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Home My WebLink About08-1442THIS IS AN ASSESSMENT GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 2043415 ARBITRATION MATTER. OF DAMAGES HEARING REQUIRED. UNIFUND CCR PARTNERS 10625 Techwoods Circle Cincinnati, OH 45242 Vs. EUGENE S KUHN PO BOX 1404 CARLISLE PA 17013 NOTICE COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 0$- 144A (2m l lerpi 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, 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 S. BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 COMPLAINT IN CIVIL-ACTION 1. Plaintiff, Unifund CCR Partners is a debt buyer and successor in interest to the original creditor, CITIBANK SOUTH DAKOTA NA. 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 merchandise 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, if available, 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 $19,003.49. 6. Plaintiff has made demand upon the defendant(s)for payment of the balance due of $19,003.49 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 8/29/05. WHEREFORE, plaintiff claims of the defendant(s) the sum of $19,003.49 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDERIC I. WE NBE G, ESQUIRE JOEL M. FLINK, QUIRE Attorney for Plaintiff P01h 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. WE NBER , ESQUIRE EXHIBIT "A" 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 EUGENE S KUHN, Account Number 5491130250541786, the amount of $17968.14. This account was issued under the name of CITIBANK SOUTH DAKOTA NA and acquired from Citibank (South Dakota) NA. Said account has been forwarded to Gordon & Weinberg P.C., as attorney for Plaintiff Unifund CCR Partners, 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. MV?WDAUTED this 10/15/2007 FUND CCR PARTNERS By: Kim Kenney Authorized Representative Title 10625 Techwoods Circle, Cincinnati OH 45242 Address I hereby certify that on 10/15/2007, before me, the subscriber, a Notary Public for the State/County aforesaid, personally appeared th stated afliant, and made oath in due form of law. •. 1 829 \`p R to L \ 0 .. ? \R\{//??%J ENNIFER A DUN ti, _ :--- -' NOTARY PUBL ?; a Z STATE OF OH Comm. Expires July 04, 2012 0 ?OF 11 My commission Expires 00 C-) 00 cm I- "% 2043415 GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 UNIFUND CCR PARTNERS COURT OF COMMON PLEAS CUMBERLAND COUNTY VS. EUGENE S KUHN DOCKET NO. : 08-1442 CIVIL TERM PRAECIPE TO WITHDRAW COMPLAINT TO THE PROTHONOTARY: Kindly withdraw the above-captioned action, without prejudice. GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINAEBR, ESQUIRE JOEL M. FLINK, ESQUIRE Attorney for Plaintiff P006 11- _% CERTIFICATION OF SERVICE I, FREDERIC I. WEINBERG, ESQUIRE, hereby certify that I, on the date below, served a copy of the Praecipe to Withdraw Pursuant to Pa.R.C.P. 1028(c)(1), via First Class Mail, postage pre-paid, to all other parties or their counsel of record. FREDERIC U?ENBERG, ESQUIRE Dated IN 3 c- oo fir: csl rTl dar cry