HomeMy WebLinkAbout08-0413IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
UNIFUND CCR PARTNERS
ASSIGNEE OF PALISADES CIVIL ACTION
COLLECTION, LLC
10625 Techwoods Circle
Cincinnati, OH 45242
Plaintiff
NO: 0$ k13 Civil ler"
VS.
PAULA A LEHMER
915 ALISON AVE
MECHANICSBURG PA 17055
Defendant :
NOTICE TO DEFEND
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 to
Defend are served, by entering a written appearance personally or by an 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 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 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.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO
PROVIDE YOU WITH INFORMATION ON AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT REDUCED FEE OR NO FEE.
MIDPENN LEGAL SERVICES
401 EAST LOUTHER STREET
CARLISLE, PA 17013
717-243-9400
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
UNIFUND CCR PARTNERS
ASSIGNEE OF PALISADES CIVIL ACTION
COLLECTION, LLC
10625 Techwoods Circle
Cincinnati, OH 45242
Plaintiff
: NO:
vs.
PAULA A LEHMER
915 ALISON AVE
MECHANICSBURG PA 17055
Defendant
COMPLAINT
Plaintiff, UNIFUND CCR PARTNERS ASSIGNEE OF PALISADES COLLECTION,
LLC, by and through its attorneys, Edwin A. Abrahamsen & Associates, P.C., complains of the
Defendant as follows:
1. Plaintiff, UNIFUND CCR PARTNERS ASSIGNEE OF PALISADES
COLLECTION, LLC, (hereinafter "Plaintiff') is a Ohio corporation with a principal place of
business located at 10625 Techwoods Circle, Cincinnati, OH 45242.
2. The Defendant PAULA A LEHMER (hereinafter "Defendant") is an adult
individual residing at 915 ALISON AVE MECHANICSBURG PA 17055.
3. At all relevant times herein, Plaintiff was engaged in the business of debt purchase
and collection.
4. Defendant applied for and received a credit card issued by CITIBANK SOUTH
DAKOTA NA with the account number 5491130341872562.
5. The within account was sold by CITIBANK SOUTH DAKOTA NA to Unifund for
valuable consideration and all rights under said accounts were assigned to Unifund. (See, Bill of
Sale, Affidavit and Assignment attached hereto as Exhibit "A.")
6. Use of the CITIBANK SOUTH DAKOTA NA credit card was subject to the terms
of the Cardmember Agreement, a copy of which was sent to the Defendant along with the credit
card. (See, Cardmember Agreement attached hereto as Exhibit "B.")
7. Defendant used the CITIBANK SOUTH DAKOTA NA credit card account
number5491130341872562, for purchases, cash advances and/or balance transfers.
8. The Defendant was mailed account statements relative to the Defendant's use of the
subject credit card. (See, Card Statements attached hereto as Exhibit "C.")
9. The Defendant defaulted under the terms of the Agreement by failing and refusing
to make monthly payments on the account as they became due.
10. The account became delinquent on October 10, 2005.
11. The principal amount was $16,362.31 at the time it was received by Plaintiff.
12. Pursuant to the account agreement, any unpaid balance accrues interest at the rate
of 32.31.
13. The total amount due and owing the Plaintiff including interest, is $29,377.34.
14. Pursuant to the terms of the Agreement, Defendant is liable for Plaintiffs court
costs and reasonable attorney's fees in the amount of 25% of the balance.
WHEREFORE, Plaintiff requests judgment in its favor and against Defendant in the
amount of $29,377.34 plus costs of suit, reasonable attorneys' fees of $7,344.34 and any other
relief as the Court deems just and appropriate.
Respectfully submitted,
Assoc.
Edwin A. Abr/ire
Michael F. Rquire
Scott J. Best, Attorney I.D. /93
600
1729 Pittston Avenue
Scranton, PA 18505
mratchford@eaa-law.com
sbest@eaa-law.com
rvkbi A
BILL OF SALE
THIS BILL OF SALE is effective as of Junel, 2007 between UNIFUND
PORTFOLIO A, LLC, an Ohio Limited Liability Company ("Assignor") and CLIFFS
PORTFOLIO ACQUSITION I, LLC, a Delaware limited liability company
("Assignee"). Unless otherwise defined herein, terms used herein shall have the
meanings specified in the Sale, Assumption, and Assignment Agreement effective as of
Junel, 2007, between Assignor and Assignee (the "Agreement").
Assignor, for value received and in connection with the Agreement, transfers,
sells, assigns, conveys, grants, and delivers to Assignee free, clear and unencumbered
title to the Cliffs Subpool as defined in the Agreement and all of Assignor's rights thereto
effective as of 12:01 AM on Junel, 2007 (the "Effective Time"). The sale is without
recourse to Assignor and without warranty of any kind (including, without limitation,
warranties pertaining to title, validity, collectibility, accuracy or sufficiency of
information, and applicability of any statute of limitations), except as stated in the
Agreement or herein.
PORTFO IO LLC
:By: y N. Th an
Director, Acquisitions
rX&h1#f
BILL LL OF SALE, ASSIGNMENT AND ASSUMPTION AGREEMENT
THIS BILL OF SALE, ASSIGNMENT AND ASSUMPTION AGREEMENT is dated as of June
1, 2007, between Citibank (South Dakota), N.A., a national banking association organized under
the laws of the United States, located at 701 East 60th Street North, Sioux Falls, SD 57117 (the
"Bank") and Unifund Portfolio A, LLC, located at 10625 Techwoods Circle, Cincinnati, OH
45242 ("Buyer").
For value received and subject to the terms and conditions of the Purchase and Sale Agreement
dated June 1, 2007, between Buyer and the Bank (the "Agreement"), the Bank does hereby
transfer, sell, assign, convey, grant, bargain, set over and deliver to Buyer, and to Buyer's
successors and assigns, good and marketable title to the Accounts described in Section 1.2 of the
Agreement, free and clear of all encumbrances, equity, lien, pledge, charge, claim, or security
interest.
This Bill of Sale, Assignment and Assumption Agreement is executed without recourse and
without representations or warranties including, without limitation, warranties as to collectibility.
Citibank (SoRM Dakota),
By:
Name: / OOt;5:19
T Finance
(605) 331-2855
Title:
Unifund Portfolio A, LLC
t?
By:
Signature) r?
Name: 'e- ? ? Zt
Title:
h1W61*1
AFFIDAVIT OF INDEBTEDNESS
State of Ohio )
County of Hamilton ) ss.
Kim Kenney, being sworn, deposes and says that she is an authorized representative of Unifund CCR
Partners, servicer, which is doing business at 10625 Techwoods Circle, Cincinnati, Ohio 45242, and that she
is authorized to make the following statements and representations which are within her personal
knowledge, and that she is competent to testify to the matters stated herein.
To the best of her knowledge the Defendant is not now in the Military Service as defined in the Soldier's
and Sailor's Civil Relief Act of 1940 and amendments thereto.
There is due and payable from PAULAA LEHMER, Account Number 5491130341872562, the amount of
$27842.03.
This account was issued under the name of CITIBANK SOUTH DAKOTA NA and acquired from Citibank
(South Dakota) NA: Said accourit.has been forwarded to Law Ofcs of-Edwiri'"A: Ahrahariisen,& A; as
attorney for Plaintiff Unifund CCR Partners assignee of Palisades Collection LLC, for the purpose of the
commencement of a legal suit, with full power and authority to do and perform all acts necessary for the
collection, adjustment, compromise or satisfaction of said claim as permitted by law.
I do solemnly declare and affirm under the penalties of perjury that the matters set forth above are true and
correct to the best of my knowledge.
4W ATE this 10/22/2007
UyffUND CCR PARTNERS
By: Kim Kenney, Authorized Representative
Title
10625 Techwoods Circle, Cincinnati, OH 45242
Address
I hereby certify that on 10/22/2007, before/me, the s bscriber, a Notary Public for the
State/County aforesaid, personally appear d the abov stated affiant, and made oath in due
form of law. A
My commission Expires
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STATE OF OHIO
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>T&T Universai Card Cardmemiier Agreement
-as .Agreement along with your card carrier and any ocher written
count materials contains the terms which ;Quern your AT&T Universal
ra and Account. Please read these documents and keep :hem with
ur other important papers.
Definitions. In this Agreement, the word "C ard*' means a singie Card
r %wo or more Cards we have issued to you under this Agreement. The
-as "you." "Your:' "yours" and "cardmember' mean each individual who
its for a (ard.The words "we:-:)ur- or "us" mean the issuer of the
>;i Universal Card.The word "Account' means the AT&T !Jniversai
:d Account for which you were issued a Card im?orinted with your
: aunt Number. the words "Authorized User' mean any person to
-torn you give permission to use your Accoune.The worts "Transaction
?,ce' mean the date the goods or services were purchased or -the riace
ash Advance was made. The words"Poscng Date" mean the date
t the charge was debited ardfor credited to your Account. The vvo'ds
esignaced Telephone plumber" mein the ceieohone number to which
ur Dial-I service is billed, which may or may not be your home
aohone number i he words "Calling Transactions' mean the Calling
.A Calls you make with your Card and all ocher calls billed co your
-count to the extent you otherwise agree, if made from or billed to
,Air DesignacedTelephone Number.
'four Responsibility for the Account. •!ou are responsible for ail
mounts owed on your Account whether is is used by you or by an
-,chorized User, and you agree co pay such amounts according to the
:rims of this Agreement If this is a joint Accounc, each of you, together
d individually, is responsible for ail amounts owed. even if the Account is
.pd by only one of you. In order co cancel permission of an Authorized
;:er to use your AT&T Universal Card Account. you must notify us in
sing and you must return to us. with your written notice. any Card in
a possession of the Auchonzed User. fbij will continue co be liable for
Purchases and Cash Advances made by an Authorized User, and aft
)crer resulting Accounc fees and charges, until we receive your !ewer and
Card. If we ask, you must cut the lard in hall and return it to us-You
-st sign each Card as soon as you receive it.
'ou will continue to be liable for the entire balance of your .Account,
en if your cc-applicant is ordered by a court co pay us. if a court orders
••ur co-appikant to pay all or a portion of your Account balance, you viil
^rnain liable co us 4 your co-applicant fails to pay as ordered by the
:art, and your Account status will continue to be reported to the credit
n-eau under your name.
From time co time you may hear about new products and services
a!ng offered cc you and other cardmembers. If you would prefer not to
-:ce!ve this information either by telephone or mail or both, just let us
.-10w by tailing our colt-free Customer Service number: 1900 423-4343.
Accepting This Agreement, This Agreement will be effective when
ou or an Authorized User uses the Card, or if you fail co cuc your Card
half and return it to us within 30 days after is is issued to you or when
•,)u call and activate the Card 3y the Card Acdvadon Number process.
I. RM1111 11". - 1M.,
4.Your Credit Line. You may not use your Account in any way that
,,ould cause you to go over your credit line.We may refuse to authorize
;r accept any t,' ariaction on your Account which -would cause you to
!xceed your credit line. it is your obBguion not to exceed the credit line
or your. Account If you owe more chart your credit line. you agree co pay
ne excess immediately upon our reouest and we may charge you an
werlimit fee. as described it Section 16 of this Agreement and/or
f
suspend your Account privileges or cancel your Account as described in
Section 24 of this Agreement. We may also establish a credit lima for
Cash Advances, which will be a portion of your overall credit line. If we
dc.your outstanding Cash Advance balance may not exceed this Cash
Advance !imit'We may change your credit line and your Cash Advance
limit from time to time, and we will notify you ik we do.
S. Purchases and Cash Advances.'(ou can use your Account and
your Card for personal, family or household purposes only.'(our Card
can be used co purchase or lease goods and services from participating
establishments.You may also use the Card to obtain a ban from your
Account, by prssenting it to any institution that accepts the Card for
that purpose, or to make a withdrawal of cash at an automated teller
machine (ATM). Both of time crime dons and Convenience Checks
(described in Section 7) are treated as "Cash Advances" on your
Account Any Purchase or Cash Advance (ocher than a Convenience
Check) which is made by you in a foreign currency will be converted
to U.S.dollars by either MasterCard International or VISA International.
To convert Purchases and Cash Advances made in a foreign currency.
MasterCard !nternational and VISA international use procedures and
conversion rates established in their operating regulations on or about
the date that the transactions are processed. The race currently includes
a 1% charge which MasterCard !nternaoonal or VISA lnurnadonat impose
and retain. The currency conversion race established on the processing
date may differ from the rate effective on the Transaction Date or the
Posting Date.
b. Calling Transactions. You can use your Card to make local, AT&T
Long Distance and AT&T international calls (Calling Card Cails).The
dla!ing instructions are on the back of the Card. Calling Card Calls are
separately identified in the "Call Derails" section of your monthly
stacement.All Calling Transactions are due and payable in full by the
payment due dace on the monthly statement in which they are billed.
Refer to the AT&T Calling TFansaatonsTerms and Conditions section
at the end of this document for more information.
7, Convenience Checks. We may supply you with personalized
Convenience Cheeks which are subject to the following conditions. Only
the person whose name is printed on a Convenience Check may sign it.
All Convenience Checks must be written in U.S. dollar-s. We will not
certify a Convenience Check-We are entitled co return it unpaid if there
is not enough available credit on your Account to pay it if you are in
default under this Agreement. jf your Card or Convenience Checks have
been reported lost or stolen or if the Convenience Check is postdated
(shows a future date). Any Convenience Check that we pay will be
posted to yourAccount as a Cash Advance.An AT&T Universal Card
Convenience Check cannot be used to make a payment on any AT&T
Universal Card Account Neither Universal Card Services Corp, nor
the issuer of the AT&T Universal Card shall have any liability for any
Convenience Check(s) returned in excess of your credit line.
8. Lost or Stolen Cards. If your Card is lost or stolen. or if you believe
that it is being used without your permission, you must notify us at once.
Call us at the number shown on your monthly statement You should also
follow dsis up in wricing.You should rior use the Account or Card after
you have notified us. If your Card or Account is used by an unauthorized
person you may be liable, but not for more than $50.00.You will not be
liable for any Purchase, Cash Advance or Calling Card Call made after
you have notified us of the loss or theft at the telephone number or the
address shown on your monthly statement. or t 800 423-4343.
You also agree to assist us in determining the facts, circumstances and
ocher pertinent information related to any loss, theft or possible
unauthorized use of Your Card(s) and co comply with such procedures
as we may require in connection with our investigation. We are not
responsible for controlling an Authorized User you have asked us to add
to your Account if you wish rc remove an Authorized Users abilir'v co
use your Account, you must notify us in writing and you must return co
us. wits your written notice, any Card(s) on your Account to which the
Authorized User may have access.
ii, If Your Card Is Refused. `Ne are not responsible and shall have no
liability if a merchant. a financial institution, an ATM or any third parry
refuses to honor your Card or accept a transaction on your Account.
Although you may have credit available. we may be unable to authorize
credit for a particular transaction due to operational difficulties or
mistakes. Transactions made above a certain dollar amount may require
authorization before the rransaaion is aoproved.The number of
transactions you make in one day may be limited since we may limit the
number of authorizations which may be given. These restrictions are
primarily for security reasons As a result, we cannot explain the details of
how our authorization system works. Neither we nor our agents nil] be
responsible or have any iiai:jlicy if authorrmcon for a transaction is not
giver.. If your Account is overismic or aelinquent,autthorization of credit
for transactions may be declined.
10. Cardmember Privacy, `We do not sell the names and addresses of
our rhrdmembers. and when undertaking projects with other comoanies
we do not permit them to use your name and address for any other
purposes.
11. Monthly Statements. 'We will send you a monthly statement ac the
end of each billing period (intervals of approximately one month which
we call "Billing Cycles") !f there is a debit or credit balance on your
Account of $1.00 or more. or a baiance on which a Finance Charge has
been imposed.
12. Payments. We may accept late Payments or partial payments and
payments marked "payment in Full:' or similar language, without losing
any of our rights under this Agreement. Payments should not be made by
postdated check. If we receive payment by postdated check we may
deposit it and shall have no liability if it is posted prior to the date which
appears on the check We may allocate payments to amounts owed on
your Account in the manner we deem appropriate, Payments should be
sent co us at the address shown on your monthly statement.There could
be a delay of up co five (5) days in crediting the payment to your Account
if you send a payment to us at any ocher address.All payments must be
made in U.S. dollars and drawn on a financial institution located in the
United States.
13. Minimum Payment.'(ou must make a Minimum Payment in each
Billing Cycle in which you have a New Balance on your Account. The
Minimum Payment in each Billing Cycle is 2.1% of the New Balance.
excluding Calling Transactions. as shown on your monthly statement,
rounded to the nearest whdhe dollar, plus all C311ing7ransac0ons posted
to your Account in the Billing Cycle. plus any unpaid Minimum Payment
from prior statements and any amounts which exceed your credit line.
However, the Minimum Payment will not be less chin $10.00 or the
exact amount of your New Balance. if it totals less than $10.00, plus
your Calling Transactions.You must pay at least the Minimum Payment
shown on each monthly statement by the due date to avoid delinquency.
You may pay the entire New Balance on your Account at any time.
14. How We Compute the Finance Charge. Finance Charges on
your Account for Purchases and Cash Advances are calculated separately.
am
Finance Charges for Purchases are figured by applying a Daily Periodic
Race (nominal Annual Percentage Rate divided by 365 days) to your Daily
Balances of Purchases, and adding together any such Finance Charges for
each day in the Billing Cycle. Finance Charges for Cash Advances are
figured by applying the Daily Periodic Rate to your Daily Balances of Cash
Advances. and adding together any such Finance Charges for each day in
the Billing Cycle. plus any applicable Cash Advance Fee(s).
To determine the Daily Balances of Cash Advances, we take the
beginning balance of Cash Advances on your Account each day, add any
new Cash Advances and arty unpaid Finance Charges on Cash Advances.
and subtract any payments and credits applied to Cash Advances chat day.
This gives us the Daily Balances of Cash Advances.A Finance Charge is
imposed on a Cash Advance (including a Convenience Check), or porcian
of it, from the date the Cash Advance is included in the daily Balance,
until the dace payment in full is received.
To determine the Daily Balances for Purchases, we rake the beginning
balance of Purchases on your Account each day, add any new Purchases,
any unpaid Finance Charges on Purchases, any other charges posted co
your Account and any unpaid Calling Transacoons from prior Billing
Cycles, and subtract any payments and credits applied to the Purchases
that day.This gives us the Daily Balances of Purchases.
A Finance Charge is imposed on a Purchase Tram the date the Purchase
is included in the Daily Balance until the date payment in full is received.
However. no Finance Charge is imposed on new Purchases in the Billing
Cycle in which they are posted to your Account if in the prior Billing
Cycle you had no New Balance, or if you paid the entire New Balance on
your Account by the Payment Due Date on the monthly statement for
chat cycle. The Payment Due Date will be no less than 25 days after the
closing date of your previous Billing Cycle. No Finance Charge is imposed
on Calling Transactions in she Billing Cycle in which they are posted to
your Account Any CallingTransaccion that is not paid by the Payment
Due Dace on die monthly statement in which it is billed is added co your
Daily Balance of Purchases on the first day of the next Billing Cycle.
Purchases and Cash Advances are included in the Daily Balance of the
Account as of the Transaction Date, except that Convenience Checks are
included as of the Posting Date. If a transaction (ocher than a Convenience
Check) is posted in a Billing Cycle after the cycle in which the transaction
occurred, the amount of that transactor is included in the Daily Balances
of Purchases or Cash Advances as of the transaction dace.Accrued
Finance Charges are included in the Daily Balance of Purchases or Cash
Advances daily.
The neminil Annual Percentage Rate that applies co your Account may
be changed one time in each month or quarter as indicated on your card
carrier. It will be calculated by taking the three-month London interbank
Offered Race (LBOR) published in The Wolf Street fcumol. converted to a
decimal and rounded up to the nearest 1/10 of a percent, one business
day prior to the 17rh day of j2nuary,April, July and October of each year
and adding the margin indicated on your card carrier w that race.Any
change in the nominal Annual Percentage Rate will go into effect on the
first day of your new Billing Cycle staring after the first day of the next
calendar month Of your Account changes monthly) or quarter (if your
Account changes-quarterly) and may result in an increase or decrease in
the Finance Charge imposed on your AccountThere will be a minimum
FINANCE CHARGE of 50¢ in any Billing Cycle in which a Finance
Charge at a Periodic Rate is charged.
The rate on yaar entire Account balance (ncluding any promotionai
rates) may be increased to a fixed ANNUAL PERCENTAGE RATE
of 23.9% (.06548% Daily Periodic Rate) if any ore or more of the
following events occur on any of your Accounts (1) payment is not
received by the Payment Due Date, (2) your outstanding balance exceeds
your credit line at any time during a Billing Cycle or (3) any payment you
Sena us is returned unpaid for any reason. Such increase will be effective
on the first day of the Billing Cycle during which any of your Accounts
become past due. overlimit or a payment is returned unpaid.You may
again qualify for the lower variable rate based on the index, margin and
Periodic Rate Review months disclosed on your card carrier once your
Account. for 12 consecutive Billing Cycles. has remained current, your
outstanding balance has remained at or below your credit line and no
payments have been returned unpaid.
`Ne add a fee for each Cash Advance, including Quasi-cash Cash
advances, posted to your Account Cash Advances include withdrawals of
cash from ATMs. Cash Advances provided by banks or other institutions
and Convenience Checks_ Quasi-cash Cash Advances include. but are
not limited to. wire transfers, foreign currency, traveler's checks. money
orders, casino gaming chips. off-crack betting and wagers. and tax payments.
The Cash Advance Fee%FINANCE CHARGE for Cash Advances applicabie
lo your Account is 3% of each Cash Advance amount, but never less than
$5 or more than $25. The Cash Advance FeefFiNANCE CHARGE for
Quasi-rash Cash Advances is 3% of each Quasi-rash amount, but never
less than S 10.The Cash Advance Fee/FINANCE CHARGE will increase
the Annual percentage Pace (APR' appealing on the monthly svtement
:n which the Cash Advance is posted to your Account.
Any Finance Charge shown an Your monthly statement is computed
only through Elie last day of the Billing Cycle. Since Finance Charges
continue to accrue until the dace your payment is received and posted co
'tour Account, additional Finance Charges may -appear on the following
month's sratement.The amount of the Finance Charge and the Cash
Advance Fee may be changed from time to time.
I S.Your Billing Rights. Keep This Notice for Future Use. This
notice contains important information about your rights and our
responsibilities under the Fair Credit BiilingAct.
Notify Us in Case of Errors or Questions About Your Bill- If you
think your bill is wrong, or d you need more information about a trans-
action an your bill, write us on a separate sheet at the address'provided
in the Billing Rights Summary portion on the back of your billing state-
ment Write cc us as soon as possible.We must hear from you no later
than 60 days after we send you the first bill on which the error or
problem appeared.You can telephone us, but doing so will not preserve
your rights.
In your fetter,give us the following information:
• Your name and Account number.
• The dollar amount of the suspected error.
• Describe the error and explain, if you can, why you believe there is
an error. If you need more information, describe the item you are not
sure about
If you have authorized us to pay your credit card bill automatically
from your savings or checking account you can stop the payment on
any amount you chink is wrong.To stop the payment, your letter must
reach us three (3) business days before the automatic payment is
scheduled to occur.
Your Rights and Our ResponsibilitiiesAfter NVe Receive Your
Written Notice. We must acknowledge your letter within 30 days
unless we have corrected the error by then. Within 90 days, we must
either correct the error or explain why we believe the bill is correct
After we receive your letter, we cannot try to coi{ect any amount you
question, or report you as delinquent.We can continue to bill you for
the amount you question, including Finance Charges, and we can apply
any unpaid amount against your credit Iine.You do not have to pay any
41
questioned amount while we are investigating, but you are still obligated
to pay the pare of your bill that are not in question.
if we find that we made a mistake on your bill. you will not have to pay
any Finance Charges refaced co any questioned amount. if we did not
make a mistake, you may have to pay Finance Charges and you will have
co make uo any missed payments on the questioned amount In either
case. we will send you a sotement of the amount you owe and Elie date
that it is due.
If you fail to pay the amount that we think you owe, we may report you
as delinquent However, if our explanation does not satisfy you and you
write to us within 10 days telling us that you still refuse to pay, we must
tell anyone we reoort you to diat you have a question about your bill.
And we must tell you the name of anyone we reported you to.We must
tall anyone we report you to that the matter has been settled between
us when it finally is.
If we do not follow these rules, we cannot collect the first $50.00 of
the questioned amount even if your bill was correct.
Special Rule for Credit Card Purchases. If you have a problem
wide the quality of property or services Ehat you purchased with a credit
card, and you have tried in good faith co correct the problem with the
merchant, you may have Elie right not to pay the remaining amount due
on the property or services.There are two limitations on this righcYou
must have made the purchase in your home state or, if not within your
home state, within 100 miles of your current mailing address: and the
purchase price must have been more than SSO.OaThese limitations do
not apply if we own or operate the merchant, or if we mailed you the
advertisement for the property or services.
16. Account Fees. Sublecc to applicable law, we may charge you, and you
agree to pay, the following fees. If your Minimum Payment is not received
by the Payment Due Date shown on your monthly statement, we may
impose and you agree to pay a lace fee as indicated on your card carrier.
'((u will not be assessed late charges more than once for any single
paymenL During any Billing Cycle in which your outstanding balance
exceeds your credit line, we may charge and you agree to pay an overiimit
fee as indicated on your card carrier. If any payment you send us on your
Account is returned unpaid, for any reason. we may charge and you agree
to pay a Returned Check fee as indicated on your card carrier.We may
also assess this fee if, for any reason, we return an unpaid Convenience
Check.Your annual membership fee, 8 applicable, is non-refundable and
will be billed to your Account and is indicated on your card carrier. We
may change the amount of these fees or add new fees from time to time.
17. Immediate Repayment of your Full Balance. You will be in
default, and we may, without notifying you in advance, close your Account,
cancel all Cards issued on it and demand immediate payment of your
entire balance if any of the following occurs:You fail to make a payment
when it is due; you do not follow the terms of the Agreement in any way;
you have made any false or misleading statement on the application for
your Account: you fail to pay any other loans you owe us; you become
insolvent or die: there is an attachment, execution or levy against you or
your property, you make an assignment for the benefit of creditors; a
bankruptcy petition is filed by or against you: a guardian, conservator,
WMP,eceiver, custodian or trustee is appointed for you; you are generaly not
Lin g your debts as they come due; or there has been an adverse chant
ur financial standing. If you are in default and fail to pay arty amounts
owe on your Account, you will be liable for our costs of collection
if we refer this claim to an aetorney for collection, you will be liable
ny reasonable attorneys fees we incur, plus the costs and expenses
y legal action.
6
18. Delay in Enforcement.'Ne can delay enforcing or fail to enforce
any of our rights under this Agreement without losing them.
19. Credit Reports. You authorize us, our subsidiaries and affiliates,
and Universai Card Services Corp. and its parent. to make or have made
any credit, employment and Investigative inquiries we deem appropriate
related to this extension of credit or the collection of amounts owed on
your Account. Information concerning your Account or credit history
,with us can be furnished by these pardes to consumer reporting agencies
and others who may properly receive that informaxion.A negative credit
report refiecting on your credit record may be submitted to a credit
reporting agency if you fail to fulfill the terms of this Agreement From
time to time. we may monitor telephone calls between you and Universal
Card Services Corp. and/or us to assure the quality of our customer
sernce.
20. Change in Terms ofYour Account. We can change any terms of
your Account at any time- We will provide you with notice as required by
law by mailing a notice to you at the latest address shown in our records
Any changes Mil apply to the current balance of your Account as weii as
cc iuture oaiances.You may choose to accept or deciine a change by
keeping your Account open or by closing your Account within fifteen
(15) days of the notire and repaying any outstanding balance according to
the old terms.Your decision to keep your Account open after any change
will constitute your agreement to the change.We may sell or otherwise
tarsfar your Account and any amounts owed by you to another -:reditoi
at any time. If we do. this Agreement will remain in effecL
21. Law Governing This Agreement. This Agreement and your
Account shall be governed by and interpreted in accordance with the laws
of the state of the issuer of the Account and the United States. regardless
of where you may reside or use your Account at any dme. This choice of
law is made co ensure uniform procedures and interpreooon for all of
our cardmembers, no matter where they reside or use their AccounEs.
22. Severability. In the event that any provision of this Agreement is
held or determined invalid or unenforceable, for any reason, the
remainder of the Agreement shall remain in full force and effect and
unaffected by such holding or determination.
23. Entire Agreement. This Agreement, including your card carrier and
any other written account materials, embodies the entire Agreement
and understanding between us and supersedes all Agreements. statement.,
and understandings relaxing to the AT&T Universal Card and the terms
of its use. unless otherwise expressly stated.
24. Cancellation. You may cancel your Account at any time by notifying
us in writing at the address on your monthly statement and returning to
us all Cards issued on your Account, cut in half, and destroying all unused
Convenience Checks. Even after your Account is closed, you remain
responsible for paying any amounts you owe.on the Account according
to the terms of this Agreement. If this is a joint Account, either of you
may request that the Account be closed and we will honor that request
without us having any liability to either of you.We can suspend your
Account privileges or cancel your Account at any time. with or without
ruse or notice. We may take such action if you do not use your Card to
make Purchases, Cash Advances or make Calling Card Calls at least one
time each year or if we determine that your Account is not maintained for
personal, family or household purposes.We may issue you a different Card
at any time.
25. Headings. The headings used in this Agreement are for the con•
venience of reference only and are not intended in any way co define or
describe the scope or intent of any provision of this Agreement.
26. Reevaluation of Credit. We may reinvestigate any information, you
provided on your credit application at any time. and in the course of
doing so, we may ask you for additional information, request credit
bureau reports andlor otherwise verify your current credit sanding.
1. In these terms and conditions. the term AT&T Calling Card refers to
the Calling Card function of your AT&T Universal Card. The words "you:'
"your" and "yours" mean each individual who applies for the AT&T
Univers all Card Account.
2-You agree to pay for all charges incurred with the AT&T Calling Card
andlor with respect to your Designated Telephone Number and to
comply with the other terms sec forth herein.
3.Your .AT&T Calling Card is not transferable.You may authorize others
to use the AT&T Calling Card. but the responsibility of payment for the
charges incurred will remain yours.
4. Charges for AT&T telecommunications services will be rated and
charged in United States dollars in accordance with AT&Ts effective
tariffs. AT&T tariff rates for AT&T Calling Card Calls include a service
charge. which will vary depending upon where and how you call.-he
service charge as of February f998 for a scare-to-state AT&T Calling Card
Call using 1 800 CALL ATT is 64 for a non-operator-assisted call and
52.25 for an operator-assisted calLThe service charge as of February
1998 for an in-state AT&T Calling Card Call using 1 800 CALL ATT
ranges from 200 to $ 1.05 for a non-operator-assisted all and from 50t
co $125 for an operator-assisted call.These service charges may vary if
you have an AT&T optional ailing plan or use other dialing medicos: For
example 0 or 10-ATT, to place an AT&T Calling Card Call. All rates are
subject to change without notice.
S.A separate charge will be assessed for calls originated from pay phones
to recover a pay phone usage fee imposed upon AT&T by the FdC. As of
December 1997, that charge is 30¢.
6. In the event the AT&T Caling Card may be used for AT&T Services nor
covered by tariff. AT&T will attempt to provide such non-tariffed services
as described in its marketing materials, but AT&T does not warrant such
services co be error-free or fit for any particular purpose. You may not
use the non-tariffed portion of the services for any unlawful purpose
and you are responsible for and will hold AT&T hartriless against the
consequences of any such unlawfui use of any slander, libel or other
actionable content in any message.The liability of AT&T, or any of its
employees, agents or cooperating service provider(s) arising from any
misdehvery, nondelivery or any other errors or omissions in the
provision of the non-ariffed portion of the services is limited to an
amount equal to the charge for any such service(s).
7.Your Account may be subject to a maximum monthly usage limit
8. If AT&T suspects fraudulent use of your AT&T Calling Card, AT&T
may, among other things. suspend or terminate your card without
further notice.
, 1998 UCS
t ? turx Past Consumer waste CP-LBRO798
J?
AT&T Universal Card Cardmember Agreement
This Agreement along with your card carrier and any other written
account materials contains the terms which governyour AT&T Universal
Card and Account Please read -hose documents and keep them with
your other important papers.
1. Definitions. In this Agreement, the word "Card" means a single Card
or two or more Cards we have issued co you under this AgreememThe
'lords "you:' "your. "'yours" and "cardmember" mean each individual who
applies for a Card.The words "we our" or "us" mean the issuer of the
AT&T Universal Card.The -word "Account" means the AT&T Universal
Card Account for which you were issued a Card imprinted with your
Account Number.The -words "Authorized User" mean arry person to
whom you give permission to use your Account The words "Transaction
Date" mean the date the goods or services were purchased or Elie dace
the Cash Advance was made. The words "Posting Date" mean the date
chat the charge was debited ardlor credited to your Accounc. The words
-Des?'gnated elephone Number' mean the telephone number to which
your Dial- Iservice is billed. -which may or may not he your home
telephone number.The words "Calling Transactions" mean the Calling
Card Calls you make with your Card and all other calls billed co your
Account to the extent you otherwise agree, if made from or billed to
your Designated Telephone Number.
2.Your Responsibility for the Account. You are responsible for all
amount-- owed on your Account- whether it is used by you or by an
Authorized User. and you agree to pay such amounts according to the
terms of this Agreement if chic +s a pant Account, each of you. together
and individually, is responsible for ail amounts owed, even if the Account is
used by only one of you. In order to cancel permission of an Authorized
User to use your AT&T Universal Card Account you must notify us in
writing and you must return to us. with your written notice, any Card in
the possession of die Authorized User.You will continue co be liable for
all Purchases and Cash Advances made by an Authorized User, and all
ocher resulting Account fee: and charges. until we receive your letter and
the Card. if we ask. you musE cut the Card in half and return it to us-You
must sign each Card as soon as you receive it
You will continue to be liable for the entire balance of your Account.
even if your co-applicant is ordered by a court to pay us. If a court orders
your co-applicant to pay all or a portion of your Account balance, you will
remain liable to us if your cc-applicant fails to pay as ordered by the
court, and your Account status will continue to be reported to the credit
bureau under your name.
From rime to time you may hear about new products and services
being offered to you and other cardmembers. If you would prefer noc to
receive this information either by telephone or magi or bot80? h,'ust let us
know by calling our toll-free Customer Service number: 1 423-4343.
3.AcceptingThisAgreerrtent. This Agreement will be effective when
you or an Authorized User uses Elie Card, or if you fag to cut your Card
in half and return it to us within 30 days after it is issued to you or when
you tail and activate the Card by the Card Activation Number process.
,? How to use your credirline.
4.Your Credit Line. You -may not use your Account in any way that
would cause you to go over your credit Iine.We may refuse to authorize
or accept any transaction on your Account which would cause you to
exceed your credit line. % s your obligation not to exceed the credit fine
for your Account 1f you owe more than your credit line. you agree to pay
the excess immediately upon our request and we may charge you an
overiunit fee, as described in Section 16 of this Agreement, andicr
ACCOUNT NUMBER oHLHnI.r H3 air -PAYMENT DUE DATE MINIM WTXYMEHT PAYMENT ENCLOSED
104 9t2007
5491130341872562 27,842.0 PAST DUE 27,812.03
Me Cracks FaWbIc To MUM
UNIFUND STATEMENT
PAULA A LEHMER
915 ALISON AVE
MECHANICSBURG PA 17055
MESSAGE FROM UNIFUND
YOUR ACCOUNT IS PAST DUE $27,842.03. THE PAST DUE AMOUNT IS INCLUL ED IN THE MINIMUM PAYMENT. PLEASE REMIT
IMMEDIATELY. IF YOU HAVE ALREADY SENT A PAYMENT FOR T'l E ABOVE! AMO U NT,THAN K YOU.
TRANSACTIONS:
Date Transaction Balance Due[Payments New Balance
10A 912007 This Account Was Issued Under The 27,E 42.03 27,842.03 0 27,842.03
Name Of CITIBANK SOUTH DAKOTA
NAand Acquired From Citibank (South
Dakota) NA.
PROMPT CREDITING OF PAYMENTS. TO RECEIVE CREDIT FOR PAYMENTS AS OF THE
DATE OF RECEIPT, WEMUST RECEIVE YOUR CHECK OR MONEY ORDER AT:
UNIFUND
10625 TECHWOODS CIRCLE
CINCINNATI, OH 45242
PAYMENTS RECEIVED AT THE ABOVE ADORES! IN THEMA14NER SPECIFIED AFTER THAT
TIME WILL BE CREDITED TO YOUR ACCOUNTAS OF OUF NEXT BUSINESS DAY. THE
CREDITING TO YOUR ACCOUNT OF PAYMENTS RECEIVED AT ANY LO.ATION OTHER THAN
THE ABOVE ADDRESS MAY BE DELA'(ED UP TO 5 DAYS OF RECEIPT.
THIS COMMUNICATION IS FROM A DEBT COLLECTOR. FEDERAL LAW REQUIRES US TO INFORM YOU THAT
THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT
PURPOSE.
AT&T Univertal-OlatinurPnarP Universal Card
Charter Member
Page 1 of 3
P LEHMER How To ReaCh US
Visit: www.universaicard.com
Account 6491 1303 41872682 Customer Service: 1-800-423-4343 or write
Calling Card + PIN Cardmember Services PO Box 44167
September 9.October 10, 2005 Jacksonville, FL 32231-4167
Quick Reference
Minimum Payment Due .................................... $16,362.31 Don't forget to use your AT&T Universal
Due Date* ................................ ............. November 4, 2005 Platinum Card which offers you up to 30
*Payment must be received by 1:00 pm local time an the payment due date. free calling minutes good toward U.S.
Amount Past Due .................. ...... $2.77768 $2777.68
... domestic and international calls, and 2 free
di
t
i
Amount Over Limit ................ .....
....................... $1;962.31 rec
ory ass
stance inquiries per month.
Credit Line ................................ .......................... $14,400.00
Available Credit ........................
Cash Advance Limit ................. .................................... $0.00
............................ $1,000.00 Help is availablel Please call the toll-free
Available Cash Advance Limit . ................................... $0.00 number shown above to learn about our
special payment options. Please give us
Account Summary the opportunity to assist you.
Previous 8alanca i x,940 a?
P?ymants.aorl ustmants D 00
MasterCar Activity 421-49
Total AT&T Services o m
New Balance $16,362.31
Note: Detailed activity starts on page 3.
date paid amount paid check #
Please follow payment Instructions outlined In the 'important Instructions for Making Payments" section of the statement.
Yaw Account Nmbmr
05491130341872562999999999995910 5491 1303 4187 2562
Please Cnbr Armenrt of Payment Lnelo ed
Paylwat Due Dab Your Total Wknee 7$1; Amawt Dw
NOV 04 2005 $16362.31 6362.31 I $
13295 MC 32 A I AR705I754
I111'iill/l?llll lll'II'II11/'II?1?1II'lll'1 /'llll'11I111/?I/II 'II11'II"IIIIt I11/'II III111"1'i/•11'II11I?11'11III
P LEHMER AT&T UNIVERSAL CARD
915 ALISON AVE PO BOX 183056
MECHANICSBURG PA 17055-3908 COLUMBUS, OH 43218-3056
lltlt6llI1111.1ullllfllllllflifelltllnlllttl,lll1.Ill. l,ll
P LEHMER
Account 6491 1303 4187 2582
September 9 - October 10, 2005
(a ANT Universal Card
Page 2 of 3
In the return envelope, please:
I Make your check payable to AT&T Universal Card.
2 Enclose your check or money order. Include your account
number and name on the front of your check or money order.
Please, no cash or foreign currency.
3 Enclose your payment coupon. Do not staple or tape it to your
payment. Insert the payment coupon so that the entire
AT&T Universal Card address appears through the window of
your remittance envelope.
P LEHMER
Account 6491 1303 4187 2582
September 9 - October 10, 2006
AM Uniyersal Card
Page 3 of 3
AT&T UNIVERSAL MASTERCARD ACTIVITY
Purchases ............................................................................................................................................................... 421.49
Cash Advances and Checks .................................................................................................................................... 0.00
Total MasterCard Activity ................................................................................................................................. $421.49
PURCHASES
Total MasterCard Purchases ................................................ $421.49
Standard Purch
Trans Post Description Amount
10/10 PURCHASES*FINANCE CHARGE*PERIOD 386.96
Total Standard Purch $386.96
Balance Transfer - Charged To Offer 9
Trans Post Description Amount
10/10 PURCHASES*FINANCE CHARGE*PERIOD 3A.53
Total Balance Transfer - Charged To Offer 9 $34.53
CASH ADVANCES
Cash Advance Limit ....................................... $1,000.00' 'This represents a portion of your total credit line.
FINANCE CHARGE INFORMATION
Days in Balance
Nominal Periodic x Billing x Subject to ¦
Standard Purch 30.740% .08422%(D) x 31 x $14,821.36
Offer 9 30.740% .06422%(D) x 31 x $1,322.49
CASH ADVANCES
Standard Adv 30.740% .08422%(D) x 31 x $0.00
Periodic Transaction
07NANCE + Foe/FINANC
= $386.96 + $0.00 30.740%
= $34.53 + $0.00 30.740%
= $0.00 + $0.00 30.740%
Total FINANCE CHARGE - $421.49
AT&T SERVICES SUMMARY
AT&T Universal Calling Card Calls ................................................................................................................... $0.00
AT&T Universal Platinum Card
Charter Member
WATT Universal Card
Page 1 of 3
P LEHMER
Account 6481 1303 4187 2562
Calling Card + PIN
September 9 - October 10, 2005
Quick Reference
(Minimum Payment Due .................................... 616,362.31
Due Dataw ............................................. November 4, 2005
"Payment must be roceived by 1:00 pm local time on the payment due dab.
Amount Past Due ............................................... 62,777.86
Amount Over Limit ............................................ $1,882.31
Credit Line .......................................................... $14,400.00
Available Credit ............................................................ 80.00
Cash Advance Limit ............................................. $1,000.00
Available Cash Advance Limit .................................... $0.00
Account Summary
Previous balance 16-940-82
Pay? ants and A?"?ustments 0 00
MasterCa'- rid Activky 4 149
Total AT&T Services o m
New Balance $16,362.31
Note: Detailed activity starts on page 3.
How To Reach Us
Visit: www.universaleard.oom
Customer Service: 1-800-423-4343 or write
Cardmember Services, PO Box 44167
Jacksonville, FL 32231-4167
Don't forget to use your AT&T Universal
Platinum Card which offers you up to 30
free calling minutes good toward U.S.
domestic and international calls, and 2 free
directory assistance inquiries per month.
Help is available! Please call the toll-free
number shown above to learn about our
special payment options. Please give us
the opportunity to assist you.
date paid amount paid check #
Please follow payment Instructions outlkwd In the "Important Instructions for Making Payments" section of the statement.
05491130341872562999999999995910 Your Accoiart Member
5491 1303 4187 2562
Please Enter Araalnt of Payment Lnelesad
Peynest Due bete - - -1 Your nce Arlwtwt Dire
NOV 04 2005 $16362.3111 $16362.31 1 Fs
13293 MC 32 A 1 AR7051754
P LEHNER
915 ALISON AVE
MECHANICSBURG PA 17055-3908
AL CARD
PO BOX11 183056
COLUMBUS, OH 43218-3056
IIt61tIIIIIILtLtIIIIItI1tIhIIItILIIttIIIttLIIlLellrltll
P LEHMER
Account 5491 1303 4187 2582
September 9 - October 10, 2005
ART Universal Card
Page 2 of 3
In the return envelope, please:
I Make your check payable to AT&T Universal Card.
2 Enclose your check or money order. Include your account
number and name on the front of your check or money order.
Please, no cash or foreign currency.
3 Enclose your payment coupon. Do not staple or tape It to your
payment. Insert the payment coupon so that the entire
AT&T Universal Gard address appears through the window of
your remittance envelope.
P LEHMER
Account 5491 1303 4187 2562
September 9 - October 10, 2005
AW Universal Card
Page 3 of 3
AT&T UNIVERSAL MASTERCARD ACTIVITY
Purchases ............................................................................................................................................................... 421.49
Cash Advances and Checks .................................................................................................................................... 0.00
Total MasterCard Activity ................................................................................................................................. $421.49
PURCHASES
Total MasterCard Purchases ................................................ $421.49
Standard Purch
10/10 PURCHAS S*FINAN_F CHARGE*PFRTon 31016,96
Total Standard Purch $386.96
Balance Transfer - Charged To Offer 9
Trans Post neecrintinn Amount
10110 PURCHASES*FTNANC NAR.F*PFRTn 34.53
Total Balance Transfer - Charged To Offer 9 $34.53
CASH ADVANCES
Cash Advance Limit ....................................... $1,000.00• 'This represents a portion of your total credit line.
FINANCE CHARGE INFORMATION
Days In Balance Periodic Transaction ANNEIA
Nominal Periodic x Billing x Subject to ¦ FINANCE + FeelEIMA t4E PERCENTAor
_ APR Rate Period Finance Charge CHAM &UAM A
PURCHASES
Standard Purch 30.740% .08422%(D) x 31 x $14,821.36 = $386.96 + $0.00 30.740%
Offer 9 30.740% .08422%(D) x 31 x $1,322.49 = $34.53 + $0.00 30.740%
CASH ADVANCES
Standard Adv 30.740% .08422%(D) x 31 x $0.00 = 50.00 + $0.00 30.740%
Total FINANCE CHARGE - $421.49
AT&T SERVICES SUMMARY
AT&T Universal Calling Card Calls ................................................................................................................... $0.00
VERIFICATION
I, Michael F. Ratchford, attorney for Plaintiff,UNIFUND CCR PARTNERS ASSIGNEE
OF PALISADES COLLECTION, LLC, am fully familiar with the facts set forth in the within
Complaint and am authorized to make this Verification on behalf of Plaintiff. I Verify that the
facts set forth in the within allegations are true and correct to the best of my knowledge, knowing
that any false statements are punishable by law pursuant to 18 C.S.A. 4904.
EDWIN A. ABRAHAMSEN
MICHAEL F. RATCHFORD
SCOTT J. BEST*
"ALSO MEMBER OF NJ BAR
January 15, 2008
Cumberland County Sheriffs
1 Court House Sq.
Carlisle, PA 17013
9R
THE LAW OFFICE OF
EDWIN A. ABRAHAMSEN & ASSOCIATES, P.C.
WWW.EAA-LAW.COM
Re: UNIFUND CCR PARTNERS ASSIGNEE OF PALISADES COLLECTION,
LLC vs. PAULA A LEHMER
Our file Nos.: U07-0662
Dear Sheriff:
In regard to the above-noted matter, enclosed please find the following:
1. A true and correct copy of the Complaint;
2. The completed form for service;
3. A check for service;
4. A self-addressed return envelope for the return of service.
Please serve the named defendant in accordance with the County Rules of Civil
Procedure. If you should have any questions or concerns, please do not hesitate to call me at
(570) 558-5510.
The defendants address is : PAULA A LEHMER 915 ALISON AVE
MECHANICSBURG PA 17055
Thank you for your attention to this matter.
P.C.
Enclosures
mfr/MR
1 729 PITTSTON AVE. • SCRANTON, RA I B505 • (P) 570.558.5S1 ? • (F) 570.558.551 1
? oO
? b
s
'"rl
0
SHERIFF'S RETURN - REGULAR
CASE NO: 2008-00413 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
UNIFUND CCR PARTNERS
VS
LEHMER PAULA A
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
LEHMER PAULA A
the
DEFENDANT , at 1950:00 HOURS, on the 18th day of January , 2008
at 915 ALISON AVENUE
MECHANICSBURG, PA 17055
PAULA LEHMER
by handing to
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 18.00
Service 10.56
Affidavit .00
Surcharge 10.00
00
8.55
Sworn and Subscibed to
before me this day
So Answers:
R. Thomas Kline
01/22/2008
EDWIN ABRAHAMSEN
By.
Deputy Sheriff
of A. D.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
UNIFUND CCR PARTNERS
ASSIGNEE : CIVIL DIVISION
OF PALISADES COLLECTION, LLC
Plaintiff :
vs. NO: 08-413 CIVIL TERM
PAULA A LEHMER
Defendant :
PRAECIPE FOR ENTRY OF DEFAULT JUDGMENT
TO THE CLERK OF JUDICIAL RECORDS:
Kindly enter judgment by default for failure to respond to Plaintiff's Complaint in the
amount of $$29,877.34, which includes reasonable attorneys' fees. Notice of the intent to file a
default judgment was served upon the Defendant on February28,2008. A copy of the Notice of
Intent to Take Default Judgment is attached hereto and marked Exhibit "A."
Edwin A. Abrahamsen &
Michael F. R
Attorney I.D.
Attorney for4
P.C.
JUDGMENT
cd, Esquire
o.: 86285
aintiff
AND NOW, this _ day of i , 20g&, Judgment is hereby entered in favor
of the Plaintiff and against the Defendant in the amount of $$29,877.34, which includes
reasonable attorneys' fees for failure to respond to Plaintiffs Complaint.
PROTHONOTARY
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
UNIFUND CCR PARTNERS
ASSIGNEE
OF PALISADES COLLECTION, LLC ,
vs.
PAULA A LEHMER
CIVIL DIVISION
Plaintiff :
NO: 08-413 CIVIL TERM
Defendant
CERIFICATE OF SERVICE
I, Michael F. Ratchford, Esquire, hereby certify that on the date indicated below, I served
a copy of the Praecipe for Entry of Default Judgment in the above captioned matter by mailing
the same via First Class United States mail, postage prepaid addressed as follows:
PAULA A LEHMER
915 ALISON AVE
MECHANICSBURG PA 17055
Edwin A. Abrahamsen & Associates, P.C.
Date: ?? &Ld
Z c el F. Ratchfor
Attorney I.D. No.: 8
120 Keyser Avenue
Scranton, PA 18504
(570) 558-5510
UNIFUND CCR PARTNERS ASSIGNEE
OF PALISADES COLLECTION, LLC
Plaintiff
vs.
In the Court of Common Pleas of
CUMBERLAND County, Pennsylvania
Civil Division
NO: 08-413 CIVIL TERM
PAULA A LEHMER
Defendant
AFFIDAVIT UNDER SOLDIERS AND SAILORS
RELIEF CIVIL RELIEF ACT OF 1940 AS
AMENDED
State of Pennsylvania
County of CUMBERLAND SS:
Michael F. Ratchford, Esquire being duly sworn according to law deposes and says that the
above named defendant(s): PAULA A LEHMER; is(are) not in the military service of the United
States of America as defined by the Soldiers' and Sailors' Civil Relief Act of 1940 as amended;
That the defendant(s): PAULA A LEHMER; is(are) older than eighteen years of age;
That the employment status of the defendant(s): PAULA A LEHMER; is(are) unknown.
Michael F. Ratchfon
Sub cribed befor met is day of A?n\_20 rvl
Je ni er Loeh- lotary Public s ? zo
V0V
r ,.
gP`
\-t .
V
v
EDWIN A. ABRANAMSEN
MICHAEL P. RATCHFORD
SCOTT a. BEST-
*ALSO MEMBER OF NJ 8AR
94
THE LAW OFFICE OF
EDWIN A. ABRANAMSEN & ASSOCIATES, P.C.
WWW-EAA-LAW.CDM
February 28, 2008
PAULA A LEHMER
915 ALISON AVE
MECHANICSBURG PA 17055
Re: UNIFUND CCR PARTNERS ASSIGNEE OF PALISADES COLLECTION,
LLC v. PAULA A LEHMER
CUMBERLAND County Civit Action No.: 08-413 CIVIL TERM
Dear PAULA A LEHMER :
Enclosed please find the Ten Day Notice of Intent to Take Default in regard to the above-
noted matter. Please act accordingly.
If you have any questions or wish to discuss your outstanding account, please contact me
at (570) 558-5510,
Edwin A. Abrahamsen & Associates.
Michael F. Ratchford, quire
Enclosure
This is a communication from a debt collector in an attempt to collect a debt. Any information
will be used for that purpose.
1 729 PITTSTON AVE. - SCRANTON, PA 16505 - (P) 570.558.551 0 - (F) 570.556.551 1
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
UNIFUND CCR PARTNERS
ASSIGNEE : CIVIL ACTION
OF PALISADES COLLECTION, LLC
Plaintiff
NO: 08-413 CIVIL TERM
VS.
PAULA A LEHMER
Defendant .
TEN DAY NOTICE OF INTENT TO TAKE DEFAULT JUDGMENT
To: PAULA A LEHMER
915 ALISON AVE
MECHANICSBURG PA 17055
Date of Notice: February 28, 2008
IMPORTANT NOTICE PURSUANT TO PA R C P 237 1(a)(2)
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER AN
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.
MIDPENN LEGAL SERVICES
401 EAST LOUTHER STREET
CARLISLE, PA 17013
717-243-9400
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
UNIFUND CCR PARTNERS
ASSIGNEE CIVIL ACTION
OF PALISADES COLLECTION, LLC ,
Plaintiff :
NO: 08-413 CIVIL TERM
vs.
PAULA A LEHMER
Defendant ;
CERIFICATE OF SERVICE
I, Michael F. Ratchford, Esquire, hereby certify that on February 28, 2008 I served a copy
of the Ten Day Notice of Intent to Take Default in the above captioned matter by mailing the
same via First Class United States mail, postage prepaid addressed as follows:
PAULA A LEHMER
915 ALISON AVE
MECHANICSBURG PA 17055
Edwin A. Abrahamsen & Associates, P.C.
BY/ %?
Michael F. Ratchford,
Attorney I.D. No.: Ael
1729 Pittston A
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0we
Scranton, PA 505
(570) 558-5510
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UNIFUND CCR PARTNERS ASSIGNEE
OF PALISADES COLLECTION, LLC
Plaintiff
vs.
PAULA A LEHMER
Defendant
In the Court of Common Pleas of
CUMBERLAND County, Pennsylvania
Civil Division
NO: 08-413 CIVIL TERM
NOTICE OF FILING JUDGMENT
Notice is herby given that a money judgment in the above-captioned matter has been entered
against you in the amount of $ _ ?q Rry7 ? dog
on y
By:
If you have any questions regarding this notice, please contact the filing party:
Edwin A. Abrahamsen & Associates
1729 Pittston Avenue
Scranton, PA 18505
Telephone: (570)-558-5510
(Notice is given in accordance with PA Supreme Court Rule of Civil Procedure No. 236)
Unifund CCR Partners
10625 Techwoods Circle In the Court of Com on Pleas of
Cincinnati, OH 45242 CUMBERLAND County, Pennsylvania
Plaintiff Civil Division
vs.
NO: 08-413 CIVIL TERM
PAULA A LEHMER Praecipe to Satisfy the Judgment
915 ALISON AVE
MECHANICSBURG PA 17055
Defendant
To the Prothonotary of CUMBERLAND County Pennsylvania:
Please enter the above Praecipe to Satisfy the Judgment.
Edwin A. At
Lawyer ID #
Esquire
i & Associates, P.C.
Sworn and subscribed before me on this, day of 20-A
Thank you,
ITI
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