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Home My WebLink About03-5486GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, Identification No.: 41360 21 SOUTH 21ST STREET PHILD2DELPHIA, PA 19103 215/988-9600 NCO PORTFOLIO MANAGEMENT, ASSIGNEE OF FLEET BANK 1804 WASHINGTON BLVD. BALTIMORE, MD 21233 ESQUIRE INC. VS. GLENDA L. HOUSER 210 7TH ST. NEW CUMBERLAND PA 17070 NOTICE THIS IS AN ARBITRATION MATTER. ASSESSMENT OF DAMAGES HEARING REQUIRED. COURT OF COMMON PLEAS CUMBERLAND COUNTY YOU ~AVE 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) 24903166 THIS IS AN ARBITRATION MATTER. ASSESSMENT OF DAMAGES HEARING REQUIRED. GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 21 SOUTH 21ST STREET PHILADELPHIA, PA 19103 215/988-9600 NCO PORTFOLIO MANAGEMENT, ASSIGNEE OF FLEET BANK 1804 WASHINGTON BLVD. BALTIMORE, MD 21233 vs. GLEN]DA L. HOUSER 210 7TH ST. NEW CUMBERLAND PA 17070 INC. COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO.: COMPLAINT IN CIVIL-ACTION 1. 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's predecessor in interest, under the terms of which the plaintiff agreed to extend to defendant(s)the use of plaintiff's credit facilities. 2. 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. 3. 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. 4. All the credits to which the defendant(s)is entitled have been applied and there remains a balance due in the amount of $3,823.85. 5. Plaintiff has made demand upon the defendant(s)for payment of the balance due of $3,823.85 but the defendant(s)has failed and refused and still refuses to pay the same or any part thereof. WHEREFORE, plaintiff claims of the defendant(s)the sum of $3,823.85, plus 20% interest from the date of 11/6/99, court costs, and attorney's fees all of which is justly due and owing from defendant(s) to plaintiff. P01A GORDON & WEINBERG, BY: FRED , ESQUIRE Attorney for ~iff 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. WEI~/~IRE SHERIFF'S RETURN - REGULAR CASE NO: 2003-05486 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND NCO PORTFOLIO NLANAGEMENT INC VS HOUSER GLENDA L JASON VIORAL , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon HOUSER GLENDA L DEFENDANT , at 2000:00 HOURS, at 210 7TH STREET NEW CUMBERLAND, PA 17070 GLENDA HOUSER a true the on the 20th day of October , 2003 by handing to 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 11.73 Affidavit .00 Surcharge 10.00 .00 39.73 Sworn and Subscribed to before me this j 5~J. day of othonotary ~ So Answers: R. Thomas Kline 10/21/2003 GORDON & WEINBERG By: ~ eputy Sheriff GORDON & WEINBERG, P.C. By: FREDERIC I. WEINBERG, Identification No.: 41360 21 SOUTH 21ST STREET PHILADELPHIA, PA 19103 215/988-9600 ESQUIRE NCO PORTFOLIO MANAGEMENT, ASSIGNEE OF FLEET BANK VS. GLENDA L. HOUSER INC. COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO.: 03-5486 Civil NOTICE PURSUANT TO RULE 236 OF THE SUPREME COURT OF PENNSYLVANIA, YOU ARE HEREBY NOTIFIED THAT A JUDGMENT BY DEFAULT HAS BEEN ENTERED AGAINST YOU IN THE ABOVE PROCEEDING. IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL FREDERIC I. WEINBERG, ESQUIRE AT 215/988-9600. GORDON & WEINBERG, BY: Dated: December 2, 2003 GORDON & WEINBERG, P.C. By: FREDERIC I. WEINBERG, Identification No.: 41360 21 SOUTH 21ST STREET PHILADELPHIA, PA 19103 215/988-9600 ESQUIRE NCO PORTFOLIO MANAGEMENT, ASSIGNEE OF FLEET BANK VS. GLENDA L. HOUSER INC. COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO.: 03-5486 Civil PRAECIPE FOR JUD~4ENT The Prothonotary will please enter Judgment in the above matter by default for want of an answer against the Defendant, GLENDA L. HOUSER, and assesse~s as per statement below. FREDERIC I. WEI~J~G, ESQUIRE Attorney for PI~mntiff Principal $3,823.85 Court costs $155.50 Interest from November 6, 1999 @20% $3,115.65 Total: $7,095.90 I hereby certify that written notice of the intention to file this Praecipe was mailed or delivered to the parties against whom judgment is to be entered and to his attorney of record, if after the default occurre~d at least ten (10) any, days prior to the date of the filing of ~hi~ Pra~cipe. FREDERIC I.~WEIN~G,~ESQUIRE Attorney for P1 ~n~ff Filed: By the Prothonotary: AND NOW, this ~ day of k~'~-- , 2003 Judgment is entered in favor of the plaintiff(s) defendant, trial. and against for want of an answer and damages assessed at time of Pro't honot'a r~ ~ GORDON & WEINBERG, P.C. By: FREDERIC I0 WEINBERG, Identification No.: 41360 21 SOUTH 21ST STREET PHILADELPHIA, PA 19103 215/988-9600 ESQUIRE NCO PORTFOLIO MANAGEMENT, ASSIGNEE OF FLEET BANK VS. GLENDA Lo HOUSER INC. COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO.: 03-5486 Civil CERTIFICATION OFADDRESS I hereby certify that the precise residence of the holder of the within judgment is; NCO PORTFOLIO MANAGEMENT, INC., ASSIGNEE OF FLEET BANK, 1804 WASHINGTON BLVD., BALTIMORE, MD and that the last known address of defendant, GLENDA L. HOUSER, 210 7TH ST., NEW CUMBERLAND PA 17070. GORDON & BY: WEINBERG, P.C. GORDON & WEINBERG, P.C. By: FREDERIC I. WEINBERG, Identification No.: 41360 21 SOUTH 21ST STREET PHILADELPHIA, PA 19103 215/988-9600 ESQUIRE NCO PORTFOLIO MANAGEMENT, ASSIGNEE OF FLEET BANK vs. GLENDA L. HOUSER INC. COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO.: 03-5486 Civil AFFIDAVIT OF NON-MILITARY SERVICE FREDERIC I. WEINBERG, ESQUIRE, being duly sworn according to law, deposes and says that he represents the plaintiff in the above-entitled case; that he is authorized to make this affidavit on behalf of the plaintiff; and that the above-named defendant is over twenty-one years of age; that the address of the defendant is, 210 7TH ST., NEW CUMBERLAND PA 17070; that the occupation of the defendant is unknown; and that the defendant is not in the Military Service of the United States, nor any State or Territory thereof or its allies as defined in the Soldiers' and Sailors' Civil Relief Act of 1940 and the amendments thereto. Sworn to and Subscribed Before me this ~ l~ODay of 2003. CI~ of ~il~e~ Phila, ~oun~ FREDERIC ~ESQUIRE Attorney for Plaintiff GORDON & WEINBERG, P.C. By: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 21 SOUTH 21ST STREET PHILADELPHIA, PA 19103 215/988-9600 NCO PORTFOLIO MANAGEMENT, INC. ASSIGNEE OF FLEET BANK VS. GLENDA L. HOUSER COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO.: 03-5486 Civil NOTICE OF INTENTION TO TAKE DEFAULT TO/PARA : GLENDA L, HOUSER DATE OF NOTICE/FECHA DEL AVISO: November 13, 2003 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN THIS CASE. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE AS SET FORTH ABOVE, 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 A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: AVISE IMPORTANTE USTED ESTA EN REBELDIA PORQUE HA FALLADO EN TOMAR LA ACTION EXIGIDA DE SU PARTE EN ESTE CASE. A MENOS DE QUE USTED ACTUE DENTRO DE DIEZ DIAS DE LA FECHA DE ESTE AVISO, SE PUEDE REGISTRAR UNA SENTENCIA CONTIL~. USTED, SIN EL BENEFICIO DE UNA AUDIENCIA Y PUEDE PERDER SU PROPIEDAD O DERECHOS IMPORTANTES. USTED DEBE LLEVAR ESTE AVISO A UN ABOGADO ENSEGUIDA. SI USTED NO TIENE UN ABOGADO Y NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, DEBE COMU'NICARESE CON LA SIGUIENTE OFICINA PARA AVERIGUAR DONDE PEUDE OBTEN ER AYUDA LEGAL: CUMBERLAND COUNTY BAR ASSOCIATION 32 S. BEDFORD STREET CARLISLE, PA 17013 (717) 24903166 P10D GORDON & WEINBERG, P.C. BY: FREDEP(IC~RE GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQ. & PAUL M. SCHOFIELD, JR., ESQ. I.D.//41360 & 81894 21 SOUTH 21st STREET PHILADELPHIA, PA 19103 (215) 988-9600 NCO PORTFOLIO MANAGEMENT, INC. ASSIGNEE OF FLEET BANK 1804 WASHINGTON BLVD. VS. GLENDA L. HOUSER 210 7TM STREET NEW CUMBERLAND, PA 17070 and NEW CUMBERLAND FEDERAL CREDIT UNION 345 LEWISBERRY ROAD NEW CUMBERLAND, PA - GARNISHEE ATTORNEYS FOR PLAINTIFF COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 03-3E25 CIVIL TERM PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue writ of execution in the'above matter, directed to the Sheriff~t~nberland~County; ~~Or (1) against GLENDA L. HOUSER (2) against defendam(s) and NEW CUMBERLAND FEDERAL CREDIT UNION garnishee(s) (3) AMOUNT DUE $7,095.90 INTEREST from (Costs to be added) TOTAL Attorney(s~s) WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 03-5486 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF YORK COUNTY: To satisfy the debt, interest and costs due NCO PORTFOLIO MANAGEMENT, INC., ASSIGNEE OF FLEET BANK Plaintiff(s) From GLEN-DA L. HOUSER, 210 7TM STREET, NEW CUMBERLAND PA 17070 (1) You are directed to levy upon the property of the defendant (s)and to sell (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of NEW CUMBERLAND FEDERAL CREDIT UNION, 345 LEWISBERRY ROAD, NEWCUMBERLAND PA 17070GARNISHEE(S) as follows: KINDLY SERVE INTERROGATORIES UPON GARNISHEE BANK. and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due7,095.90 Interest Atty's Corem % Atty Paid $122.23 PlaintiffPaid Date: OCTOBER 27, 2004 L.L. $.50 Due Prothy $1.00 Other Costs (Seal) REQUESTING PARTY: Name FREDERIC I. WEINBERG, ESQ. Address: 21 SOUTH 21sx STREET PHILADELPHIA PA 19103 Attorney for: PLAINTIFF Telephone: (215) 988-9600 Supreme Court ID No. 41360 CURTIS R. LONG f( By: Deputy Expires 1125/05 COUNTY OF YORK OFFICE OF THE SHERIFF SERVICE CALL (717) 771-%111 45 N. GEORGE ST., YORK, PA 17401 DUPLICATE INSTRUCTIONS PLEASE.TYPE ON..Y LINE 11lJRlj 12 DO , PlA.NlIFFiSl 2 COURT NUMBER2004 SU 3589 Y08 NCO POHTFOLIO MANAGEMENT INC 3 DEFENDANT/Sf 'I:n't':frro;:lg~i~~PLAINT ::l-+ \ GLENDA L HOUSER Writ of Execution SERVE { 5 NAME OF INDIVIOUAl. COMPANY, CORPORATION. ETC TO SERVE. OR DESCRIPTION OF PROPERTY TO BE LEVIED. ATTACHED. OR SOLO ....... NDI CUMBERLAND FEDERAL CHEDIT UNION GAANISHEE ..". 6 ADDRESS (STREET OR RFO VV1TH BOX NUMBER. APT NO. CITY, BORO. TWP , STATE AND liP CODE) AT 1 Longstovm M York FA 17402 7 INDICATE SERVICE Q PERSONAL lJ PERSON IN CHARGE U DEPUTIZE 'J CERT MAIL U 1 ST CLASS MAil U POSTED U OTHER SHERIFF SERVICE PROCESS RECEIPT and AFFIDAVIT OF RETURN ,20_ I, SHERIFF OF YORK COUNTY, PA. do hereby deputize the sheriff of COUNTY to execute this Writ and make return thereof'accordlng to law. This deputization being made at the request and risk of the plainliff.. NOW SHERIFF OF )lORK COUNTY 8 SPEClAtlNSTRUCTIONS OR OTHER INFORMA nON THAT Will ASSIST IN EXPEDITING SERVICE SERVE GAANSIHEE ONLY DEF ADDRESS: 210 7th Street New Cumberland PA 17070 NOTE: ONLY APPUCABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN - Any deputy shenff le\fYing upon Of attaching any property under within wnt may leave same without a watchman. in CU$tody of whomever is foul'ld in po5!>eSSion. af\ef notifying pel son of levy Of attachment, Without liabrlity on the part of such deputy or the shenff to any plaintiff herein for any loss. destrudion. Of' removal of any property before sheriff's sale thereof 9 TYPE NAME and ADDRESS of ATfORNEY / ORIGINATOR and SlGNATURE. 10. TELEPHONE NUMBER 11. DATE FILED Fred Weinberg 215 988 9600 12 SEND NOTICE OF SERVICE COpy TO NAME AND ADDRESS BElOW (thiS area must be completed if nolice is to be mailed) .Gordan & weinberg PC 21 South 21st Street ?hila PA 19103 . SPACE8ELOW FOR USE elF THE SlEAFr - DO NOT WRITE BELOW TttS LIE 13. I acknowtedge receipt of the writ 1.. DATE RECEIVED Ofcompla""5;nO,caledabove S Bickel 12/2/04 10/27/04 15 Expiration/Hearing Date 1/25/05 16 HOW SERVED 17. ,. RESIDENCE ( ) POSTED ( POE( ) SHERIFF'S OFFICE ( ) OTHER { SEE REMARKS BelOW 21 TIE 22 PP 748 $1'1. Advance Coo.. DO Atty JJ C9fk~ll{ Refund Check No 46.06 172707 40 Costs Due or Refund 42 day of !/-. Notarial Seal James v. Vangreen, Notary Public ~ City of York, Yo,:, county, PA My Commission <.:;5 Mar. 21, 2005 SQ. I ACKNOIM.E:DGE RECEIPT OF THE SHERIFF'S RETURN SIGNATURE OF AUTHORIZED ISSUING AUTHORITY AND TiTlE 1. \NHITE . Issuing Authority 2. PINK. Attocney 3. CANARY. Sherift'sOffice 4. BLUE. SheoffsOffice 1/28/05 49 DATE 151. DATE RECEIVED 12/7/04, 9:55 AM - SERVED TWO TRUE AND ATTESTED COPIES OF THE WITHIN WRIT OF EXECUTION AND INTERROGATORIES UPON NICHOLAS L. MANGUS, MANAGER FOR NEW CUMBERLAND FEDERAL CREDIT UNION, THE WITHIN NAMED GARNISHEE, AT 1 LONGSTOWN ROAD, YORK, PENNSYLVANIA, AND ATTACHED AS DIRECTED. SHERIFF'S COSTS $103.94 (PAID) SO ANSWERS, ~~ JANUARY 28, 2005 WILLIAM M. HOSE, SHERIFF ) .j~ .2, JO()) ~ eel )n~,~ f?~~ WRIT OF EXECUTION andlor ATTACHMENT da.:ti-0U ~ 3es;}q-Y Q!? COMMONWEALTH OF PENNSYL VANIA) COUNTY OF CUMBERLAND) NO 03-5486 Civil CIVIL ACTION -LAW TO THE SHERIFF OF YORK COUNTY: To satisfy the debt, interest and costs due NCO PORTFOLIO MANAGEMENT, INC., ASSIGNEE OF FLEET BANK Plaintiff(s) From GLENDAL.HOUSER,2107THSTREET,NEWCUMBERLAND PA 17070 (I) You are directed to levy upon the property of the defendant (s)and to sell (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of NEW CUMBERLAND FEDERAL CREDIT UNION, 345 LEWISBERRY ROAD, NEWCUMBERLAND P A 17070GARNISHEE(S) as follows: KINDLY SERVE INTERROGATORIES UPON GARNISHEE BANK. and to notify the garnishee(s) that: (a) an attachment has been issned; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify hirn/her that he/she has been added as ,,"0; garnishee and is enjoined as above stated. Amount Due7,095.90 Interest Atty's Comm % Atty Paid $122.23 Plaintiff Paid Date: OCTOBER 27, 2004 YORK COUNTY PROTHY FEES $ 33.50 YORK COUNTY SHERIFF FEES Q L.L. $.50 Due Prothy $1.00 Other Costs CURTIS R. LONG (Seal) Proth By: ot~JJ DeputY REQUESTING PARTY: Name FREDERIC I. WEINBERG, ESQ. Address: 21 SOUTH 21 ST STREET PHILADELPHIA PA 19103 Attorney for: PLAINTIFF Telephone: (215) 988-9600 Supreme Court ID No. 41360 ,..-:-') ,...> TRUE L.OPY FROM R!pORn. f'Il O' '",,"NB,'l, i hero l.mto~l mfhand J""',,,> "'Ci.1rIINe~"; " .,."d.. 1 Q' 'ot '" i;J.,J:{_.-.~Ia.y N' -6. . 3="cfJ' -- . -- .: r;l . .~. thon ~ ~:; U -q