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Home My WebLink About07-61904 NC028604 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 NCO PORTFOLIO MANAGEMENT ASSIGNEE OF CITIBANK 1801 WASHINGTON BLVD BALTIMORE, MD 21230 VS. SARAH M SIMONDS 120 E LOUTHER ST CARLISLE PA 17013-3051 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 6'7_ tolgo C;v; TerIV1 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 1 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. 5. All the credits to which the defendant (s) is entitled have been applied and there remains a balance due in the amount of $34,814.37. 6. Plaintiff has made demand upon the defendant(s)for payment of the balance due of $34,814.37 but the defendant(s)has failed and refused and still refuses to pay the same or any part thereof. r 7. Defendant's last payment on account was made on 10/28/03. WHEREFORE, plaintiff claims of the defendant(s) the sum of $34,814.37 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDERIC I. tE!I12&ERG, ESQUIRE JOEL M. FLIN QUIRE Attorney for Plaintiff POlA.DB a VERIFICATION FREDERIC I. WEINBERG, ESQUIRE, hereby states that he is the attorney for the Plaintiff(s) in this action and verifies that the statements made in the foregoing pleading are true and correct to the best of his knowledge, information and belief. The undersigned understands that the statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities. FREDERIC I. WE NBE G, ESQUIRE 44. # ?k 00 CZD w W 00 `- r a ; T fr N t G} } r? 9 O SHERIFF'S RETURN - REGULAR i~ASE NO: 2007-06190 P ` COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND NCO PORTFOLIO MANAGEMENT VS SIMONDS SARAH M KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon CTMnATnq PAPAW M the DEFENDANT , at 1924:00 HOURS, on the 9th day of November , 2007 at 120 E LOUTHER STREET APT D CARLISLE, PA 17013-3051 by handing to SARAH SIMONDS a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge / ? p _ Sworn and Subscibed to before me this of 18.00 4.80 .00 10.00 day So Answers: R. Thomas Kline 11/13/2007 GORDON & WEINBERG By: A. D. OcL 29. 2007 8:50AM Cumberland Co. Sheriff No.7837 P. R. THOMAS KUNE Shelf EDWARD L SCHORPP Sotdtor ?oq at Go QCumbert$ OFFICE OF THE SHERIFF One Courthouse Square Carlisle, Pennsylvania 17013 RONNY R. ANDERSON CNaf Deputy JODY S. SMITH Real Estate Deputy To: Postmaster AgencyCoatrol o.6- Sa C,44 9: 5 4 fL,_ Date: /0 Addres:Informstion Request Please furnish this agency with the new oddress, if available, for the following individual or verify whether the address given below is one at which mail fsr this individual is currently being delivered. If the following address is s post office box, please tmish the sheet address as recorded on the box holder's applieation form. h Name S?iy /1'?. .S /srilJ,?O.l /" Last Known Address: G ? ' ST G /`'£fo ,40"- pvj ?tvt C D P r I eerdfy the address information for this individual is required for the perforroanae of this agency's ut'T`c ial duties. C PC (Signature of . y Official) (Title) For Post Office Use Only Mail is delivered to address given. New Address () Not Known at Address Given () Moved, Left No Fommding Address _ () No Such Address () Other (Specify) Box holds' Street Address Agency Return Address Postxnark/Date Stamp Please fax results to the Cumberland County Sheriit'e Office. Number (717) 240-6397 Address Information Request (Required format) Exhibit 352.44b F "V .n, NC028604 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 NCO Portfolio Management Assignee of Citibank COURT OF COMMON PLEAS CUMBERLAND COUNTY VS. SARAH M SIMONDS DOCKET NO. : 07-6190 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 $16,745.87 Interest from 10/28/03 ®29.99$ $20,790.06 Costs (Complaint & Service) $178.50 Total: $37,714.43 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: NCO Portfolio ManagementAssignee of Citibank and that the last known address of defendant, SARAH M SIMONDS, 120 E LOUTHER ST, CARLISLE PA 17013-3051. 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. 'Y ?S? 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 _N'54 day of LQP- , 2007 Judgment is entered in favor of the plaintiff(s) and against defendant(s) by default for want of an answer and damages assessed at the sum of , $37,714.43 as per the above certification. 5 i?r thonotary 0" GORDON & WEINBERG, P.C. BY: FREDERIC V. WEI ERG, ESQUIRE JOEL M. LINK, E QUIRE Attorne for P intiff ... i NC0266b4 GORD N & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 41200 1001 E. Hector Street, Ste 220 Cons ohocken, FA 19428 484/i 51-0500 she s? a? NCO ortfolio Management Assignee of COURT OF COMMON PLEAS Citi ank CUMBERLAND COUNTY ? va. DOCKET NO. 07-6190 CIVIL TERM I ses SARA! K M SIMONDS i NQTICB OF PM=ION TO TAKE DEF]IQLT TO/ ARA SARAH M SIMONDS 120 E LOUTHER ST i CARLISLE PA 17013-3051 DATE OF NOTICE/FECHA DEL AVISO: November 30, 2007 ZWORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PER ONALLY OR BY AN ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR 63JECTIONS 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 LA ER, 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 PRO IDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO BLI?IBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION ea+ e? 32 S. BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 GORDON & WEINBERG, P.C. BY: FRPERIC . WEINBERG, ESQUIRE J L M. FLINK, ESQUIRE P10 -2 ,` ? ? O -,? a T? ? _ ? i , ? _ ? ? ? . ; ? ? _., ., 5u ? _ ^ r_ rn ? D a =?' r `? J ? ? r.? ,?' --? 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 NC028604 NCO Portfolio Management Assignee of Citibank Vs. SARAH M SIMONDS COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 07-6190 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. LL Judgment by Default $37,714.43 Money Judgment $ Judgment on Award of Arbitrators$ 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 S OTHONOTARY