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THIS IS AN ARBITRATION MATTER. ASSESSMENT OF
DAMAGES HEARING REQUIRED.
CORDON & WEINBERG, P.C.
BY: FREDERIC I. WEINBERG, ESQUIRE
Identification No.: 41360
JOEL M. FLINK, ESQUIRE
Identification No.: 4120.0
1001 E. Hector Street, Ste 220
Conshohocken, PA 19428
484/351-0500
Atlantic Credit & Finance Inc.
Assignee from Household Bank
3353 Orange Avenue
Roanoke, VA 24012
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
vs.
M H LYNCH
309 N MORRIS ST
SHIPPENSBURG PA 17257-1635
DOCKET NO . ~'] -'JJr30 ~jVl ~ "rP~M
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
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
$2,090.68.
6. Plaintiff has made demand upon the defendant(s)for
payment of the balance due of $2,090.68 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 11/13/05.
WHEREFORE, plaintiff claims of the defendant(s) the sum of
$2,090.68 plus applicable costs, interest and attorney's fees.
GORDON & WEINBERG, P.C.
BY:
FREDERIC I. W INBE ESQUIRE
JOEL M. FLINK, IRE
Attorney for Plaintiff
P01A.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 I BERG, ESQUIRE
.. - i
INC. ' ~ ~~1/~~
ATLANTIC CREDIT & FINANCE, ~ ~
1VI HHEATER )LYNCH
AFFIDAVIT OF DEBT AND VERIFIED BILL OF PARTICULARS
i
The undersigned being first duly sworn according to law, deposes and says that she is familiar with
the policies and practices, as well as the books and records of the Plaintiff with respect to the matters
stated herein, and based on information and belief states as follows:
1. Plaintiff s principal business consists of purchasing charged off receivables.
2. The Defendant defaulted on HOUSEHOLD BANK Account No. 540801.0019747100. Said
Account was charged off on Tune 30, 2006 in the amount of $2,090.68.
3. Plaintiff purchased or was otherwise assigned this charged off account along with other debts. As
a result of the foregoing sale and assignment, the Plaintiff succeeded to all right, title and interest
in the charged off account, and it now owns the account.
4. Plaintiff conducted a due diligence investigation to determine, among other things, the accuracy of.
the account information provided to ascertain whether the statute of limitations was a bar to
demand or institution of suit. Further, Plaintiff and/or its predecessor entered into a contract where
the predecessor made representations and warranties that 1) it had clear right, title and interest in
the account; 2}the account was free and clear of all liens and encumbrances; and 3) it had the
power, authority, and full right to sell and convey its interest in the account.
5. According to Plaintiff s records, the last payment date was November 13, 2005. After application
of all payments, credits, adjustments, and lawful offsets, if any, there is still a balance due and'
. owing on this indebtedness of $2,090.68.
6. The internal Account Statement of Plaintiff is attached hereto as Exhibit A and displays the
account information that was provided to Plaintiff at the time of purchase and assignment.
The foregoing is true and correct to the best of my knowledge and belief.
By: Ci~~~~~G~
Heather Clary
Assistant Director of Forwarding
Subscribed and sworn before me March 29,2007.- ;, w:~~~t^~ry.,.
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• Jame hnso otary Public=. '-• wR~'~~QJ.~
M Commission Ex Tres: 2/28/20~r~INarAR'~;~•~+~
y p '~~af,~sus+
THIS COMMUNICATION IS FROM A DEBT COLLECTOR
GORAON & WEINBERG P.C.: JAFF- 2G71908
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