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HomeMy WebLinkAbout07-3205 NC026616 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 NCO Portfolio Management, as assignee of Household Auto Finance 1804 Washington Blvd. Baltimore MD 21230 VS. MELISSA MYERS 67 MEADOWBROOK COURT NEW CUMBERLAND PA 17070-2511 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 0A1 - ?.w I COMPLAINT IN ASSUMPSIT 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 i 1. Plaintiff is a debt buyer and successor in interest to the original creditor as set forth in the caption of this Complaint. 2. The defendant, for valuable consideration received, executed and delivered to plaintiff a promissory note under the terms of which the defendant promised to pay to the plaintiff consecutive monthly payments under the terms and conditions set forth in the promissory note. 3. Contrary to the terms of the aforesaid promissory note, the defendant failed to make the required payments when due as a result of which the unpaid balance of $19,259.92 became due and payable. 4. As a result of defendant's default, defendant is indebted to plaintiff in the amount of $19,259.92 plus interest thereon and attorney's fees as provided for in the promissory note. 5. Plaintiff has made demand upon the defendant for payment of the amount due but the defendant has failed and refused and still refuses to pay the said sum or any part thereof. 6. Defendant's last payment on account was made on June 25, 2003. WHEREFORE, plaintiff claims of the defendant the sum of $19,259.92 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDERIC I QOFI BERG, ESQUIRE PAUL M. SC D, JR. , ESQUIRE Attorney fintiff POIC.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 II. WE)INBERG, ESQUIRE n ? 'C7 i7" L o? SHERIFF'S RETURN - NOT FOUND CASE NO: 2007-03205 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND NCO PORTFOLIO MANAGEMENT VS MYERS MELISSA R. Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT MYERS MELISSA but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT & NOTICE the within named DEFENDANT , MYERS MELISSA 67 MEADOWBROOK COURT So apl?lie r NEW CUMBERLAND, PA 17070 GIVEN ADDRESS IS LOCATED IN YORK COUNTY. Sheriff's Costs: Docketing 18.00 Service 17.28 Not Found 5.00 Surcharge 10.00 .00 51 0,7 ?,{ ? 50.28 , NOT FOUND , as to k, K. 'rnoma s aline ,if of Cumberland County (7ORDON & WEINBERG 06/05/2007 Sworn and Subscribed to before me this day of A. D. NC026616 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 484/351-0500 NCO Portfolio Management, as assignee of Household Auto Finance VS. MELISSA MYERS COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 07-3205 PRAECIPE TO WITHDRAW COMPLAINT TO THE PROTHONOTARY: Kindly withdraw the above-captioned action, without prejudice. GORDON & WEINBERG, P.C. BY: FREDE7vrfor I. W NBERG, ESQUIRE JOEL FLINK, ESQUIRE Attor Plaintiff P006 01 CERTIFICATION OF SERVICE I, FREDERIC I. WEINBERG, ESQUIRE, hereby certify that I, on the date below, served a copy of the Praecipe to withdraw Complaint to Pa.R.C.P. 1028(c)(1), via First Class Mail, postage pre-paid, to all other parties or their counsel of record. zl/--- FREDERIC . EINBERG, ESQUIRE Dated /o -- Lb - 07 OF A'MARY 2019 OCT 23 FM 2-9 22 CUWA6,??