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HomeMy WebLinkAbout07-5361Burton Neil & Associates, P.C. By: Yale D. Weinstein, Esquire ID. N0. 89678 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610)696-2120 Attorne for Plaintiff MIDLAND FUNDING LLC 8875 Aero Drive, Suite 200, San Diego, CA Plaintiff v. DANIELLE M ASKEY 450 S 3rd Street Apt 5, Lemoyne, PA Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 07 ~ 53lc1 ~ivi ( Ter~- 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 appeazance personally or by attorney and filing in writing with the court your defenses or objections to the claim set forth against you. You aze 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 91683 Burton Neil & Associates, P.C. By: Yale D. Weinstein, Esquire ID. NO. 89678 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 Attorney for Plaintiff MIDLAND FUNDING LLC 8875 Aero Drive, Suite 200, San Diego, CA Plaintiff v. DANIELLE M ASKEY 450 S 3rd Street Apt 5, Lemoyne, PA Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION -LAW Complaint 1. The plaintiff is Midland Funding LLC with place of business located at 8875 Aero Drive Suite 200, San Diego CA. 2. The defendant is Danielle M Askey, who resides at 450 S 3rd Street Apt 5, Lemoyne, Cumberland County, Pennsylvania. 3. Aspire furnished consumer credit to defendant beazing account number 4351810000363258 hereinafter referred to as the credit card account. 4. Defendant made purchases, balance transfers and/or cash advances on the credit cazd account. 5. The balance due on the credit cazd account is $4,277.57. 6. Defendant did not pay the balance due on the credit card account as required by the credit cazd agreement. As such, defendant is in default on the credit cazd account. 7. Plaintiff purchased defendant's account and is now the holder and owner of the account. 8. Although demand has been made by plaintiff upon defendant to pay the sum of $4,277.57, defendant failed and refused to pay all or any part thereof. Wherefore, plaintiff demands judgment against the defendant in the sum of $4,277.57 and the costs of this action. & ~~86ciat~s, P.C. By:_ D. Weinste n E ney for Plaintiff The law firm of Burton Neil & Associates, P. C. is a debt collector. ,~ I~ I A h c Verification I, "D Y" ~ w ~ V am an employee of Midland Credit M emen ~ t, Inc. which is by contract the servicer for plaintiff Midland Funding LLC retained to collect delinquent debt. I am authorized to make this verification pursuant to a servicing agreement from plaintiff to Midland Credit Management, Inc. The foregoing averments of fact in the within pleading are true and correct to the best of my knowledge, information and belief. I understand that the statements made herein are subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to the authorities. Date: Name Danielle M Askey 4351810000363258 7~ -~O *ik Oo 00 b D l ~, v c ~i N O w SHERIFF'S RETURN - REGULAR CASE N0: 2007-05361 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MIDLAND FUNDING LLC VS ASKEY DANIELLE M KENNETH GOSSERT Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon ASKEY DANIELLE M the DEFENDANT at 1836:00 HOURS, on the 26th day of September, 2007 at 450 S 3RD ST LEMOYNE, PA 17043 day by handing to a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing ,~ Service Affidavit ~pl9'~~ Surcharge ~ 18.0 0 So Answers: f/ ~~,' J~ .00 10.00 R. Thomas Kline .00 60.64 09/27/2007 RTTRTIIi~T i~TF.TT, Sworn and Subscibed to before me this of APT 5 By. A.D.