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Home My WebLink About07-6167• 2042156 THIS IS AN ARBITRATION MATTER. ASSESSMENT OF DAMAGES HEARING REQUIRED. GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 LVNV Funding LLC Assignee of Citi-Sears 15 South Main St, Ste 700 Greenville, SC 29601 VS. JAMIE J ATWOOD 100 FROST ROAD GARDNERS PA 17324-9019 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 07 _ to 1107 Civi t Term 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 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 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. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 4 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. S. All the credits to which the defendant (s) is entitled have been applied and there remains a balance due in the amount of $2,540.67. 6. Plaintiff has made demand upon the defendant(s)for payment of the balance due of $2,540.67 but the defendant(s)has failed and refused and still refuses to pay the same or any part thereof. 7. Defendant's last payment on account was made on November 1, 2007. 8. Unless the undersigned hears from the Defendant in writing within thirty (30) days after receipt of this Complaint that the Defendant disputes the validity of the debt, or any portion thereof, the undersigned will assume the debt is valid. If Defendant notifies the undersigned in writing that the debt or any portion thereof is disputed, the undersigned will obtain verification of the debt or, if the debt is founded upon a judgment, a copy of the judgment will be obtained, and the undersigned will mail the Defendant a copy of such verification or judgment. Upon written request within thirty (30) days, the undersigned will provide the Defendant with the name and address of the original creditors, if different from the current creditor. This pleading is an attempt to collect a debt and any information obtained will be used for that purpose. WHEREFORE, plaintiff claims of the defendant(s) the sum of $2,540.67 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDERIC I. WEI ERG, ESQUIRE JOEL M. FLI ESQUIRE Attorney for Plaintiff POIA.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. WE NB G, ESQUIRE (7) N --i FTI L _ '? -, Zo v Y^ 00 0 W D N ?? . 0 0 SHERIFF'S RETURN - REGULAR CASE NO: 2007-06167 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND LVNV FUNDING LLC VS ATWOOD JAMIE J WILLIAM CLINE , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon A'MAMnM .7AMT P T the DEFENDANT , at 1650:00 HOURS, on the 6th day of November , 2007 at 100 FROST ROAD GARDNERS, PA 17324-9019 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: Docketing Service Affidavit +'ro? Surcharge pG9 Sworn and Subscibed to before me this of So Answers: 18.00` ?- 9.60 .00 10.00 R. Thomas Kline .00 37.60 11/07/2007 GORDON & WEINBERG By day Deputy Sheriff A.D. AP, 2042156 GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 81894 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 LVNV Funding LLC Assignee of Citi-Sears VS. JAMIE J ATWOOD COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 07-6167 CIVIL TERM PRAECIPE FOR ENTRY OF JUDGMENT FOR WANT OF AN ANSWER, ASSESSMENT OF DAMAGES VERIFICATION OF ADDRESS AND NON-MILITARY SERVICE TO THE PROTHONOTARY: Enter judgment for want of an answer for plaintiff and against defendant(s) above named only and assess damages certified to be calculable as a sum certain from the complaint, as follows: Principal $2,121.20 Interest from 9/20/07 Q66 $29.29 Costs (Complaint & Service) $116.10 Total: $2,266.59 Understanding the false statements made herein are subject to penalty under 18 Pa.C.S.A. §4904, Unsworn Falsification to Authorities, I verify that: 1. The last known addresses of the parties are: LVNV Funding LLC Assignee ofCiti-Sears and that the last known address of defendant, JAMIE J ATWOOD, 100 FROST ROAD, GARDNERS PA 17324-9019. 2. The annexed notice(s) of intention to file this praecipe was (were) mailed to all parties, defendant and to their record attorneys, if any, after default occurred, and at least ten days prior to the date of filing of this praecipe. 3. The said defendant(s) is (are) not in the military service of the United States or otherwise within the coverage of the Soldiers and Sailors Civil Relief Act and is (are) over 18 years of age. AND NOW, this day of , 2007 Judgment is entered in favor of the plaintiff(s) and against defendant(s) by .I• default for want of an answer and damages assessed at the sum of , $2,266.59 as per the above certification. Prothonotary GORDON & WEINBERG, P.C. BY: FREDERI I. W NBERG, ESQUIRE JOEL M. IM-Mg, ESQUIRE Attorney for Plaintiff 2042156 ans se- 1= e? e GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 LVNV Funding LLC Assignee of Citi-Sears Vs. JAMIE J ATWOOD COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 07-6167 CIVIL TERM NOTICE OF INTENTION TO XA-XZ DEFAULT TO/PARA JAMIE J ATWOOD 100 FROST ROAD GARDNERS PA 17324-9019 DATE OF NOTICE/FECHA DEL AVISO: November 27, 2007 33eoRTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY AN ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN 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 PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. 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. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 GORDON & WEINBERG, P.C. BY: ' FRED IC WEINBERG, ESQUIRE JO M. FLINK, ESQUIRE P10D-2 C7 co I 2042156 GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 LVNV Funding LLC Assignee of Citi-Sears vs. JAMIE J ATWOOD COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 07-6167 CIVIL TERM NOTICE Pursuant to Pa.R.Civ-P. 236 of the Supreme Court of Pennsylvania, you are hereby notified that a judgment has been entered against you in the above proceeding as indicated below. /X/ Judgment by Default $2,266.59 Money Judgment $ LL Judgment on Award of Arbitrators$ L1 Judgment on Verdict$ IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL ATTORNEYS: FREDERIC I. WEINBERG OR JOEL M. FLINK, ESQUIRES AT THIS TELEPHONE NUMBER: 484/351-0500 5 / ow-4t? /C A P O ONOTARY /A/-1 s07