HomeMy WebLinkAbout07-3782IN 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.
CIVIL ACTION
NO: 07 - 3-yF;L,
VERONICA KLINE
956 WERTZVILLE RD
ENOLA PA 17025 Defendant
e;Wf-?
`
NOTICE TQ 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 WHERE 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 STREI:T CARLISLE, PA 17013
(800) 932-0356 OR (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.
VERONICA KLINE
956 WERTZVILLE RD
ENOLA PA 17025
CIVIL ACTION
NO:
Defendant
COMPLAINT
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 VERONICA KLINE (hereinafter "Defendant") is an adult
individual residing at 956 WERTZVILLE RD ENOLA PA 17025.
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 FUSA -PLATINUM
CNNCT ACQ with the account number 5417116931134357.
5. The within account was opened by Defendant with account number
5417116931134357 and was sold by FUSA -PLATINUM CNNCT ACQ to Unifund for valuable
consideration and all rights under said accounts A;, ere assigned to Unifund. (See, Bill of Sale,
Affidavit and Assignment attached hereto as Exhibit "A.")
7. Use of the FUSA -PLATINUM CNNCT ACQ 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 FUSA -PLATINUM CNNCT ACQ credit card account
number 5417116931134357, 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 January 14, 2005.
12. The principal amount was $15,083.38 at the time it was received by Plaintiff.
13. Pursuant to the account agreement, any unpaid balance accrues interest at the rate
of 25.24.
14. The total amount due and owing the Plaintiff including interest, is $27,074.30.
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 judgment in its favor and against Defendant in
the amount of $27,074.30 plus costs of suit, reasonable attorneys' fees of $6,768.58 and any other
relief as the Court deems just and appropriate.
Respectfully submi
Edwin A. Abrahamsen & o'iates, P.C.
Michael F. RatchfordV285193 ire
Scott J. Best, EsquiAttorney I.D. Nos.: 600
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 aathorized 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 2 of 2 Oct 112006
Statement for account number; 5417 1169 3113 4357 ANK OHE
Now Balance Payment Due Date oas' Due Amount Mininum Payment il/?
$0.00 09r25104 so.00 tD.00
117 R-I 0'rle
Amount Enclosed ?NocN C911elcpa G t r
N- Cx-a dnrr Cr etr1e17 o.n back. k 0
54171169311343570011000000001100001
'VE RONICA J KLN E
CARDMEMBER SERVICE 956 WERTZVILLE RD
P.O. BOX 15153 ENOLA PA 17025.1835
WILMN 5T ON DE 19885515.3
list 111111111111111111111t111111111111111411111111111111111111 In1111n1111un111111t1nnIlln1n111u111u111nl1n1n111
1:5000 i60 281: 2 25693 1. 31.3546tr
Statement Dale: 08 e6104-08131 04 CUSTOMER SERVICE
E
BANK
ON Payment Due Date: 08/04 In U.S. 1.800.436-7927
= Minimum Payment Due: $0 $0..00 Espatld 1-888-4455308
TDD 1-800-965-8066
Outside U.S. call collect
MASTERCARD ACCOUNT SUMMARY Account lYanbel- 5417 1109 3113 431117 1302-594-82D0
Previous Ralarea $15,283.38 Total Credh Una 513,003 AccoUNTNQuREs
Payments, Credits -$12.499.43 Available Credit $0 P_o. eca 0101
Purch aces, Cash, Do :)Ks + $0 00 Cash Access Line $2,600 W Irgt- DE 100".96sc
Finanas Charges . $0.30 Available for Cash so PAYMWT
ADDRESS
New Belencs $0.00 1
p - 0. se . a 1DE
vrrwnetla, DE 118003163
VISIT U9 AT.
v.wvesdnambraantn rom
TRANSACTIONS
Trans Amount
Date Relwonoo Number Marrhant Namo or Transaction Dascripdon Credit Debit
08411 1`17`. 10OL400992WO CHARGE OFF ACCOUNT-PRINCIPALS 12499.43
De131 1`17'1001.4009920110 CHARGE OFF ACCO'JNT'FINANCE CHARGES' 2789.95
FINANCE CHARGES PERIODIC RATF(S) AND APR(S) MAY VARY
Dilly C.-por,ding 1. nee erg.
Periodic Rate APR Average Daily Balance Due To Transaction FINANCE
Categon/ 06 days in cycle Previous Cycle Curran Cycle Paliedb Rate Feas CHARGES
Purchases 063-16% 25.24% - - - $0.00
Cash advances 06916% 25.24% - - $0.0c
Total finance charges $0.00
Effective Amual Porcontago Rate (APR): WA
aoce Period Type: A (Please see bac+; ofsaeasrr rit for me Grow Period a.Wlarla5on.)
The Corresponding APR is tie rata of into-est you pay when you carry a balance on purchases or cash adwncea.
The Effective APR represents your total finance charges - Including transaction fees such as cash advance and balance transfer
fees - expressed as a percertage.
708041. 18 S ECURITY ALERTI
HELP US PRCT ECT YOU AGAINST IDENTITY THEFT
CALI NOW TO UPDATE YOUR PHONE NUMBERS
CALL 1-888-240.8049
This Statement is a Facsimile - Not an Original
5630 9000 U58 sco s la 048651 ZXPew 1 of 1 1711 1600 1105686 OKCSS634
?F4 Our
AFFIDAVIT OF INDEBTEDNESS
State of Ohio)
County of Hamilton ) ss.
Kim Kenney being sworn, deposes and says that she is Media Supervisor of Unnnd 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 VERONICA KLINE, Account Number 5417116931134357, the amount of
$26239.88 (principal balance in the amount of $15083.38 plus interest up through 04/10/2007 in the
amount of $11156.50). By the terms of the agreement between the defendant and the original creditor,
interest is accruing from the aforesaid date at the rate of 25.24 percent per annum. This balance reflects any
payments, credits or offsets made since the account was charged off.
Chase Bank USA NA's account was issued under the name of FUSA PLATINUM CNNCT ACQ M/C.
Unifund CCR Partners purchased this account from Chase Bank USA NA. Said account has been referred
to Law Ofcs of Edwin A. Abp & A with fill 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
L T" CCR PARTNERS
By: Kim Kenney
Media Supervisor
and 7T Y before" 10 day of April. 2007
Year
My commission Expires
JENNIFER A. DUNCAN
v.•" r, •.. ??
i NOTARY PUBLIC
? STATE OF OHIO
Comm. Expires
Client # 1300 = July 04, 2007
0
OF
cm "g T A
Fl 300
ACCOUNT NUMBER BALANCE AS OF PAYMENT DUE DATE MINIMUM PAYMENT PAYMENT ENCLOSED
0411 =007
5417116931134357 26,239.88 PAST DUE 26,239.88
Me CNec" Paffile To Robin!
UNIFUND STATEMENT
VERONICA KLINE
956 VVERTZVILLE RD
ENOLA PA 17025
MESSAGE FROM UNIFUND
YOUR ACCOUNT IS PAST DUE 126.239.88. THE PAST DUEAMOUNT IS INCLUDED IN THE MINIMUM PAYMENT. PLEASE REMIT
IMMEDIATELY. IF YOU HAVEALREADY SENTA PAYMENT FOR THE ABOVE AMOUNT,THANK YOU.
TRANSACTIONS:
Date Transaction IR Balance Due Payments Hew Balanc
04!1012007 Chase Bank USA NA's Account 0.2524 26,239.88 26,239.88 0 26,239.88
Was Issued Under The Name Of
FUSA -PLATINUM CNNCT ACQ
MIC.
PROMPT CREDITING 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 NEkT 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.
LXH 16t T
CHASE Cp
EXHIBIT A
BILL OF SALE
Chase Bank USA, N.A. (as successor through merger with Bank One, Delaware, N.A.)
("Seller"), for value received and pursuant to the terms and conditions of Credit Card Account
Purchase Agreement dated January 26, 2006 between Seller and Unifund Portfolio A, LLC
("Purchaser"), its successors and assigns ("Credit Card Account Purchase Agreement"), hereby
assigns effective as of the Cut-off Date of August 10, 2006 all rights, title and interest of Seller in
and to those certain receivables, judgments or evidences of debt described in Exhibit 1 attached
hereto and made part hereof for all purposes.
Amounts due to Seller by Purchaser in hereunder shall be paid U.S. Dollars by a wire transfer to
be received by Seller on August 21, 2006 (the "Closing Date") by 2:00 p.m. Seller's time, as
follows:
Chase Bank USA, N.A
ABA #021000021
Beneficiary Name: Chase Bank USA, N.A.
Beneficiary Account: #304-256420
This Bill of Sale is executed without recourse except as stated in the Credit Card Account
Purchase Agreement to which this is an Exhibit. No other representation of or warranty of title or
enforceability is expressed or implied.
Chase Bank US„s?A, N.A.
By:
Date: August 11.2006 _
Title Vice President
Unifun ortfolio , LL
By:
Date: Au t 11 2006
Title
IM 1617- 4
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SHERIFF'S RETURN - NOT FOUND
CASE NO: 2007-03782 P
COMJ40NTWEALTH OF PENNSYLVANIA
AbUNTY OF CUMBERLAND
UNIFUND CCR PARTNERS
VS
KLINE VERONICA
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
KLINE VERONICA but was
unable to locate Her in his bailiwick.
OnMnT TTATM f_ ATnrVT0V
He therefore returns the
the within named DEFENDANT
956 WERTZVILLE ROAD
KLINE VERONICA
NOT FOUND , as to
ENOLA, PA 17025
CURRENT RESIDENT HAS LIVED THERE FOR 15 YEARS
AND DOES NOT KNOW DEFENDANT.
Sheriff's Costs:
Docketing 18.00
Service 14.40
Not Found 5.00
Surcharge 10.00
.00
47.40
So answers:
r
R. Ihomas Kline
S eriff o Cumberland County
EDWIN ABRAHAMSEN & ASSOCIATES
06/26/2007
Sworn and Subscribed to before
me this day of
A. D.
UNIFUND CCR PARTNERS In the Court of Common Pleas of
c/o Edwin A. Abrahamsen & Associates, Cumberland County, Pennsylvania,
120 North Keyser Ave. Civil Division
Scranton, PA 18504
Plaintiff
Vs.
VERONICA KLINE
No: 07-3782 CIVIL TERM
88 N. ST. JOHN'S RD Praecipe to Reinstate
CAMP HILL, PA 17011 the Civil Complaint
Defendant
To the Prothonotary of Cumberland County Pennsylvania:
Please enter the above Praecipe to Reinstate Civil Complaint.
Thank you,
Michael F. Ratchford,
Edwin A. Abraham
Lawyer ID # 8628
Associates, P.C.
Sworn and subscribed before me
Loeh, Voti ry Public
r-
day of C-- 20
ZIP
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may''
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L;7
SHERIFF'S RETURN - REGULAR
CASE NO: 2007-03782 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
UNIFUND CCR PARTNERS
VS
KLINE VERONICA
SHARON LANTZ
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
KLINE VERONICA
the
DEFENDANT , at 1233:00 HOURS, on the 10th day of January , 2008
at 88 ST JOHNS ROAD
CAMP HILL, PA 17011
GORDON KLINE, HUSBAND
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
Service
Affidavit
Surcharge
ill HlO P
18.00
30.72
.00
10.00
.00
58.72
So Answers:
Sworn and Subscibed to
before me this
day
of
R. Thomas Kline
01/10/2008
EDWIN ABRAHAMSEN & ASSOCIATES
By: I I / _
-Deputy Sheri
A. D.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
UNIFUND CCR PARTNERS
CIVIL DIVISION
Plaintiff
VS.
VERONICA KLINE
NO: 07-3782-CIVIL TERM
Defendant
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 $26,489.16, which includes reasonable attorneys' fees. Notice of the intent to file a
default judgment was served upon the Defendant on February28,2008. A copy of the Notice of
Intent to Take Default Judgment is attached hereto and marked Exhibit "A."
Edwin A
i Zv
Michael F. Ratc
Attorney I.D. N
Attorney for
JUDGMENT
& Associates, P.C.
85
AND NOW, this 14'?' day of Maw h, 2008, Judgment is hereby entered in favor
of the Plaintiff and against the Defendant in the amount of $26,489.16, which includes
reasonable attorneys' fees for failure to respond to Plaintiff's Complaint.
CLERK OF JUDICIAL RECORDS
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
UNIFUND CCR PARTNERS
Plaintiff
CIVIL DIVISION
vs. .
NO: 07-3782-CIVIL TERM
VERONICA KLINE
Defendant
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:
VERONICA KLINE
88 N SAINT JOHNS ROAD
Camp Hill PA 17011-6942
Date: la
Edwin A. Abrahamsen & Associates, P.C.
By:
Michael F. Ratchfor squi
Attorney I.D. No . 6285
120 Keyser enue
Scranton, P 18504
(570) 558-5510
UNIFUND CCR PARTNERS
In the Court of Common Pleas of
vs.
VERONICA KLINE
Plaintiff CUMBERLAND County, Pennsylvania
Civil Division
NO: 07-3782-CIVIL TERM
Defendant AFFIDAVIT UNDER SOLDIERS AND SAILORS
RELIEF CIVIL RELIEF ACT OF 1940 AS
AMENDED
State of Pennsylvania
County-of CUMBERLAND SS:
Michael F. Ratchford, Esquire being duly sworn according to law deposes and says that the
above named defendant(s): VERONICA KLINE; 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): VERONICA KLINE; is(are) older than eighteen years of age;
That the employment status of the defendant(s): VERONICA KLINE; is(are) unknown.
before me?this
day of
20 6?
Jenny
O
JG?? ?0?ti
"0
116?41
y?o
EDWIN A. ABRAHAMSEN
MICHAEL F. RATCHFORD
SCOTT J. BEST'
'ALSO MEMBER OF NJ BAR
47A
THE LAW OFFICE OF
EDWIN A. ABRAHAMSEN & ASSOCIATES, P.C.
WWW.EAA-LAW.COM
February 28, 2008
VERONICA KLINE
88 N SAINT JOHNS ROAD
Camp Hill PA 17011-6942
Re: UNIFUND CCR PARTNERS v. VERONICA KLINE
CUMBERLAND County Civil Action No. ; 07-3782-CIVIL TERM
Dear VERONICA KLINE :
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. Ratchfo , Esquire
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 PITT5TON AVE. • SCRANTON, PA 1 8505 • IP) 570.558.551 0 • (F) 570.558.551 1
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
UNIFUND CCR PARTNERS
: CIVIL ACTION
Plaintiff :
VS.
VERONICA KLINE NO: 07-3782-CIVIL TERM
Defendant :
TEN DAY NOTICE OF INTENT TO TAKE DEFAULT JUDGMENT
To: VERONICA KLINE
88 N SAINT JOHNS ROAD
Camp Hill PA 17011-6942
Date of Notice: FebruM 28, 2008
IMPORTANT NOTICE PURSUANT TO PA.R.C.P: 237.1(a)(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
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
UNIFUND CCR PARTNERS
: CIVIL ACTION
Plaintiff
VS.
VERONICA KLINE NO: 07-3782-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:
VERONICA KLINE
88 N SAINT JOHNS ROAD
Camp Hill PA 17011-6942
Edwin A. Abrahamson & Associates, P.C.
BY:
Michael F. Ratchfor squire
Attorney I.D. No.: 6285
1729 Pittston Avenue
Scranton, PA 18505
(570) 558-5510
73 +_?C7
I
CO -<
a
UNIFUND CCR PARTNERS
In the Court of Common Pleas of
Plaintiff CUMBERLAND County, Pennsylvania
Civil Division
vs.
VERONICA KLINE
Defendant . NO: 07-3782-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 $ a(D ? 48q In on 31l4/og
By:
If you have any questions regarding this notice, please contact the filing parry:
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)