Loading...
HomeMy WebLinkAbout07-5363V 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 MIDLAND FUNDING LLC 8875 Aero Drive, Suite 200, San Diego, CA Plaintiff v. PATRICIA BECK 273 Meadows Road, Newville, PA Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 0'1- 53(03 Civi ( 7prw- 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 90820 1 Burton Neil & Associates, P.C. ~y: Brit J. Suttell, Esquire ID. N0.204140 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. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. (~ 7 - ~ 3 ~ 3 PATRICIA BECK 273 Meadows Road, Newville, PA Defendant 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 Patricia Beck, who resides at 273 Meadows Road, Newville, Cumberland County, Pennsylvania. 3. Aspire furnished consumer credit to defendant bearing account number 4134810002247172 hereinafter referred to as the credit cazd account. 4. Defendant made purchases, balance transfers and/or cash advances on the credit card account. 5. The balance due on the credit card account is $1,670.34. 6. Defendant did not pay the balance due on the credit cazd account as required by the credit cazd agreement. As such, defendant is in default on the credit card 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 $1,670.34, defendant failed and refused to pay all or any part thereof. Wherefore, plaintiff demands judgment against the defendant in the sum of $1,670.34 and the costs of this action. Burton Neil & Associates, P.C. By: Brit . Suttell, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates, P. C. is a debt collector. ~. . Verification I, ri I I LI(/~ ~( ~~ am an employee of Midland Credit Management, 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 ~~`/~G-%Gr ©C,~c~4L Patricia Beck 4134810002247172 •"; -O .~D s (~ 60. ~ `] # ~ Sb 1 . ~ V K . -E ~t1 ~~~ s C uD ~~ SHERIFF'S RETURN - REGULAR CASE NO: 2007-05363 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MIDLAND FUNDING LLC VS BECK PATRICIA DAVID MCKINNEY Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE BECK PATRICIA was served upon the DEFENDANT at 1852:00 HOURS, on the 12th day of September, 2007 at 273 MEADOWS RD NEWVILLE, PA PATRICIA BECK 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 18.00 Service 15.36 Affidavit .00 Surcharge 10.00 .00 9~)Bjbl ~ ~~ Sworn and Subscibed to before me this day of , So Answers: ~.~ /• R. Thomas Kline 09/13/2007 BURTON NEIL & ASSOCIATES gy ; .~ Deputy Sheriff A.D. MIDLAND FUNDING LLC IN THE COURT OF COMMON PLEAS 8875 Aero Drive Suite 200, San Diego CA 92123 Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 07-5363 PATRICIA BECK 273 Meadows Road Newville PA 17241 Defendant :CIVIL ACTION -LAW Praecipe for Default Judgment To the Prothonotary: 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 $1,670.34 $1,670.34 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 o Prothonotary '~ !o/a3/o'j Burton ei' Associates, P.C. _~ By~ rit J. Sutte11,; Esquire Attorney for Plaintiff I.D. N0.204140 1060 Andrew Drive, Suite 170 West Chester, PA 19380 The law firm of Burton Neil & Associates is a debt collector. 90820 1111111 IIIII IIIII IIIII III IIIIIIII IIIII II 1111111 NI 1111111 IIIII IINII IIII 111111 Iihl II IIII ~1 MIDLAND FUNDING LLC Plaintiff v. 90820 PATRICIA BECK Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-5363 CNIL ACTION -LAW Notice of Intention to Fite Praecipe for Default Judgment TO: Patricia Beck 273 Meadows Road NewvilIe PA 1724 ] IMPORTANT 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 your defenses or objections to the claims set forth against you. Unless you act within ten (I0) 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 End 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: October 4, 2007 In making this communication, we advise our office is a debt collector. I illl~ IAN I~11~ ~I IINiI~ Burton Neil & Associates, P.C. By. ''i"Y Brit J. Si ell, Esquire Attorney for Plaintiff Identification No. 204140 1060 Andrew Drive, Suite 170 West Chester, PA ] 93 80 (610) 696-2120 I III IAN ICI WNII III I~ IIMI W!lINB ill VIII IIN VIII Iii II III ° ~ " " ~ ..~ ~ TD y-1 ~ ~ r C3 i ~ ~ ` ' ~ 7: ~ ---~ ,~" < ,..i _ ~ ~ Yi, t .~ ~ D ' '. _ ~ y ~ ... ~ r.~ o =i cry 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 MIDLAND FUNDING LLC IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. PATRICIA BECK N0.07-5363 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 ~ f Prothonotary By: aece 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.