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
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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
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_ 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.