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Home My WebLink About08-0603 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HARVEST CREDIT MANAGEMENT VII, I CIVIL DIVISION LLC,a limited liability companyl assignee of Household Bank / l Metris Bank l I Plaintiff ( No. 2008 - (0?3 Civ, Term V. I SHANNON DARON an individual I I Defendant I I I I ( COMPLAINT i I I Code No. I 1 Filed on Behalf of: I ( PLAINTIFF I I I ATTORNEY OF RECORD FOR THIS PARTY I I Louis B. Swartz I PA. ID # 00242 I I ISWARTZ, LOVEJOY & ASSOCIATES 116th FLOOR LAW AND FINANCE BUILDING (PITTSBURGH, PENNSYLVANIA 15219 I I 1(412) 288-0300 ;80207 NOTE: THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE ;80207 Plaintiff Defendant No. 2008 NOTICE TO DEFEND AND CLAIM RIGHTS IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HARVEST CREDIT MANAGEMENT VII, LLC,a limited liability company assignee of Household Bank / Metris Bank V. SHANNON DARON an individual 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 days (20) 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 judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any 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, 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. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 1-800-990-9108 717-249-3166 NOTDEFCU.PLE ;80207 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HARVEST CREDIT MANAGEMENT VII, I LLC,a limited liability companYl assignee of Household Bank Metris Bank i Plaintiff I V. SHANNON DARON 1 an individual Defendant No. 2008 -?63 Cuic:( COMPLAINT 1. Plaintiff(s) is HARVEST CREDIT MANAGEMENT VII, LLC, a Limited Liability Co., assignee of Household Bank/Metr. Plaintiff's address is c/o 1600 Law & Finance Building, Pittsburgh, PA 15219. 2. Defendant(s) is Shannon Daron, an individual. Defendant's address is 920 North Front Street, Apt 9, Wormleysburg, PA 17043. 3. Plaintiff, at Defendant's special instance and request, opened for the Defendant a credit account which Defendant thereafter used and there is a balance due and unpaid, despite demand, in the amount of $1,451.5211 plus interest from March 12, 200611. The account was assigned to Plaintiff for value. WHEREFORE, Plaintiff demands Judgment a inst Defendant(s) in the amount of $1,451.52 plus interest rom March 12, 2006 and costs. Loui Swartz Attorney for PLAINTIFF SWARTZ, LOVEJOY & ASSOCIATES 16th FLOOR LAW AND FINANCE BUILDING PITTSBURGH, PENNSYLVANIA 15219 (412) 288-0300 HARVEST CREDIT MGT VII LAST STATEMENT DETAILS FOR Household Bank/Metris Ba* ACCOUNT#: 5458001637933122 LGBS#: EH108420 SHANNON DARON 13D PFAUTZ RD DUNCANNON PA 17020 SSN: XXX-XX-4216 ACCOUNT SUMMARY INFORMATION FOR #01637933122 LAST STATEMENT: N/A INTEREST RATE: 17% BALANCE DUE: $1,451.52 LAST PAYMENT: March 12, 2006 AVAILABLE BALANCE: $0.00 OPEN DATE: December 19, 2004 TRANSACTION J AMOUNT TRANS. DATE POST DATE DETAIL CHARGE OFF J$1,451.52 PA22 Swartz Lovejoy & Associates LLP - #80207 EH 108420 CHARGE OFF %,\(? tb I`' EXHMITA BILL OF SALE MADISON STREET INVESTDUIVTS, LLC, ("Seller"), for value received and pursuant to the terms and conditions of the Forward Flow Purchase Agreement ("Agr+eemen0) datod May 8, 2006 between Seller and Harvest Credit managemern VII, LLC ("Put see), does hereby sell, assign and convey to Purchaser, its successors and assigns, all right, title and interest of Seller is and to those certain purchased Accounts listed on the Sale File attached, without recourse and without representation of, or warranty of, collectibility, or otherwise, except to the extent provided for within the Aunt. 1,514 accounts with a total face amount of $4,954,921.35 EXECUTED THIS 7th day of December 2006. MADISON STREET INVESTMENTS, LLC By; Kevin Emmerich, Operations BILL OF SALE TURLE CREEK ASSETS, LTD, by and through its general primer, FORWARD PROPERTIES INTERNATIONAL, INC. ("Seller"), for value received, does hereby sell, assign, and convey to MADISON STREET INVESTMENTS, LLC ("Purchaser"), its successors and assigns, all right, title and interest of Seller in and to those certain purchased Accounts listed in the Sale File, without recourse and without representation of, or warranty of, collectibility, or otherwise, except to the extent provided for within the Purchase and Sale Agreement. EXECUTED this 6th day of December, 2006 TURTLE C K ASSET'S, LTD. By and throe its general partner, FORWARD P OPE4TIES, INTERNATIONAL, INC. By BR.L OF SAIX IMC CARD SBBVXMS (No INC. (fth HOLMMOLD CARD SBRVX= ?NBC, ( for valna reoeivad and Pt= mt to the terms &M coadiom of the P404vabs ("Apowa n datad Novi 25.20M hetween Sdkt toad Iftwo1dd Bank (ss). NA, and Ti R= CRMM ASSUM II. LTD.. ft "WPM Of FORWARD T enmRNATXft&L 1N C., a ram parad ("R=*mww), aom ? s. wdpft and t d ? s*ghee. is mcv= =d .Qr d miRoe, aii right, titb aad ioteeest oaf s+el w is 10 wed VAwWvdMw (aa declined in the AVe®ent) Usoed m the allwJ ed .L?1Ri. ??idoaut mtavu« aad wltbout r?r,Naurauad of. or wwrmy at *0AOQb , Of Gft wise, ==P to the a peavided far within the Apm.L BXBCLnmj t6i & doy cxf DWMAW, 2006. '01 CARD iK" IIvC: Name: 71ft ;80207 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HARVEST CREDIT MANAGEMENT VII, LLC,a limited liability company assignee of Household Bank / Metris Bank SHANNON DARON an individual Plaintiff v. Defendant No. 2008 VERIFICATION The undersigned, ,;,? pe VI ?„? , avers that he/she is the Vice PrAsident of Plaintiff, is authorized to make this verification on behalf of Plaintiff, the statements of fact contained in the attached Complaint are true and correct to the best of his/her information, knowledge and belief, and are made subject to the penalties of 18 Pa. Cons. Stat. Ann. Section 4904 relating to unsworn falsification to authorities. VERIFCOM.PLE Date p. C cn Q 00 V v 8 CTI v r .? 7, Ci 7T SHERIFF'S RETURN - NOT FOUND CASE NO: 2008-00603 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND HARVEST CREDIT MANAGEMENT VII VS DARON SHANNON R. Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT DARON SHANNON but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT & NOTICE , the within named DEFENDANT , DARON SHANNON 920 NORTH FRONT ST APT 9 NOT FOUND , as to WORMLEYSBURG, PA 17043 PER POST OFFICE, DEFENDANT LIVES IN DUNCANNON - PERRY COUNTY. Sheriff's Costs: Docketing Service Not Found Surcharge 4- S o answ .;:?.- ?. - . / --'' 18.00 -'?? - 15.36 5.00 R. Tho -Kline 10.00 Sheriff of Cumberland County .00 48.36 LOUIS SWARTZ 02/08/2008 Sworn and Subscribed to before me this day of A. D. V ACED{:.JI 2010 FEB 22 r'?= 1: 45 cu, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HARVEST CREDIT MANAGEMENT VII, I CIVIL DIVISION LLC,a limited liability companyl assignee of Household Bank Metris Bank I Plaintiff 1 No. 2008-00603 V. SHANNON DARON an individual I Defendant 1 I I I I PRAECIPE TO DISCONTINUE CASE I WITHOUT PREJUDICE I I Code No. I I Filed on Behalf of: I 1 PLAINTIFF I I I I ATTORNEY OF RECORD FOR THIS PARTY I 1 Louis B. Swartz I I PA. ID # 00242 I I ISWARTZ, LOVEJOY & ASSOCIATES 116th FLOOR LAW AND FINANCE BUILDING (PITTSBURGH, PENNSYLVANIA 15219 I I 1(412) 288-0303 #80207 NOTE: THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE aeon',- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HARVEST CREDIT MANAGEMENT VII, I LLC,a limited liability company) assignee of Household Bank / I Metris Bank I Plaintiff I No. 2008-00603 V. SHANNON DARON an individual Defendant PRAECIPE TO DISCONTINUE CASE WITHOUT PREJUDICE TO: THE PROTHONOTARY Please discontinue the captioned casq iA hout prejudice. ATTORNEY FOR 114LAINTIFF VERIFICATION I verify that the above Praecipe was exec d by me for the purposes stated therein. This statement is made pect to the penalties of 18 Pa. Cons. Stat. Ann. section 4904 r ating to unsworn falsification to authorities. DiSCWOP.PLE