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Home My WebLink About07-6927IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CSGA, LLC CIVIL ACTION - LAW 2200 Fletcher Avenue, 5th Floor Fort Lee, NJ 07024 Plaintiff NO. Mickey Rankine 302 N. Baltimore Ave. Apt 3 : Mt Holly Springs, PA 17065 Defendant NOTICE TO DEFEND YOU have been sued in Court. If you wish to defend against the claim 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 3 ou. 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 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. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD Ti, 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 Referral Service Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166; (800) 990-9108 & MIGLIACCIO, LLP Io Jrdan W. Felzer, Esquire rnev ID # 38670 etzerUwioomiaw.com hree Neshaminy Interplex, Suite 301 Trevose, PA 19053 Telephone (800) 834-4066 CIVIL ACTION - COMPLAINT Plaintiff, CSGA, LLC, as Assignee of DISCOVER , by and through its attorneys, Bronson and Migliaccio, LLP, represents as follows: 1. Plaintiff, CSGA, LLC, is a limited liability company organized and existing under the laws of the State of New York with a principal place of business at 2200 Fletcher Avenue, 5`n Floor, Fort Lee, NJ 07024. 2. Defendant, Mickey Rankine, is an adult individual residing at 302 N. Baltimore Ave. Apt 3, Mt Holly Springs, Pennsylvania 17065. 3. Plaintiff, CSGA, LLC purchased certain accounts by which it is the lawful successor in interest to DISCOVER , and thereby possesses all rights pertaining thereto, including all rights to an account belonging to Defendant, as more specifically described below. COUNT I - BREACH OF CONTRACT CSGA, LLC v. Mickey Rankine 4. Defendant utilized an extension of credit made available by DISCOVER, bearing account 6011004230608719, whereby Defendant would from time to time be advanced credit for purchases or expenditures in exchange for the promise to repay funds so utilized at an agreed upon rate of interest. All of the above was done at the specific request therefore by the Defendant. 5. There is a principal balance due and owing on the account in the amount of $11,734.12 plus accrued interest. A statement of account is attached hereto and marked as Exhibit "A" and is incorporated herein by reference. 6. There is an interest balance due and owing on the account in the amount of $19472.48. A statement of account is attached hereto and marked as Exhibit "A" and is incorporated herein by reference. 7. Plaintiff has made demand upon the Defendant for Payment. More specifically, a written demand was made at least thirty (30) days prior to the filing of this Complaint. 8. and has neglected and refused to pay the outstanding balance. received on the account. No recent payments have been WHEREFORE, Plaintiff CSGA, LLC respectfully requests judgment against the Defendant, Mickey Rankine, in an amount not exceeding the limits for mandatory arbitr anon, as follows: a. The principal sum of $11,734.12, plus; b. Interest accrued in the amount of $1,472.48; C. Costs and interest at the legal rate; or d. For such other and further relief as this Court deems just and proper. COUNT II - UNJUST ENRICHMENT CSGA, LLC v. Mickey Rankine 9 Plaintiff hereby incorporates paragraphs one through eight above as though more fully set forth at length hereinafter. Defendant is in breach of the terms of the agreement for the extension of credit 10. The principal balance of $11,734.12 represents the reasonable value of goods and services, the benefit of which is inured to the Defendant at the expense of DISCOVER, creating an equitable claim which Plaintiff now holds as successor in interest. 11. The balance of $1,472.48 represents interest accrued as of the date of this filing. WHEREFORE, Plaintiff CSGA, LLC respectfully requests judgment against the Defendant, Mickey Rankine, in an amount not exceeding the limits for mandatory arbitration, rY anon, as follows: a. The principal sum of $11,734.12, plus; b. An amount of interest on the principal balance equal to the legal rate and running from date the account was closed by the Original Creditor until present, represent in the time-value of money on the credit extension utilized by the Defendant. g c. Costs and interest at the legal rate going forward from today; or d. For such other and further relief as this Court deems just and proper. On UN NUN & MIGLIACCIO, LLP Ar eys for Plaintiff B rdan W. F elzer, Esq., ID# 38670 jf @lobmlaw.com T Neshaminy Interplex Suite 301 Trevose, PA 19053 (800) 834-4066 VERIFICATION I, Jeremy Hanauer, in my capacity as a Corporate Officer of CSGA, L.L.C., verify that the averments of fact contained in the foregoing Complaint are true and correct to the best of my knowledge information and belief. This statement is made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. Date:-LI -14-0? CSGA, LLC ACCOUNT INFOYtMATION REPORT ACCOUNT#: 13452143060309420 FINANCIAL Forwarder: CSGA, LLC Acct#: 6011004230608719 Original Creditor: DISCOVER Debt Type: CC Principal $11,734.12 Interest $1,472.48 Attorney $0.00 Court $343.50 STATUS: RETURNED TO COLLECTOR WIP# Days Left Misc $0.00 Assigned to: LPASTEVENS 1065 0 BALANCE $13,550.10 Personal Information Debtor 1 First MI Last Name MICKEY RANKINE Address 302 N. BALTIMORE AVE. APT 3 City MT HOLLY SPRINGS ST PA Zip 17065 Country Province Work Tel Home Tel (717)486-8102 Ext Fax SS# a? Driver's License # DOB 02/24/1954 State Spouse Bank and Asset There is no bank information on this account. Debt Service Provided CREDIT CARD Placement Breakdown Principal $11,734.12 Awarded Int Attorney Fees Court Costs Misc Costs Accrued Int $1,472.48 Total Placement $11,734.12 Original Loan Terms Contract Date Number of Payments Interest Rate % 0.05 Collateral Placement 03/16/2006 $11,734.12 Last Payment $0.00 Debt Type Credit Cards Last Payment Date 08/18/2003 Last Payment Amount Last Charge Date Last Charge Amount Original Loan Amount Amount of Payments Serial/Vin Number Page 1 of 1 10/26/2007 01:31:07 W P11 `C ?a r•a ca C:) r 0 r.Tl IG u CD VERIFICATION I, Jeremv Hanauer, in my capacity as a Corporate Officer of CS the averments of fact contained in the foregoing Complaint are true and correct to the best of my knowledge information and belief. This statement is made subject to the penalties of 18 Pa.C.S. § 4904 relating to unworn falsification to authorities. Date: 11 -14 -01 CSGA, LLC SHERIFF'S RETURN - REGULAR CASE NO: 2007-06927 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CSGA LLC VS RANKINE MICKEY JACOB BAKER Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE RANKINE MICKEY was served upon DEFENDANT the at 1025:00 HOURS, on the 3rd day of December-, 2007 at CUMBERLAND CO SHERIFF'S OFFICE ONE COURTHOUSE SQUARE CARLISLE, PA 17013 by handing to MICKEY RANKINE 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 b1 Sworn and Subscibed to before me this of So Answers: 18.00 5.76 ??????? .00 10.00 R. Thomas Kline .00 33.76 12/04/2007 BRONSON & MIGLIACCIO By: A 'y 2ia y ?Q day Dep ty heriff A.D.