HomeMy WebLinkAbout07-3725IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
UNIFUND CCR PARTNERS
c/o Edwin A. Abrahamsen & Associates, P.C.
120 North Keyser Avenue
Scranton, PA 18504
Plaintiff
CIVIL ACTION
NO: 3725 t u 1.?)
VS.
JANET M BLACK
533 S HANOVER ST
CARLISLE PA 17013 Defendant
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 to
Defend are served, by entering a written appearance personally or by an 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT `dVHERE YOU CAN GET LEGAL HELP.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE
TO PROVIDE YOU WITH INFORMATION ON AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT REDUCED FEE OR NO FEE.
MIDPENN LEGAL SERVICES
401 EAST LOUTHER STREET CARLISLE, PA 17013
(800) 932-0356 Oft (717) 243-9400
FAX: (717) 243-8026
IN THE COURT' OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
UNIFUND CCR PARTNERS
c/o Edwin A. Abrahamsen & Associates, P.C.
120 North Keyser Avenue
Scranton, PA 18504
Plaintiff
VS.
JANET M BLACK
533 S HANOVER ST
CARLISLE PA 17013
CIVIL ACTION
NO: 07 - 3 7;L5
Defendant
COMPLAINT
?c u?L`7-mot
Plaintiff, Unifund CCR Partners, by and through its attorneys, Edwin A. Abrahamsen &
Associates, P.C., complains of the Defendant as follows:
1. Plaintiff, UNIFUND CCR PARTNERS c/o Edwin A. Abrahamsen &
Associates, P.C., (hereinafter "Plaintiff") is a Pennsylvania corporation with a principal place of
business located at 120 North Keyser Avenue Scranton, PA 18504.
2. The Defendant JANET M BLACK (hereinafter "Defendant") is an adult
individual residing at 533 S HANOVER ST CARLISLE PA 17013.
3. At all relevant times herein, Plaintiff was engaged in the business of debt purchase
and collection.
4. Defendant applied for and received a credit card issued by FIRST USA BANK
with the account number 4417128074554344.
5. The within account was opened by Defendant with account number
4417128074554344 and was sold by FIRST USA BANK to Unifund for valuable consideration
and all rights under said accounts were assigned to Unifund. (See, Bill of Sale, Affidavit and
Assignment attached hereto as Exhibit "A.")
7. Use of the FIRST USA BANK credit card was subject to the terms of the
Cardmember Agreement, a copy of which was sent to the Defendant along with the credit card.
(See, Copy of Cardmember Agreement, attached hereto and marked Exhibit "B.")
8. Defendant used the FIRST USA BANK credit card account number
4417128074554344, for purchases, cash advances and/or balance transfers.
9. The Defendant was mailed account statements relative to the Defendant's use of
the subject credit card.
10. The Defendant defaulted under the terms of the Agreement by failing and refusing
to make monthly payments on the account as they became due.
11. The account became delinquent on July 11, 2003.
12. The principal amount was $12,230.22 at the time it was received by Plaintiff.
13. Pursuant to the account agreement, any unpaid balance accrues interest at the rate
of 14.99.
14. The total amount due and owing the Plaintiff including interest, is $19,986.27.
15. Pursuant to the terms of the Agreement, Defendant is liable for Plaintiffs court
costs and reasonable attorney's fees in the amount of 25% of the balance.
WHEREFORE, Plaintiff requests j udgment in its favor and against Defendant in
the amount of $19,986.27 plus costs of suit, reasonable attorneys' fees of $4,996.68 and any other
relief as the Court deems just and appropriate.
Respectfully submitted,
Edwin A. Abrahamsen & Afi6ciates, P.C.
Michael F. Ratchford, E ire
Scott J. Best, Esquir
Attorney I.D. Nos.: 86285/93600
120 N. Keyser Avenue
Scranton, PA 18504
VERIFICATION
I, Michael F. Ratchford, attorney for Plaintiff, Unifund CCR Partners, am fully familiar
with the facts set forth in the within Complaint and am authorized to make this Verification on
behalf of Plaintiff. I Verify that the facts set forth in the within allegations are true and correct to
the best of my knowledge, knowing that any false statements are punishable by law pursuant to
18 C.S.A. 4904.
Page I of I Dec 28 2005
Statement for account number: 441 7 1280 7455 4344 QANK=ONE.
New Balance Payment Due Date Past Due Amount Mlrimurl Payment ii/?7
$0.00 12i26N3 $0.00 $c=
Amount Enclosed 11141aesyouralrekllaYabbb Bank One
N81r aotlresa or e-trlae7 Pmt 7n hOCN.
441712E07455434400000000000000006
CARDMEMBER SERVICE JANET M SLACK AVE
P.O. BOX 16163 29 MAPLE
HANCVERPA
?A 17331-5111
WILMINGTON DE 19906-6 1 63
11,1111, A.M... III
1: 5000 160 281: 2 2 1 8D 7 4 5 54 344 1110
-
t
Slaterrrar6Date. 1r221-3.11130•-3 CUSTOMERSERVICE
Q 0
F
ONE
N0 Payment Due Data 12r25fi3 Inns. 1800-436-7927
1
? r.
?/
Y!7 Minimum Papnant Due: $0.00 EspaM1Ol 1-888-4463308
TDD 1.900-9668060
Outside U.S. call mllact
1 302 594.8200
VISA ACCOUNT SUMMARY Account Number. x41712 80 74664544
Previous Balance $12230.22 Total Cracit Tina 510,000 AccOBwirsta Btms
Payments, Credits • $12230.22 Available Credit $0 P.O eo. ease
Purchases, Cash. Debits + $0.00 :ash Access Line $2,000 W"rglen' Ds tae11-roea
Finance Charges . $0.00 Available for Cash $0 PAYMMT ADDRESS
New Balance $0.00 Po sa. 15112
W -g. , De leeeea1M
na1T us Ar.
w.eabnambnrn t-
TRANSACTIONS
Trans Amount
Dale Reference Number Merchant Name or Transaabil DescrPtIon Credit Cebit
1'..30 F338SC40ADOW92OW CHARGE OFF ACCOUNT-PRINCIPALS 9.807.14
1+.341 F126600AD009099W CHARGE OFF ACCOUNT 'FINANCE CHARCES• 2329.08
FINANCE CHARGES PERIODIC RATE(SI ANDAPR(S) MAY VARY
Dail Comspon-ft AN Inane Charge
Periodic sts APR Average Daily Balance Due To Transaction FINANCE
Category 09 cat's In oyce Previous Cyole Cunerd Cycle Periodk Rate Fees CHARGES
Purchases .04107% 14.99% - - - - $0.00
Cash advances .04107% 14.99% - - $0.00
Total finance charges $0.00
Effective Amual Percents" Ran (APR): WA
Grace Period Tyoe: B (Rease see back otstaternent for the Grace Period explanation.?
The Corresponding APR is the rate of interest you pay when ycu carry a balance on purchases or cash advanes.
The Fffectiva APR represents your Total finance charges - including transaction fans such as cash adviin:e and balance transfer
lees - expressed As a percentage.
T1103086 WATCH WORLDS APART ON THE NATIONAL GEOGRAPHIC CHANNEL AND
SEE WHAT HAPPENS WHEN AMERICAN FAY (LIES A RE AIRLIFTED TO
REMOTE COUNTRIES FOR A MASH COURSE IN CULTURAL DIVERSITY.
WORLDS APART AIRS MONDAYS ATs P.M. ET.9 PM. PT
ON THE NATIONAL G E03RAPHIC CHANNEL
T 11031$6 SAVE TIME AND A STAMP[ TO MAKE YOUR PAYMENT JUST LOGON'TO
YOUR ACCOUNT AT W W W.CARrMEVBERSE-RVICES.COM AND SELECT
"MAKE PAYMENT ONLINE' FROM THE MENU. YOUR PAYMENT WILL BE
POSTED WITHIN ONE BUSINESS DAY AND THERE ARE NO FEES FOR
THESE SERVICESI
71103137 PAY MONTHLY BILLS AUTOMATICALLY. CONTACT YOUR SERVICE
PROVIDERS ANDASK TO SET UP AUTOMATIC PAYMENTS WITH YOUR
BANK ONE VISA CARD. YOU'LL SAVE TIME AND HASSLE EVERY MONTH
FOR MORE INFORMATION, VISIT WWW.CARC MEMBERSERV ICES.COM
AND CLICK ON SILL MANAGER.
This Statement is a Facsimile - Not an Original
5636 0600 1553 see s is 41311311 2XPass 1 of 1 53" 3414141 30111406 of sssss
C)04 It 9 IT
AFFIDAVIT OF INDEBTEDNESS
State of Ohio )
County of Hamilton) ss.
Kim Kenney being sworn, deposes and says that she is Media Supervisor of Unif ind CCR Partners herein
called assignee, which is doing business at 10625 Techwoods Circle, Cincinnati, Ohio 45242 and the
statements and representations herein are within her personal knowledge.
The defendant is not in any branch of the military.
There is due and payable from JANET M BLACK, Account Number 4417128074554344, the amount of
$19589.47 (principal balance in the amount of $12230.22 plus interest up through 04/10/2007 in the
amount of $7359.25). By the terms of the agreement between the defendant and the original creditor,
interest is accruing from the aforesaid date at the rate of 14.99 percent per annum. This balance reflects any
payments, credits or offsets made since the account was charged off.
Chase Manhattan Bank USA NA's account was issued under the name of FIRST USA BANK. Unifund
CCR Partners purchased this account from Chase Manhattan Bank USA NA Said account has been
referred to Law Ofcs of Edwin A Abrahamson & A with full power and authority to do and perform all acts
necessary for the collection, settlement, adjustment, compromise or satisfaction of said claim.
DATED this April 10, 2007
1--- r'-V %J 001" CCR PARTNERS
By: Kim Kenney
Media Supervisor
10625 Techwoods Circle Cincinnati. OH 45242
Address
and swt to bef&kAie this 10 day of 2007
Year
My commission Expires
?p,RIAI
\??.'
\
G
J ENNIFER A. DUNCAN
NOTARY PUBLIC
--' STATE OF OHIO
Client # 1300
?g:r" 5 Comm. Expires
July 04, 2007
EX14 16 IT A
1300
ACCOUNT NUMBER BALANCE AS OF PAYMENT DUE DATE MINIMUM PAYMENT PAYMENT ENCLOSED
0411 0/2007
4417128074554344 19,589.47 PAST DUE 19,589.47
Mx Checks Pap le To Unllbnd
UNIFUND STATEMENT
JANET M BLACK
533 S HANOVER ST
CARLISLE PA 17013
I MESSAGE FROM UNIFUND
YOUR ACCOUNT IS PAST DUE $19,589.47. THE PAST DUE AMOUNT IS INCLUDED IN THE MINIMUM PAYMENT. PLEASE REMIT
IMMEDIATELY. IF YOU HAVE ALREADY SENT A PAYMENT FOR THE ABOVE AMOUNT,THANK YOU.
TRANSACTIONS:
Date Transaction IR Balance Due Payments New Balanc
0411 WOW Chase Manhattan Bank USA NA's 0.1499 19,589.47 19,589.47 0 19,589.47
Account Was Issued Under The
Name Of FIRST USA BANK.
PROMPT CREDITIN0 OF PAYMENTS. TO RECEIVE CREDIT FOR PAYMENTS AS OF THE
DATE OF RECEIPT, WE MUST RECEIVE YOUR CHECK OR MONEY ORDER AT:
UNIFUND
10625 TECHWOODS CIRCLE
CINCINNATI, OH 45242
PAYMENTS RECEIVED AT THE ABOVE ADDRESS IN THE MANNER SPECIFIED AFTER THAT
TIME WILL BE CREDITED TO YOUR ACCOUNT AS OF OUR NEXT BUSINESS DAY. THE
CREDITING TO YOUR ACCOUNT OF PAYMENTS RECEIVED AT ANY LOCATION OTHER THAN
THE ABOVE ADDRESS MAY BE DELAYED UP TO 5 DAYS OF RECEIPT.
THIS COMMUNICATION IS FROM A DEBT COLLECTOR. FEDERAL LAW REQUIRES US TO INFORM YOU THAT
THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT
PURPOSE.
Kit3 iT
BILL OF SALE
Omme Maabom Book USA, N.A. (as a{tit'cemor Rough merger with Bank One,
Detaa wasre, Kk) e Sella-,% fir value received and pmt to the term and tons of
Qv& cwd Amt pmehm Agr+*=mt dated October 26, 2004 between Saar and Umfund
Paijtnams t"Tuithawl its sucoemn and sasigm ("C iuk Cad Account Psarchm
AgreeammM haar+aiby am eflSmodve as of to off Dow of July 12,2005, A rifts, title ad
interest of Sete is and In Ihow oftuin r oinbks„ judrnents or evidences of debt described m
ZAftft I a taobsed lie r to and made part heeof for all "ossm
Ass QUDft disc to Seller by Purobasec in berms shalt be paid U.S. Dollars by at wire ta=sfer to
be tw4ived by Seller on MY 26.200S (94 "Closing Date") by 2.00 p m. Seller's Woe, as
follows:
J %orpn gust Do*
RIBA a1C2 400M
ElaHiicUry NanW CM06 MasdalU Ml Bank US1l,NA
BsanMiclery Aoc cuss 4304466M
TMs Bill of Sak is executed witbaiit ruse cxoW aat smtnd m the Ckmdk Cwd Account
P a timse A ncnt to which this is an Exldbit. No odwr top meentation of or warranty of tide or
enforcembdity is e Mused or iraa d.
Grasse t1+ isnbatt uu Bank USA, N.A. lrWfiWdCCR
BY.
Date: 14,2005 lie:
Title: VWC hmd= `T'ide
cfq(g 1< A
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LAW OFFICES
Erwin A. AiBfuHmSEN
AsSOCIATES, F.C.
120 N. Keyser Avenue • Scranton, FA 18504
Toll Free: 1-800-503-1665 Fhone: 570-558-5510 lax: 570-558-5511
June 19, 2007
Cumberland County Sheriffs
1 Court House Sq.
Carlisle, PA 17013
Re: Unifund CCR Partners vs. JANET M BLACK
Our file Nos.: U07-0084
Dear Sheriff:
In regard to the above-noted matter, enclosed please find the following:
1. A true and correct copy of the Complaint;
2. The completed form for service;
3. A check for service;
4. A self-addressed return envelope for the return of service.
Please serve the named defendant in accordance with the County Rules of Civil
Procedure. If you should have any questions or concerns, please do not hesitate to call me at
(570) 558-5510.
The defendants address is : JANET M BLACK 533 S HANOVER ST CARLISLE PA
17013
Thank you for your attention to this matter.
Edwin A. Abrahamsen & Associates, P.C.
Michael F. Ratchford, 're
Enclosures
mfr/MR
41 `.
n'r r
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SHERIFF'S RETURN - NOT FOUND
CASE NO: 2007-03725 P
COMMONTWEALTH OF PENNSYLVANIA
`COUNTY OF CUMBERLAND
UNIFUND CCR PARTNERS
VS
BLACK JANET M
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
BLACK JANET M but was
unable to locate Her in his bailiwick. He therefore returns the
COMPLAINT & NOTICE
the within named DEFENDANT
533 _S HANOVER STREET
BLACK JANET M
NOT FOUND , as to
CARLISLE, PA 17013
DEFENDANT LIVES IN HANOVER. NEVER RECEIVED REINSTATED
COMPLAINT TO BE SERVED IN HANOVER.
Sheriff's Costs:
Docketing 18.00
Service 4.80
Affidavit 5.00
Surcharge 10.00
.00
Q,.., cl IUIb1 37.80
So answer
`R. Thomas Kline
Sheriff of Cumberland County
EDWIN ABRAHAMSEN & ASSOCIATES
09/12/2007
Sworn and Subscribed to before
me this day of
A. D.
Unifund CCR Partners
1729 Pittston Avenue
Scranton, PA 18505
Plaintiff
Vs.
In the Court of Common Pleas of
: Cumberland County, Pennsylvania,
Civil Division
No: 07-3725-Civil Term
Janet M Black Praecipe to Reinstate
28 Maple Ave the Civil Complaint
Hanover, PA 17331
Defendant
To the Prothonotary of Cumberland County Pennsylvania:
Please enter the above Praecipe to Reinstate Civil Complaint.
Thank you,
Michael F. R
Edwin A. At
Lawyer ID 4
& Associates, P.C.
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SHERIFF'S RETURN - OUT OF COUNTY!
CASE NO: 2007-03725 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
UNIFUND CCR PARTNERS
VS
BLACK JANET M
R. Thomas Kline , Sheriff or Deputy
duly sworn according to law, says, that he made a
and inquiry for the within named DEFENDANT ,
BLACK JANET M
but was unable to locate Her in his bailiwick.
deputized the sheriff of YORK County
serve the within COMPLAINT & NOTICE
Sheriff who being
iligent search and
to wit:
He therefore
Pennsylvania, to
On January 30th , 2008 , this office was inkreceipt of t
attached return from YORK
Sheriff's Costs: So answers-
Docketing 18.00
Out of County 9.00
Surcharge 10.00 R. Thomas Kline
Dep York County 44.21 Sheriff of Culr
Postage 1.48
8 2. 6 9 ? -)/0
01/30/2008
EDWIN ABRAHAMSEN & ASSOCIATES
Sworn and subscribe to before me
this day of ,
gland County
A. D.
COUNTY OF YORK
OFFICE OF THE SHE IFF SERVICE CALL
45 N. GEORGE ST., YORK, PA 17401
SHERIFF SERVICE 1MTWXrWft
PROCESS RECEIPT and AFFIDAVIT OF RETURN PLEA$E YPE ONLY LW 1 TMU 12
Do T MACH AM COMS
,. PLAINTIFF151 2. COURT NUMBER
Unifund CCR Partners _ 07-3725 civil
3 DEFENDANT/S/
4.
-?-
TYPE OF WRIT OR COMPLAINT
Janet M. Black Notice and Complaint C I CA
SERVE 5 NAME OF INDIVIDUAL, COMPANY. CORPORATION, ETC TO SERVE OR DESCRIPTION OF PR PERTY TO BE LEVIED, ATTACHED, OR SOLD
Janet M. Black
6 ADDRESS (STREET OR RFO WITH BOX NUMBER. APT NO., CITY. BORO. TWP, STATE AND IP CODE)
AT 28 Maple Avenue Hanover, PA 17331
7. INDICATE SERVICE' U PERSONAL U PERSON IN CHARGE )MEPUTIZE U ET L U 1 T CLASS MAIL U POSTED U OTHER
NOW December 28 20 07 I, SHERIFF OF COUNTY PA, doh by deputize
theeriff of
York COUNTY to execute this W
return the ing
to law. This deputization being made at the request and risk of the plaintiff.
,
lp?
SHERIFF OF UNTY
8. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE
.
OUT OF COUNTY
Cumberland
ADV FEE PAID BY CUMBERLAND CO SHERIFF
Please mail return of service to Cumberland County S heriff. Thank you.
NOTE: ONLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN - Any deputy sheriff levying upon or a thing any property under within writ may leave same
without a watchman, in custody of whomever is found in possession, after notifying person of levy or attachment, without liability the part of such deputy or the sheriff to any plaintiff
herein for any loss, destruction, or removal of any property before sheriffs sale thereof.
9. TYPE NAME and ADDRESS of ATTORNEY / ORIGINATOR and SIGNATUREM I C H A E L F . R A H ?LEPHONE NUMBER DATE FILED
120 N. KEYSER AVE., SCRANTON, PA 18504 F
'
----------- 12-26-200
12. SEND NOTICE OF SERVICE COPY TO NAME AND ADDRESS BELOW: (This area must be completed if notice is to be ma iled)
CUMBERLAND CO S HERIFF
SPACE BELOW FOR USE OF THE SHERIIFF - DO NOT WRITE WILOW TM LM
13. 1 acknowledge receipt of the writ 1 4. DATE RECEIVED 15. ExpiratioNHearing Date
or complaint as indicated above. M J M C G I L L Y C S Q 11 2-31-2007 1 1-25-2008
16. HOW SERVED PERSONAL" RESIDENCE ( ) POSTED( ) POE( ) SHERIFF'S OFFICE . ( ) OTHER ( ) SEE REMARKS BELOW
17. O 1 hereby certify and return a NOT FOUND because I am unable to locate the individual, company, etc. named above. (See remarks below.)
18. NAM O TITLE OF INDIVIDUAL SERVED / LIST A DRESS HERE IF NQT SHOWN ABOVE (Retationstu to Defendant) 19. Date of Service 20 Time of Service
IN- 7
21. ATTE S Date Time Miles Int. Date Time Miles Int. Date Time Miles Inl. Date Time Miles Int. Dale T Int. Date Time Miles Int.
22. REMARKS:
23. Advance Costs 24 Service Costs 25 N/F 26. Mileage 27. Postage 28. Sub Total 29. Pound 30. Notary 3 . Surchg. 32 Tot. Costs 33 Costs Due Rebind Check No
$100.00 • 60 .
_ -' 5
34. Foreign County Costs 35. Advance Costs 36 Service Costs 37. Notary Cert. Mdeage/PostagetNot Found 39. ota Costs 40. Costs Due or Refund
41. AFFIRMED and subscribed to bet me this h 30 S
42. day of OMfU?Q1?5?LT 44. Signature of
Dep. Sheriff
2 6 45. DATE
NOTARIAL SEAL 46. Signature of York
County Sheriff 47. DATE
LISA L. BOWMAN, NOTARY PUBLIC
CITY OF YORK, YORK COUNTY RICHARD P. K E _ E S E IFF 1-17-2008
MY COMMISSION EXPIRESAUG. 12, 20'!?,9 48. Signature of Foreign 49 DATE
County Sheriff
F
91
,, - ? . _
„ • . ,
;,.,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
UNIFUND CCR PARTNERS
Plaintiff
CIVIL DIVISION
vs.
JANET M BLACK
Defendant
NO: 07-3725 CIVIL TERM
PRAECIPE FOR ENTRY OF DEFAULT JUDGMENT
TO THE CLERK OF JUDICIAL RECORDS:
Kindly enter judgment by default for failure to respond to Plaintiff's Complaint in the
amount of $20,486.27, which includes reasonable attorneys' fees. Notice of the intent to file a
default judgment was served upon the Defendant on Februaiy28,2008. A copy of the Notice of
Intent to Take Default Judgment is attached hereto and marked Exhibit "A."
Edwin A. Abrahamsen & Associates, P.C.
Michael F. Ratchfor squi
Attorney I.D. No 6285
Attorney for Pl intiff
JUDGMENT
AND NOW, this ap'p'` day of , 200Qg, Judgment is hereby entered in favor
of the Plaintiff and against the Defendant in the am nt of $20,486.27, which includes
reasonable attorneys' fees for failure to respond to Plaintiff s Complaint.
PROTHONOTA P-N/
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
UNIFUND CCR PARTNERS
vs.
JANET M BLACK
Plaintiff :
Defendant
CIVIL DIVISION
NO: 07-3725 CIVIL TERM
CERIFICATE OF SERVICE
I, Michael F. Ratchford, Esquire, hereby certify that on the date indicated below, I served
a copy of the Praecipe for Entry of Default Judgment in the above captioned matter by mailing
the same via First Class United States mail, postage prepaid addressed as follows:
JANET M BLACK
28 MAPLE AVE
HANOVER PA 17331-5111
Edwin A. Abrahamsen & Associates, P.C.
Date:
Michael F. Ratchford,
Attorney I.D. No.: 8
120 Keyser Avet?
Scranton, PA 18504
(570) 558-5510
UNIFUND CCR PARTNERS
Vs.
JANET M BLACK
State of Pennsylvania
County of CUMBERLAND SS:
In the Court of Common Pleas of
Plaintiff CUMBERLAND County, Pennsylvania
Civil Division
NO: 07-3725 CIVIL TERM
Defendant AFFIDAVIT UNDER SOLDIERS AND SAILORS
RELIEF CIVIL RELIEF ACT OF 1940 AS
AMENDED
Michael F. Ratchford, Esquire being duly sworn according to law deposes and says that the
above named defendant(s): JANET M BLACK; is(are) not in the military service of the United
States of America as defined by the Soldiers' and Sailors' Civil Relief Act of 1940 as amended;
That the defendant(s): JANET M BLACK; is(are) older than eighteen years of age;
That the employment status of the defendant(s): JANET M BLACK; is(are) unknown.
Subscrib T before me this 6:f?? of
n ?Ti?T Y 20
Nota Pu is?'
G U
?- 0,
O,fi
41 Q1 G
EDWIN A. ABRAHAMSEN
MICHAEL F. RATCHFORD
SCOTT J. BEST'
*ALSO MEMBER OF NJ BAR
LT
THE LAW OFFICE OF
EDWIN A. ABRAHAMSEN & ASSOCIATES, P.C.
WWW.EAA-LAW.COM
February 28, 2008
JANET M BLACK
28 MAPLE AVE
HANOVER PA 17331-5111
Re: UNIFUND CCR PARTNERS v. JANET M BLACK
CUMBERLAND County Civil Action No.: 07-3725 CIVIL TERM
Dear JANET M BLACK :
Enclosed please find the Ten Day Notice of Intent to Take Default in regard to the above-
noted matter. Please act accordingly.
If you have any questions or wish to discuss your outstanding account, please contact me
at (570) 558-5510.
Edwin A. Abrahamsen & Associates,
Michael F. Ratchf , Esquire
15
Enclosure
This is a communication from a debt collector in an attempt to collect a debt. Any information
will be used for that purpose.
1 729 PITTSTON AVE. 6 SCRANTON. PA 18505 • (P) 570.55$.551 0 • (F) 570.558.551 1
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
UNIFUND CCR PARTNERS
Plaintiff
: CIVIL ACTION
VS.
JANET M BLACK NO: 07-3725 CIVIL TERM
Defendant :
TEN DAY NOTICE OF INTENT TO TAKE DEFAULT JUDGMENT
To: JANET M BLACK
28 MAPLE AVE
HANOVER PA 17331-5111
Date of Notice: February 28.2008
IMPORTANT NOTICE PURSUANT TO .C.PL.2 37.1 a j"2
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER AN
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.
MIDPENN LEGAL SERVICES
401 EAST LOUTHER STREET
CARLISLE, PA 17013
717-243-9400
S
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
UNIFUND CCR PARTNERS
CIVIL ACTION
Plaintiff
vs.
JANET M BLACK : NO: 07-3725 CIVIL TERM
Defendant
CERIFICATE OF SERVICE
I, Michael F. Ratchford, Esquire, hereby certify that on February 28, 2008 I served a copy
of the Ten Day Notice of Intent to Take Default in the above captioned matter by mailing the
same via First Class United States mail, postage prepaid addressed as follows:
JANET M BLACK
28 MAPLE AVE
HANOVER PA 17331-5111
Edwin A. Abrahamsen & Associates, P.C.
ar
Michael F. Ratchford, Es ire
Attorney I.D. No.: 5
1729 Pittston Avenue
Scranton, PA 18505
(570) 558-5510
p jp
q
$ cy `X3
nlF
00
UNIFUND CCR PARTNERS
In the Court of Common Pleas of
Plaintiff CUMBERLAND County, Pennsylvania
Civil Division
vs.
JANET M BLACK
Defendant . NO: 07-3725 CIVIL TERM
NOTICE OF FILING JUDGMENT
Notice is herby given that a money judgment in the above-captioned matter has been entered
against you in the amount of $ ,W y g &7 on 5?(o%g
By:
If you have any questions regarding this notice, please contact the filing party:
Edwin A. Abrahamsen & Associates
1729 Pittston Avenue
Scranton, PA 18505
Telephone: (570)-558-5510
(Notice is given in accordance with PA Supreme Court Rule of Civil Procedure No. 236)
. r.
UNIFUND CCR PARTNERS
In the Court of Common Pleas of
Plaintiff CUMBERLAND County, Pennsylvania
Civil Division
vs. C '
-} -n
JANET M BLACK
28 MAPLE AVE NO: 07-3725 CIVIL T
HANOVER PA 17331-5111
Defendant
Answers to 7
INTERROGATORIES IN T
VS. ATTACHMEN
co
-C
M&T BANK
28 WALNUT BOTTOM RD
SHIPPENSBURG PA 17257-8219
Garnishee
RE: Execution of Judgment against your depositor JANET M BLACK SSN # 187-34-7518
You are required to file answers to the following interrogatories within twenty (20) days after
service upon you. Failure to do so may result in judgment against you:
1) At the time you were served or at any subseqent time, did the Defendant possess
any bank accounts, joint or individual, that were in your custody or control?
Please specify joint or individual account. Please list the legal title of any such
account(s) an dthe primary account holder and if known whether joint account is
entireties property.
2) At the time you were served or at any subsequent time, what was the balance and
account number of the bank accounts(s) identified in Interrogatory #1?
3 At th i 6\
the t me you were served or at any subsequent time, please list the average
daily balance in the past five (5) months for each such account identified in your
answer to Interrogatories number one (1) and two (2) above. `(\ \\?
4) At the time you were served or at any subsequent time, did the bank account(s)
that the Defendant possessed contain fund derived solely from social security
funds and/or disability funds?
5) At any time before or after you were served, did the Defendant(s) transfer or
deliver any property or money to you or to any person or place pursuant to your
direction or consent, and if so, what was the consideration therefore?
Al\?
6) At any time after you were served, did you pay, transfer or deliver any money or
property to the Defenda.nt(s) or to any person or place pursuant to the Depositor's
direction or otherwise discharge any claim of the Depositor against you?
7) At the time you were served or any subsequent time, did you have, share, or
utilize any safe-deposit boxes, pledges, documents of title, securities, notes,
coupons, receivable, license, or collateral in which there was an interest claimed
by Defendant(s)?
v,
8) At the time you were served or at any subsequent time did the Defendant(s)accoount
contain funds deposited electronically on a recurring basis and which are identified
as being exempt from execution, levy or attachment. If so, state the reason for the
exemption, the amount being withheld and the entity electronically depositing
those funds on a recurring basis.
n\?
4) At the time you were served or at any subsequent time did the defendant have funds
on deposit in an accoun in which the funds on deposit, not including any otherwise
exempt funds, did not exceed the amount of the general monetary exemption under
42 Pa.C.S. Section 8123? If so, identify each account. \
10) Identify every other account (not previously noted) titled in the name of the
Defendant(s) in which you believe the Defendant(s) have an interest in whole of
part, whether or not styled as a payroll account, individual retirement account, tax
acocunt, lottery account, partnership account, joint or tenants by entirety account,
insurance account, trust or escrow account, attorney's account, or otherwise.
11) To the extent that you're above answers depend in whole or part on documents,
account records, or other papers or electronic data, describe each in exact detail
(or attach a copy of the same).
lip `? 8PS'?K
tJ??'
f' 31
Edwin A.,,kbrahamsen & Associates, P.C
f Michael F.I?aatchford,
120 North Keyser Ave
201 Scranton, PA 18504
(570) 558-5510 Ext. 1
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
Unifund CCR Partners
vs.
Janet M Black
~4`i"CO e1 ~fautbrr~~r~~
~ ~~, ' ~..
t~FfiCE C r r•;~ S~RIFF
FlLEU-~~i~r"`-IC~
~~ t~'~ 3 ~ ~~'~ ~~ ~~
ff"~~Yf V~J~~~.71'41 YV1
Case Number
2007-3725
SHERIFF'S RETURN OF SERVICE
08/30/2010 09:26 AM -Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on August 30,
2010 at 0926 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies
of the within named defendant, to wit: Janet M. Black, in the hands, possession, or control of the within
named garnishee, M & T Bank, 1 W High Street, Carlisle, Cumberland County, Pennsylvania, 17013 by
handing to Connie S. Negley, Assistant Vice President, personally three copies of interrogatories together
with three true and attested copies of the writ of execution and made the contents there of known to her.
The writ of execution and notice to defendant was mailed on August 31, 2010 to Janet M. Black at 28 Maple
Avenue, Hanover, PA 17331-5111.
SO ANSWtER'S~,
G~- ~i`"~
August 31, 2010 RON R ANDERSON, SHERIFF
Y~
Noah Cline, Deputy
(ci CountySuite Sheriff. Teleosoft. li~c.
UNIFUND CCR PARTNERS
Plaintiff
vs.
JANET M BLACK
28 MAPLE AVE
HANOVER PA 17331-5111
Defendant
vs.
M&T BANK
28 WALNUT BOTTOM RD
SHIPPENSBURG PA 17257-8219
Garnishee
In the Court of Common Pleas of
CUMBERLAND County, Pennsylvania
Civil Division
NO: 07-3725 CIVIL T
° c7N
Praecipe to Dissolve the Attachment aga
Garnishee
To the Prothonotary of CUMBERLAND County Pennsylvania:
Please enter the above Praecipe to Dissolve the Attachment against Garnishee.
Thank you,
Michael F. Ratchford, Es,
Edwin A. Abrahamsen &
Lawyer ID # 86285
Sworn and
P.C.
before me on this ?daay of 20
L erricone, Notary Public
NOTARIAL SEAL
LEE PERRICONE
Notary Public
SCRANTON CITY, LACKAWANNA COUNTY
My Commission Expires Apr 2. 2014
y/??
/,7~&/
NO
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
j
C7?'F E ; "sF?
m r°
Unifund CCR Partners, Assignee of Citibank
vs. Case Number
Janet M Black 2007-3725
SHERIFF'S RETURN OF SERVICE
08/30/2010 09:26 AM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on August 30,
2010 at 0926 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies
of the within named defendant, to wit: Janet M. Black, in the hands, possession, or control of the within
named garnishee, M & T Bank, 1 W High Street, Carlisle, Cumberland County, Pennsylvania, 17013 by
handing to Connie S. Negley, Assistant Vice President, personally three copies of interrogatories together
with three true and attested copies of the writ of execution and made the contents there of known to her.
The writ of execution and notice to defendant was mailed on August 31, 2010 to Janet M. Black at 28
Maple Avenue, Hanover, PA 17331-5111.
03/11/2011 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is
returned as ABANDONED. No action on writ in over 6 months.
SHERIFF COST: $87.50
March 11, 2011
. sp L t_ /4,(
??' ?1C1y?' !1r'
` 2
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
(ri CcuntySu¢e Shenff, Tei?:csoft. Inc.
SO ANSWERS,
RON R ANDERSON, SHERIFF