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HomeMy WebLinkAbout07-4617 2037311 THIS IS AN ARBITRATION MATTER. ASSESSMENT OF DAMAGES HEARING REQUIRED. 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 Collins Financial Services,Inc As Assignee of CIT Bank 2101 West Ben White Blvd Austin, TX 78704 COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. Terry Coy 23 TOWN MILLLS MOBILE HOME PARK SHIPPENSBURG PA 17257 DOCKET NO. Q']- 'y~~] C,lVll TGlrt'A 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. 5. All the credits to which the defendant (s) is entitled have been applied and there remains a balance due in the amount of $2,182.44. 6. Plaintiff has made demand upon the defendant(s)for payment of the balance due of $2,182.44 but the defendant(s)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 8/4/03. WHEREFORE, plaintiff claims of the defendant(s) the sum of $2,182.44 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDERIC EINBERG, ESQUIRE JOEL M. FLINK, ESQUIRE Attorney for Plaintiff POlA.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. WEINBERG, ESQUIRE .a W N ~' O ~-- C °~ ~'.' ~ ~ -- J `~ ~ ~• ca -< -C SHERIFF'S RETURN - NOT FOUND CASE NO: 2007-04617 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND COLLINS FINANCIAL SERVICES INC VS COY TERRY 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 COY TERRY but was unable to locate Hirn in his bailiwick. COMPLAINT & NOTICE , He therefore returns the the within named DEFENDANT COY TERRY 23 TOWN MILLS MHP SHIPPENSBURG, PA 17257 GIVEN ADDRESS IS VACANT. NOT FOUND as to NO FORWARDING ON FILE AT POST OFFICE. Sheriff's Costs: Docketing Service Not Found Surcharge /~ ~'2 x'[61 ` fi"` / Sworn and Subscribed to before me this day of A.D. So answers : _ ..-- 18 . 0 0 ..~ ~'`~ ~, . 2 0.16 -~`" 5.00 R. Thomas ine 10.00 Sheriff of Cumberland County GORDON & WEINBERG 08/23/2007