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HomeMy WebLinkAbout07-29842028610 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 NU ISLAND PARTNERS, LLC AS ASSIGNEE OF CLOUT FINANCIAL SERVICES 701 West 7th Street Little Rock, AR 72201 VS. JONATHAN CAMIS 564 GUTSHALL RD--APT # A BOILING SPRINGS PA 17007 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. 0,7 a ?00? (2t0 t'L 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 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. A true and correct copy of the Statement of Account is attached hereto as Exhibit "A". 5. All the credits to which the defendant (s) is entitled have been applied and there remains a balance due in the amount of $2,752.34. 6. Plaintiff has made demand upon the defendant(s)for payment of the balance due of $2,752.34 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 1/16/04. WHEREFORE, plaintiff claims of the defendant(s) the sum of $2,752.34 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDERIC I. EI RG, ESQUIRE PAUL M. SOHO ELD, JR., ESQUIRE Attorney for Plaintiff P01A.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. W BERG, ESQUIRE JONATHAN CAMIS 4680806200226560 2028610 NU ISLAND PARTNERS, LLC AS ASSIGNEE OF CLOUT FINANCIAL SERVICES AFFIDAVIT I' 1 r sd 1 I=BM-Wi't` , being duly served sworn accord g to law, depose and say that: 1. I am the agent for the Plaintiff herein and I have custody and control of the files relating to this account; 2. I have personal knowledge of the facts and circumstances in connection with this case; 3. Plaintiff's files are maintained in the usual and ordinary course of business; 4. This action is based on a claim for breach of contract and that damages are sought as a direct result of said breach; 5. After allowing for all offsets and credits, a balance remains on the subject account having account number 4680806200226560in the amount of $2,407.62; and 6. If called upon, affiant can testify at trial as to the facts pertaining to this matter. The above facts are true and correct to the best of my knowledge, information and belief. Sworn to and Subscribed e-) 0771 before me this day ?f 2007 Notary (Mme f Affiant) ". ss HANp''•. UO?pTAR s M. 105. 0'3 r- W f7l CO F? ? ?'B rfT) E T9 L SHERIFF'S RETURN - REGULAR CASE NO: 2007-02984 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND NU ISLAND PARTNERS LLC ET AL VS CAMIS JONATHAN DAVID MCKINNEY , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE CAMIS JONATHAN was served upon the DEFENDANT , at 1553:00 HOURS, on the 5th day of June , 2007 at 1397D CREEK ROAD BOILING SPRINGS, PA 17007 by handing to CRYSTAL MICK, GIRLFRIEND, ADULT IN CHARGE 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 Service Affidavit Surcharge Ljlr'0.) 9.., Sworn and Subscibed to before me this So Answers: 18.00 6.72 ?I 00 10.00 R. Thomas Kline .00 34.72 06/06/2007 GORDON & WEINBERG By: day Dep y of A. D. 4 A GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 81894 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 215/988-9600 NU ISLAND PARTNERS, LLC AS ASSIGNEE OF CLOUT FINANCIAL SERVICES vs. JONATHAN CAMIS COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 07-2984 PRAECIPE FOR JUDGMENT The Prothonotary will please enter Judgment in the above matter by default for want of an answer against the Defendant, JONATHAN CAMIS, and assesses the damages as per statement below. FREDERIC I. WEIN E , ESQUIRE JOEL M. FLINK, ESQUIRE Attorney for Plaintiff Principal $2,407.62 Interest from 1/16/04 Q6o $508.17 Costs (Complaint & Service) $113.22 Total: $3,029.01 Filed: By the Prothonotary: 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 (10ydda s prior to the date of the filing of this Praecipe. FREDERIC I. WEI ERG, ESQUIRE JOEL M. FLINK, ESQUIRE Attorney for Plaintiff AND NOW, this as} day of XIAU , 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 , $3,029.01 as per the above certification. " R. [?qAj oKA Pifothonotary C o P c? n Mr: c MM D >c rn <p t GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 81894 1 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 215/988-9600 NU ISLAND PARTNERS, LLC AS ASSIGNEE OF CLOUT FINANCIAL SERVICES Vs. COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 07-2984 JONATHAN CAMIS CERTIFICATION OF ADDRESS I hereby certify that the precise residence of the holder of the within judgment is; NU ISLAND PARTNERS, LLC ASASSIGNEE OF CLOUT FINANCIAL SERVICES and that the last known address of defendant, JONATHAN CAMIS, 1397 D CREEK ROAD, BOILING SPRINGS PA 17007. GORDON & WEINBERG, P.C. BY: FREDERIC I. INBER , ESQUIRE JOEL M. FLINK, IRE Attorney for Plaintiff -0 -DM -, 41, t7 DC: C7tit GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 81894 i 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 215/988-9600 NU ISLAND PARTNERS, LLC AS ASSIGNEE OF CLOUT FINANCIAL SERVICES COURT OF COMMON PLEAS CUMBERLAND COUNTY Vs. JONATHAN CAMIS DOCKET NO. : 07-2984 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, 1397 D CREEK ROAD, BOILING SPRINGS PA 17007; 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 o2,4'" Day of 2007. R# NA IAL SEAL r ubt?c BARBARA A p(NICK, Notary City ai ph&W{ph', Phifa. County FREDERIC I . WEIN ERG, ESQUIRE - M Commission Ex ices Jul 29, 240JOEL M . FLIN ESQUIRE Attorney for Plaintiff c_. q 71 z r o -? 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 NU ISLAND PARTNERS, LLC AS ASSIGNEE OF CLOUT FINANCIAL SERVICES vs. JONATHAN CAMIS TO/PARA 2028610 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 07-2984 NOTICE OF INTENTION TO TAKE DEFAULT JONATHAN CAMIS 564 GUTSHALL RD--APT N A BOILING SPRINGS PA 17007 DATE OF NOTICE/FECHA DEL AVISO: June 28, 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: FREDERICSC flWFIEINL B G, ESQUIRE PAUL M. JR., ESQUIRE P10D-2 2028610 GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 215/988-9600 NU ISLAND PARTNERS, LLC AS ASSIGNEE OF CLOUT FINANCIAL SERVICES COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. JONATHAN CAMIS DOCKET NO. : 07-2984 NOTICE 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 $3,029.01. IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL GORDON & WEINBERG, P.C. AT 215/988-9600. GORDON & WEINBERG, P.C. BY: FREDERLL- I. WEI BERG, ESQUIRE JOEL M. FLI SQUIRE Attorney for Plaintiff Dated: July 23, 2007 r.s a C ° `"' - ? --0 tTl - 2028610 GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 81894 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 NU ISLAND PARTNERS, LLC AS ASSIGNEE OF CLOUT FINANCIAL SERVICES COURT OF COMMON PLEAS CUMBERLAND COUNTY VS. DOCKET NO. : 07-2984 JONATHAN CAMIS SUGGESTION OF BANKRUPTCY OF DEFENDANT TO THE PROTHONOTARY: AND NOW, this July 9, 2008, it is suggested of record that Defendant, JONATHAN CAMIS, filed a petition in bankruptcy under Chapter 07 of the Bankruptcy Code on or about April 12, 2008, in the United States Bankruptcy Court for the Middle District of Pennsylvania, docket number 08-01313. Therefore, this matter should be stayed until further notice. GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE JOEL M. FLINK, ESQUIRE Attorney for Plaintiff i ?° ? i - : . . .. J?,i; Y, .. ?_ ae*r ?." l _ ? '?., ?? ?