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Home My WebLink About07-2500IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA BUREAUS INVESTMENT GROUP N07 LLC, assignee of CHASE MANHATTAN BANK USA, Plaintiff(s), -vs- NELSON A. BRUMBACH, Defendant(s). No. ~'7 --.Zs'~ IN CIVIL ACTION COMPLAINT CODE- FILED ON BEHALF OF PLAINTIFF COUNSEL OF RECORD FOR THIS PARTY: James R. Apple, Esq. PA I.D. No. 37942 Charles F. Bennett, Esq. PA I.D. No. 30541 Joel E Hausman, Esq. PA I.D. No. 42096 APPLE AND APPLE, P.C. Firm No. 719 4650 Baum Boulevard Pittsburgh, PA 15213 Telephone: 412-682-1466 Fax: 412-682-3138 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA BUREAUS INVESTMENT GROUP N07 LLC, NO. assignee of CHASE MANHATTAN BANK USA, IN CIVIL ACTION Plaintiff(s), -vs- NELSON A. BRUMBACH, Defendant(s). NOTICE TO DEFEND 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 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, 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 2 Liberty Avenue Carlisle PA 17013 1(800)990-9018 2 COMPLAINT 1. Plaintiff is a corporation having offices at 1717 Central Street, Evanston, IL 60204 and as the assignee of Chase Manhattan Bank USA, stands in its assignor's stead, and all are hereinafter referred to interchangeably as "Plaintiff'. 2. Defendant is an individual whose address is 896 Humber St, Enola, Cumberland County, Pennsylvania 17025-2923. 3. At a specific instance and request of the Defendant, the Defendant applied for and was granted a credit card and/or loan by Plaintiff at the terms and conditions agreed upon by the parties 4. The Plaintiff avers that the agreement between the parties was based upon a written agreement which the Defendant accepted by using credit card or loan to make purchases and/or cash advances. 5. Thereafter, in breach of obligations under the Agreement, the Defendant failed to make payments as they became due. 6. Plaintiff avers that the terms of the Agreement provide for acceleration of the entire balance due and owing upon Defendant's breach of the Agreement. 7. Plaintiff avers that the balance due amounts to $5,045.52, as is more specifically shown by Plaintiff's Statement of Account, a true and correct copy of which is attached hereto, marked Exhibit "A" and made a part hereof. 8. Plaintiff avers that the interest has accrued at the rate of 20% per annum on the balance due from November 10, 2006. 9. Per the term of the agreement, the Defendant has agreed to pay to the Plaintiff as liquidated damages, the costs of collection, including all reasonable attorneys' fees incurred in the collection of monies owing, which Plaintiff avers will amount to 20% of the balance due. 10. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed and refused to pay the amount due to Plaintiff or any part thereof. WHEREFORE, Plaintiff demands Judgment against Defendant in the amount of $5,045.52, with appropriate additional interest from November 10, 2006, plus attorneys' fees and costs. APPLE AND APPLE, P.C. By: orneys or Plaintiff(s) 4 Client: BUREAUS INVESTMENT GROUP NO 7 LLC Assignee of CHASE VISA/MASTERCARD 1717 Central Street Evanston, IL 60201 11/9/2006 NELSON A BRUMBACH 896 S HUMER ST ENOLA, PA 170252923 STATEMENT OF ACCOUNT Original Account Number: 5260315069119168 Account Number: 414024300 New Balance Payment Due Date Statement Closing Date $5,045.52 11/9/2006 11 /9/2006 Total Credit Line Total Available Line Cash Access Line Available Cash $p $0 $0 $0 Your account is seriously past due, and the full balance is due immediately. @ 20.00% Per Annum IRAN POST REF. DESCRIPTION OF TRANSACTION CREDITS CHARGES DATE DATE NO. Here is your Account Summary: Previous Balance $3,568.18 (-) Payment & Credits $0.00 (+) Purchases, Cash, Debits 0.00 (+) FINANCE CHARGES $1,477.34 (_) New Balance $5,045.52 Minimum Payment Due $5,045.52 Your charges and credits at a glance: Send Payments to: The Bureaus Inc PO Box 809323 Chicago IL 606809323 Write your account number on your check or money order. Never send cash. EX8181t ~~~~ N '~ fJ ~~#, ~~s. b ~~ f"~ N ;.:.-~ ....,, e~ t:`t '.~! "i1 ~_ !~ rT .• ? t'" .., ~~ rj E~-C-1 -~: SHERIFF'S RETURN - REGULAR CASE NO: 2007-02500 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BUREAUS INVESTMENT GROUP NO7 VS BRUMBACH NELSON A JESSTCA HERMANSEN Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE BRUMBACH NELSON A DEFENDANT was served upon the at 2040:00 HOURS, on the 1st day of May 2007 at 896 HUMER STREET ENOLA, PA 17025 NELSON BRUMBACH by handing to 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 18.00 Service 14.40 Affidavit .00 Surcharge 10.00 6~3e~0 7 ~, 00 4 Sworn and Subscibed to before me this day of , So Answers: R. Thomas Kline 05/03/2007 APPLE & APPLE By. De u y heriff A.D.