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HomeMy WebLinkAbout07-3705• y NCO26416 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 Bank of America 1804 Washington Blvd. Baltimore MD 21230 vs. JAHYSON L BRAXTON 5146 ERBS BRIDGE ROAD HAMPDEN PA 17050-2432 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO . Q'`I - .3"IQS' l.:lu~.~ 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 r 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 was the holder of a credit card, which at the request of the defendant was issued to the defendant by the plaintiff under the terms of which the plaintiff agreed to extend to defendant the use of plaintiff's credit facilities. 3. Defendant 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 received and accepted goods and merchandise and/or accepted services or cash advances through the use of the credit card issued by the Plaintiff. 5. All the credits to which the defendant is entitled have been applied and there remains a balance due in the amount of $3,729.31. 6. Plaintiff has made demand upon the defendant for payment of the balance due of $3,729.31 but the defendant has failed and refused and still refuses to pay the same or any part thereof. 7. Defendant's last payment on account was made on July 7, 2003. WHEREFORE, plaintiff claims of the defendant the sum of r $3,729.31 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: ' FREDERIC I WE BERG, ESQUIRE PAUL M. SC LD, JR., ESQUIRE Attorney for Plaintiff POlA.DB VERIFICATION FREDERIC I. WEINBERG, ESQUIRE, hereby states that he is the attorney for the Plaintiff 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. EIN RG, ESQUIRE ~? ..O cy ~ -s, t^ ~~ W ~ ~ _ rv ,_,Fr , . ~ t_. ~ .~ .. T - -~- _ , ~ ~ , _ ~, , :~ ,~ ~ ~, SHERIFF'S RETURN - NOT FOUND CASE NO: 2007-03705 P ..COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND NCO PORTFOLIO MANAGEMENT VS BRAXTON JAHYSON L 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 BRAXTON JAHYSON L but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT & NOTICE the within named DEFENDANT NOT FOUND as to BRAXTON JAHYSON L 5146 ERBS BRIDGE ROAD MECHANICSBURG, PA 17050-2432 PER POST OFFICE, DEFENDANT MOVED AND LEFT NO FORWARDING ADDRESS. Sheriff's Costs: Docketing 18.00 Service 9.60 Not Found 5.00 Surcharge 10.00 .00 4~~g~~1 42.60 So answers: ~'~ ~ R. Th as Kline S eriff of Cumberland County GORDON & WEINBERG 06/26/2007 Sworn and Subscribed to before me this day of A.D.