA Defendant : NO. C) I _ IM : CIVIL ACTION - LAW Complaint - Notice 011..'LC-7? 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 83731 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. SHARON ROQUE 200 Gull Court, Mechanicsburg, PA Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. a'7 . ?tv c,L : 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 Sharon Roque, who resides at 200 Gull Court, Mechanicsburg, Cumberland County, Pennsylvania. I First North American National Bank furnished consumer credit to defendant bearing account number 4146820000567220 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 $11,487.24. 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 $11,487.24, the defendant failed and refused to pay all or any part thereof. Wherefore, plaintiff demands judgment against the defendant in the sum of $11,487.24 and the costs of this action. Burton NeilA-Associ P.C. By: Yale . Wvcj ,; Attey for Plaintiff The law firm of Burton Neil & Associates, P. C. is a debt collector. Verification I, ??U6y) MW),64eyMOYI 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: ?- 115) 0-1 Sharon Roque 4146820000567220 ? w W "Z 'r a Yom' l°?i CD f` J .1- ;iii (013 _v6 Midland Funding LLC 8875 Aero Drive Suite 200, San Diego CA 92123 Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 07-1940 SHARON ROQUE 200 Gull Court Mechanicsburg PA 17050 Defendant CIVIL 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: $11,487.24 TOTAL $11,487.24 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 from t? defendant and/or the Department of Defense website. JUDGMENT BY DEFAULT ENTERED AND DAMAGES ASSESSED AS ABOVE. NOTICE GIVEN UNDER PA.R.?.P. 236 /l I? ^1 CC Prd Prothonotary The law firm of Burton Neil & Associates is a debt collector. Burton 'Veil & AsWiates, P.C. BY: Yale Weinstein, Esquire Atto ev for Plaintiff I.D. 689678 10 Andrew Drive, Suite 170 W. Chester, PA 19380 83731 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 V. SHARON ROQUE Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 07-1940 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 Prothonotary By: If you have any questions concerning the above, please contact: Yale D. Weinstein, Esquire Attorney for Parry 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. 83731 MIDLAND FUNDING LLC : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 07-1940 SHARON ROQUE Defendant : CIVIL ACTION - LAW Notice of Intention to File Praecipe for Default Judgment TO: Sharon Roque 200 Gull Court Mechanicsburg PA 17050 IMPORTANT NOTICE 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 800-990-4108 DATE OF NOTICE: May 14, 2007 In making this communication, we advise our office is a debt collector. I111MI 1111 Neil 8fAfssociates, P.C. Yak,,). instern, Esquire Attorn or Plaintiff Identi cation No. 89678 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 ! ??i 111 ? ?fll f?! ?I f ?I II?N I? i? ? ? ?!!I p! M? lei a 0 Y a C 1 "L3 CD --1 SHERIFF'S RETURN - REGULAR CASE NO: 2007-01940 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MIDLAND FUNDING LLC VS ROQUE SHARON JESSICA HERMANSEN Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon ROQUE SHARON the DEFENDANT , at 1557:00 HOURS, on the 20th day of April , 2007 at 200 GULL COURT MECHANICSBURG, PA 17050 rT 1 TINT T'%/\rTTT7 by handing to 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 11.52 Affidavit .00 Surcharge 10.00 .00 3'1?3fo7 Q 39.52 Sworn and Subscibed to before me this day So Answers: R. Thomas Kline 04/23/2007 BURTON NEIL & ASSOCIATES By: !?. Dep Sheriff of A. D. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MIDLAND FUNDING LLC VS. NO. 2007-1940 SHARON ROQUE PRAECIPE FOR APPEARANCE TO THE PROTHONOTARY: MIDLAND FUNDING LLC Please enter my appearance for in the above case. Date: December 18, 2014 Stephen Selinger Print Name Eltman, Eltman & Cooper, PC Firm 140 Broadway, 26th Fl Address New York, NY 10005