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HomeMy WebLinkAbout07-4787t Burton Neil & Associates, P.C. By: Derek C. Blasker, Esquire ID. NO. 202150 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 Attorney for Plaintiff WORLDWIDE ASSET PURCHASING,LLC 9911 Covington Cross Dr Las Vegas 89144 Plaintiff v. MARGARET PATRICK 90 Fairview Street Apt R, Carlisle PA 17015 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 6 ...~, y7 F17 Gl u t l 'f~c"" CIVIL ACTION -LAW Complaint -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 (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 claim 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. 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. LAWYER REFERENCE AND INFORMATION SERVICE Cumberland County Bar Assoc. 32 South Bedford Street Carlisle, PA 17013 Telephone No. 717-249-3166 or 800-990-9108 87141 t IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA MARGARET PATRICK NO. ~ 7 ~Z ~''~ G ~ ~ ~ ~ +~i~ 90 Fairview Street Apt R, Carlisle PA 17015 Defendant CIVIL ACTION -LAW Burton Neil & Associates, P.C. By: Derek C. Blasker, Esquire ID. N0.202150 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 Attorney for Plaintiff WORLDWIDE ASSET PURCHASING,LLC 9911 Covington Cross Dr Las Vegas 89144 Plaintiff v. Complaint 1. The plaintiff is WORLDWIDE ASSET PURCHASING,LLC, abusiness corporation, with place of business located at 9911 Covington Cross Dr, Las Vegas. 2. The defendant is Margaret Patrick, who resides at 90 Fairview Street Apt R, Carlisle, Cumberland County, Pennsylvania. 3. At the defendant's request, Direct Merchants Credit furnished consumer credit to defendant bearing account number 5458001243405788 hereinafter referred to as the credit card account. 4. The defendant accepted the credit card account by making purchases, balance transfers and/or cash advances. 5. Monthly statements were sent to defendant each month which detailed the charges and credits made to the credit card account for the prior month. 6. The balance due on the credit card account is $2,935.73. 7. Defendant did not pay the balance due on the credit card account in full upon receipt of the monthly billing statements and also did not make the required minimum monthly payment set forth in the monthly billing statement. As such, defendant is in default on the credit card account. 8. Plaintiff purchased the defendant's account from Direct Merchants Credit and is now the holder and owner of the account. 9. Although demand has been made by plaintiff upon defendant to pay the sum of $2,935.73, the defendant failed and refused to pay all or any part thereof. Wherefore, plaintiff demands judgment against the defendant in the sum of $2,935.73 and the costs of this action. Burton eil & Associates, P.C. By: Derek C. Blasker, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. ,r Verification Gayle Dizon is Attorney Relationship Manager for WORLDWIDE ASSET PURCHASING,LLC, the within Plaintiff, and makes this statement on its behalf as to the truthfulness of the facts set forth in the foregoing Complaint subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Date: f ~~~ Name Margaret Patrick 5458001243405788 ~b ~ ~ ~ a .J W ~ ~(1 c1~ ~ ~,, -~C C`) C '„ ~ ~ <~ --~ -n "-~ i`~ xT. ---~ ~.~ r~~ r= r W -a \t ~ d~ `:_ ~ - . ~; ~~~; 3 ,. . ~. , ~ W ~ r-r-t -~ :-~ tv -~ Cz~ -~G O~ F A A n 1 ~, SHERIFF'S RETURN - REGULAR CASE NO: 2007-04787 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WORLDWIDE ASSET PURCHASING LLC VS PATRICK MARGARET STEPHEN BENDER Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon PATRICK MARGARET the DEFENDANT at 2010:00 HOURS, on the 20th day of August 2007 at 90 FAIRVIEW STREET APT R CARLISLE, PA 17015 by handing to MARGARET PATRICK 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 18.00 Service 4.80 Affidavit .00 Surcharge 10.00 00 8I~ a/b~ c~..., 3 Sworn and Subscibed to before me this day of , So Answers: R. Thomas Kline oa/21/2007 BURTON NEIL By: eputy Sheriff A.D. .~ WORLDWIDE ASSET PURCHASING,LLC 9911 Covington Cross Dr, Las Vegas 89144 Plaintiff v. MARGARET PATRICK 90 Fairview Street Apt R Carlisle PA 17015 Defendant To the Prothonotary: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA N0.07-4787-CNIL CIVIL ACTION -LAW Praecipe for Default Judgment Please enter judgment by default for want of an answer in the above case in favor of the plaintiff and against the defendant, and assess damages as follows: Principal: TOTAL $2,935.73 $2,93 5.73 Understanding that false statements herein made are subject to penalty under 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities, I verify that: 1. The above are the precise last-known addresses of the judgment debtor and creditor. 2. The annexed notice of intention to file this praecipe was mailed to all parties against whom judgment is to be entered and to their record attorneys, if any, after the default occurred, and at least ten days prior to the date of the filing of this praecipe. 3. Pursuant to Section 201(b)(1)(A) of the Servicemembers Civil Relief Act of 2003 (SCRA), the defendant is not in the military service of the United States based on information received from the defendant and/or the Department of Defense website. JUDGMENT BY DEFAULT ENTERED AND DAMAGES ASSESSED AS ABOVE. NOTICE GIVEN UNDER PA.R.CIV.P. 236 BSI ,l~.g Ur,B Pro Prothonotary 9/a7/o~ The law firm of Burton Neil & Associates is a debt collector. B on eil & sso e P.C. BY: erek lasker, Esquire Attorney for Plaintiff I.D. #202150 1060 Andrew Drive, Suite 170 W. Chester, PA 19380 87141 WORLDWIDE ASSET PURCHASING,LLC Plaintiff v. MARGARET PATRICK Defendant IN THE COURT OF COMMON PL)iA5 CUMBERLAND COUNTY, PENNSYLVANIA NO.07-4787-CIVIL CIVIL ACTION -LAW Notice of Inten#ion to File Praecipe for Default Judgment TO: Margaret Patrick 90 Fairview Street Apt R Carlisle PA 17015 Il~IPORTANT NOTICE 87141 You are in default because you have failed to enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the clauns set forth against you. Unless you act within ten (IO) 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 notice to your lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help. 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. LAWYER REFERENCE AND INFORMATION SERVICE Cumberland County Bar Assoc. 32 South Bedford Street Carlisle, PA 17013 Telephone No. 717-249-3166 or 800-990-9108 DATE OF NOTICE: September 11, 2007 In making this communication, we advise our office is a debt collector. B rton eil Associa es, .C. By: Derek . Blas er, Esquire Attorney for Plaintiff Identification No. 2021 SO 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610)696-2120 IIl1111111111111111n111111111110 IIII<IIIIigINi111~llill~ll181111Illlllllllllallllll!lIIII~IIIilll _._ .... _ .._._........ ___ __ .._.~.. ~...a ~_ ..~,~....,. , '~,.. ~ ~ ~ # ~ o ~ ~ ~ ~ A v ~ ~,o~ 1 ~a ~~ f~ G."7 _...A Y-~ C~ .- T ~ Ii T~~~ 1 ~ 1~ 1 =- ° ~J ~.' ~~3 '•~' " ~- -,~, t c.x. _ Burton Neil & Associates, P.C. By: Derek C. Blasker, Esquire ID. N. 202150 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 ATTORNEY FOR: Plaintiff WORLDWIDE ASSET PURCHASING,LLC IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. MARGARET PATRICK NO. 07-4787-CNII. Defendant : CNIL, ACTION -LAW Rule of Civil Procedure N0.236 (Revised) Notice is given that a JUDGMENT in the above captioned matter has been entered against you on~07 Prothonotary By: 1.~.~..~c.a ~ o rcg If you have any questions concerning the above, please contact: Derek C. Blasker, Esquire Attorney for Party Filing 1060 Andrew Drive, Suite 170 West Chester, PA 19380 Phone: 610-696-2120 The law firm of Burton Neil & Associates is a debt collector.