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Home My WebLink About07-4791Burton Neil & Associates, P.C. By: Brit J. Suttell, Esquire ID. N0.204140 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. RANDY BERKHEIMER 59 Johns Drive, Enola PA 17025 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. p ~- ~/ 7 ~J! Cavil `~~~- 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 86525 Burton Neil & Associates, P.C. By: Brit J. Suttell, Esquire ID. N0.204140 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. RANDY BERKHEIMER 59 Johns Drive, Enola PA 17025 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CNIL ACTION -LAW 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 Randy Berkheimer, who resides at 59 Johns Drive, Enola, Cumberland County, Pennsylvania. 3. At the defendant's request, Direct Merchants furnished consumer credit to defendant bearing account number 5458001619528643 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 $3,196.92. 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 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 $3,196.92, the defendant failed and refused to pay all or any part thereof. Wherefore, plaintiff demands judgment against the defendant in the sum of $3,196.92 and the costs of this action. Burton Neil & Associates, P.C. By. ~ ~ Bri J. Suttell, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. Verification Gayle Dixon 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 Randy Berkheimer 5458001619528643 1 v 1 1 W Q ~! J ~~ z d v V ~.._._ _ .. ~~ ` _ ` J ~~ v~~ ( A -~ v . r ~- ~ ;ern .~ ~ cam; -~ SHERIFF'S RETURN - REGULAR CASE NO: 2007-04751 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WORLDWIDE ASSET PURCHASING LLC VS BERKHEIMER RANDY DAVID MCKINNEY Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE BERKHEIMER RANDY DEFENDANT at 411 BROOKVIEW COURT MECHANICSBURG, PA 17055 by handing to RANDY BERKHEIMER a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. the at 1922:00 HOURS, on the 30th day of August 2007 was served upon Sheriff's Costs: Docketing Service Affidavit Surcharge ~~'jyJa~ 18.00 26.88 .00 10.00 .00 ~.,~4 . 8 8 So Answers: .-'~~ R. Thomas Kline 08/31/2007 BURTON NEIL & ASSOCIATES Sworn and Subscibed to By: ,1 before me this day Deputy heri f Of A.D. Burton Neil & Associates, P.C. By: Brit J. Suttetl, Esquire ID. NO.204140 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff WORLDWIDE ASSET PURCHASING,LLC Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. RANDY BERKHEIMER 411 Brookview Court Mechanicsburg PA 17050-4514 Defendant N0.07-4791 CIVIL ACTION -LAW Praecipe to Reinstate To the Prothonotary: Please reinstate the Complaint. Burton Neil & Associates, P.C. By: ~ Y~ it J. Suttell, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates is a debt collector. 86525 .-~ C . r-.a -~~ C"t .~f ., g. -_~ '~'~ ~ ~ ~~ OQ OO V~.1 1, 'p D - r t`~.~ ~ .. A'." WORLDWIDE ASSET PURCHASING, LLC 9911 Covington Cross Dr., Las Vegas 89144 Plaintiff v. RANDY BERKI~IMER 411 Brookview Court Mechanicsburg PA 17050-4514 Defendant To the Prothonotary: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-4791 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 $3,196.92 $3,196.92 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 ~C . Pr Prothonotary Burton/hTeil & Associates, P.C. ( .__ -__- By: ` B t J. Suttell, Esquire Attorney for Plaintiff I.D. NO. 204140 1060 Andrew Drive, Suite 170 West Chester, PA 19380 The law firm of Burton Neil & Associates is a debt collector. 86525 -~ -~ ~ ~,,. ~ ~ ~ ~, ~: -~ o ~- f~. ~ ~ ~ ~ :~. ~~, ::~ ~' t'7 ~ --cM r~-- ~~ ~~ ~~~ =~. ~~ ~:, ~~; ~- ;~ WORLDWIDE ASSET PURCHASING,LLC Plaintiff v. RANDY BERKHEIlVIER Defendant IN THE COURT OF COMMON PLEAS 86525 CUMBERLAND COUNTY, PENNSYLVANIA NO.07-4791 CIVII. ACTION -LAW Notice of Intention to File Praecipe for Default Judgment TO: Randy Berkheimer 411 Brookview Court Mechanicsburg PA 17050-4514 ]MPORTANT NOTICE You are in default because you have failed to enter a written appearance personally or by attorney and file in writing with the court yow defenses or objections to the claims set forth against you. Unless you act within ten (10) 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 of#ice 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 io 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 27, 2007 th making this communication, we advise our office is a debt collector. Burton Neil & Associates, P.C. By: Brit J. S ell, Esquire Attorney for Plaintiff Identification No. 204140 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610)696-2120 I~IIIIIIMIII#I~Illllllllllii IIIN~INIINIII~I~~IIIIIIIlIIIIIIIIIHIIilllllllll~lll~IIII11 C r ~ -r .•~ ~~ (:.r:.. " .. `-' ~ E"'3 ---t Y i~ ~ ~iZ Y~t"7 "i' I ~ R , f w ".. -. ''- ~ ? C- -~ rn .~- ~~ 0 Burton Neil & Associates, P.C. By: Brit J. Suttell, Esquire ID. N0.204140 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. N0.07-4791 RANDY BERKHEIMER Defendant :CIVIL 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 /O~/o1~07 Prothonotary By~' / ~ 4X8 If you have any questions concerning the above, please contact: Brit J. Suttell, 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. SHERIFF'S RETURN - REGULAR CASE N0: 2007-04791 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WORLDWIDE ASSET PURCHASING LLC VS BERKHEIMER RANDY 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 RFRKHFTMFR RANDY the DEFENDANT at 1051:00 HOURS, on the 22nd day of October 2007 at 411 BROOKVIEW COURT MECHANICSBURG, PA 17050 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: So Answers: Docketing 18.00 Service 23.04 3 Af f i davi t . 0 0 i ~~-~~--"-~'' Surcharge 10.00 R. Thomas Kline .00 r~~36~b7 51.04 10/23/2007 BURTON - - - Sworn and Subscibed to B before me this day of , A.D.