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HomeMy WebLinkAbout07-5635 ---~ H0073296 THIS IS AN ARBITRATION MATTER. ASSESSMENT OF DAMAGES HEARING REQUIRED. Goldman & Warshaw, P.C. BY : FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 1001 E. Hector Street, Suite 220 Conshohocken, PA 19428. 484-351-0500 Toll Free (888) 437-4832 OLIPHANT FINANCIAL, LLC as assignee of BONTON DEPARTMENT STORE/BONTON CREDIT CARD 1800 2ND ST SARASOTA, FL 34230 vs. AMANDA R FISHER PO BOX 1412 CARLISLE PA 17013-6412 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. 07_ 5(035 l,iivi ~ ~~f IN) NOTI 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 TWENTY (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 CLAIMS SET FORTH AGAINST YOU. YOU ARE WARNED THAT IF YOU FAIL TO DO SO THE CASE MAY PROCEED WITHOUT YOU AND A JUDGEMENT 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 TRKE 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. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 COMPLAINT IN CIVIL-ACTION 1. Plaintiff is a debt buyer and successor in interest to the original creditor as set forth in the caption of this Complaint. 2. At all times relevant hereto, the defendant(s) was the holder of a credit card, which at the request of the defendant(s) was issued to the defendant(s) by the plaintiff under the terms of which the plaintiff agreed to extend to defendant(s)the use of plaintiff's credit facilities. 3. Defendant(s) accepted and used the aforesaid credit card so issued and by so doing agreed to perform the terms and conditions prescribed by the plaintiff for the use of said credit card. 4. The defendant(s)received and accepted goods and merchand- ise and/or accepted services or cash advances through the use of the credit card issued by the Plaintiff. A true and correct copy of the Statement of Account is attached hereto as Exhibit "A". 5. All the credits to which the defendant(s)is entitled have been applied and there remains a balance due in the amount of $1,106.38. 6. Plaintiff has made demand upon the defendant(s)for payment of the balance due of $1,106.38 but the defendant(s)has failed and refused and still refuses to pay the same or any part thereof. 6. Defendant's last payment on account was made on 10/22/2003. WHEREFORE, plaintiff claims of the defendant(s) the sum of $1,106.38 plus applicable costs, interest and attorney's fees. Goldman & Warshaw, P.C. BY: FREDERIC I. WEI RG, ESQUIRE Attorney for aintiff POlA.DB VERIFICATION FREDERIC I. WEINBERG, ESQUIRE hereby states that he is the attorney for the Plaintiff(s) in this action and verifies that the statements made in the foregoing pleading are true and correct to the best of his knowledge, information and belief. The undersigned understands that the statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities. FREDERIC I. W NBERG, SQUIRE EXHIBIT "A" ~/Oa73 ~. OL.IPHANT FINANCIAL, LLC 0000752717 Amanda R Fisher PO BOX 1412 CARLISLE, PA 17013-6412 STATEMENT OF ACCOUNT P.O. Box 2899 SARASOTA, FL 34230-289 Pt-~oNE: (800) 262-199 Soc Sec No: ~ooc xx-3146 x~oc-xx- REPORT DATE June 22, 2007 Originating Account Information Originating Bank BonTon Department Store Acxount Type Bonton Credit Card Account Number 113712715 Date Opened 0122/03 CUSTOMER NUMBER 0000752717 Data of Last Payment Received by Original Creditor 10/12/03 Amount of Last Payment Received by Original Creditor Not Available Charge-Off Date 04/24/04 Acquisition Balance $638.56 Acq Interest Rate: 21.6096 Payment History Date Check Number Payment Type Amount Paid Amount Credited Remaining Balance 03/01/08 Acquired Balance 50.00 50.00 $838.56 Pursuant to federal law, please be advised that Oliphant Financial, LLC is a debt collector and is attempting to collect a debt. Anq information obtained will be used fot that purpose. Port: 220 Statement without interest LEGAL 09:30:07 OLIPHANT FINANC H0073296 DEPARTMENT STO BONTON ~ ~ C~ ON AMANDA R FISHER 113712715 AFFIDAVIT I,~ w \C.1 bein dul 8 Y served sworn according to law, depose and say that: I . I am the agent for the plaintiff herein and I have custody and control of the files relating to this account; 2. I have personal lrnowledge of the facts and circumstances in connection with this case; 3. Plaintiffs files are maintained in the usual and ordinary course of business; 4. This action is based on a claim for breach of contract and that damages are sought as a direct result of said breach; 5. After allowing for all offsets and credits, a balance remains on the subject account having account number 113712715 in the amount of $638.56; and 6. If called upon, affiant can testify at trial as to the facts pertaining to this matter. The above facts are true and corroct to the best of my lmowled ge, information and belief. ~~~ (Name of Affiant) Sworn to and Subscribed before me this ~] day Y~ , 2007 No !ic TATIMIA ``~~ yy ~ ~ 's S: ,It~?6, gppp ~~~~ I~ ~ N _~ ~t =r (~ {~, ~ -ra C ~ j'. + cn t"~'1 y !'° ~ i T ~ ~' '~ ' j~ f}' + '~'' yT ~" 6 ~ ~ ' ~