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Home My WebLink About08-14432042535 THIS IS AN ARBITRATION ASSESSMENT OF DAMAGES MATTER. HEARING REQUIRED. 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 ASSIGNEE OF PALISADES COLLECTIONS, LLC 10625 Techwoods Circle Cincinnati, OH 45242 COURT OF COMMON PLEAS CUMBERLAND COUNTY Vs. PAULA A LEHMER 915 ALISON AVE MECHANICSBURG PA 17055 DOCKET NO. : 08- 14q3 Civil ler'wt 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, 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 Palisades Collections, LLC, the successor in interest to the original creditor, CHASE MANHATTAN BANK USA. 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, 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 $14,467.74. 6. Plaintiff has made demand upon the defendant(s)for payment of the balance due of $14,467.74 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 3/15/05. WHEREFORE, plaintiff claims of the defendant(s) the sum of $14,467.74 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDERIC I. W INB G, ESQUIRE JOEL M. FLINK, SQUIRE 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. WEI E , ESQUIRE EXHIBIT "A" 0? pqa535 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 Civii Relief Act of 1940 and amendments thereto. There is due and payable from PAULA A LEHMER, Account Number 4226610654372677, the amount of $14192.42. This account was issued under the name of CHASE MANHATTAN BANK USA NA and acquired from Chase Sank USA NA Said accourif lias been"fo"""rw5rded't6-G6rd6ii &, Weinberg P.C:; as..attomey'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. 1 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. WMDATED this 09/24/2007 tFUND CCR PARTNERS By: Kim Kenney, Authorized Representative Title 10625 Techwoods Circle, Cincinnati, OH 45242 Address I hereby certify that on 09/24/2007, before me, the subscriber, a Notary Public for the State/County aforesaid, personally appeared the above-stated afant, and made oath in due form of law. 'JENNIFER A NCAN NOTARY PUBLIC ATE OF OHIO COMM. Expires 0 F July 04, 2012 r I I otary My commission Expires 829 -6? ? ? ? ? ? ? ? ? 0 o ? ? ? ? ? D D 0 SHERIFF'S RETURN - REGULAR CASE NO: 2008-01443 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND UNIFUND CCR PARTNERS VS LEHMER PAULA A TIMOTHY REITZ Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE LEHMER PAULA A was served upon the DEFENDANT , at 1825:00 HOURS, on the 14th day of March , 2008 at 915 ALISON AVENUE MECHANICSBURG, PA 17055 by handing to - T TT T T T TPT TART 1n 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 311o/ay 18.00 9.60 .00 10.00 .00 37.60 Sworn and Subscibed to before me this day of , So Answers: R. Thomas Kline 03/17/2008 GORDON & WEINBERG By: Depu y Sheriff A.D. _r' -1 2042535 GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 81894 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 UNIFUND CCR PARTNERS ASSIGNEE OF PALISADES COLLECTION, LLC VS. PAULA A LEHMER COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 08-1443 CIVIL TERM PRAECIPE FOR ENTRY OF JUDGMENT FOR WANT OF AN ANSWBR, ASSESSMENT OF DAMAGES, VERIFICATION OF ADDRESS AND NON-MILITARY SERVICE TO THE PROTHONOTARY: Enter judgment for want of an answer for plaintiff and against defendant(s) above named only and assess damages certified to be calculable as a sum certain from the complaint, as follows: Principal Total: $14,467.74 $14,467.74 Understanding the false statements made herein are subject to penalty under 18 Pa.C.S.A. §4904, Unsworn Falsification to Authorities, I verify that: 1. The last known addresses of the parties are: UNIFUND CCR PARTNERS ASSIGNEEOF PALISADES COLLECTION, LLC and that the last known address of defendant, PAULA A LEHMER, 915 ALISON AVE, MECHANICSBURG PA 17055. 2. The annexed notice(s) of intention to file this praecipe was (were) mailed to all parties, defendant and to their record attorneys, if any, after default occurred, and at least ten days prior to the date of filing of this praecipe. 3. The said defendant(s) is (are) not in the military service of the United States or otherwise within the coverage of the Soldiers and Sailors Civil Relief Act and is (are) over 18 years of age. AND NOW, this 741- day of M-aw , 2008 Judgment is entered in favor of the plaintiff(s) and gainst defendant(s) by default for want of an answer and damages assessed at the sum of , $14,467.74 as per the above rtificati Prot notary GORDON & WEINBERG, C. BY: FREDERIC I WE BERG, ESQUIRE JOEL M. FL , ESQUIRE Attorney for Plaintiff 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 2042535 UNIFUND CCR PARTNERS ASSIGNEE OF COURT OF COMMON PLEAS PALISADES COLLECTION, LLC CUMBERLAND COUNTY vs. DOCKET NO. : 08-1443 CIVIL TERM PAULA A LEHMER NOTICE OF INTENTION TO TAKE DEFAULT - TO/PARA PAULA A LEHMER 915 ALISON AVE MECHANICSBURG PA 17055 DATE OF NOTICE/FECHA DEL AVISO: April 4, 2008 C IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN 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 ----PR ??ul Ift%amilf?TES-THAT-MY OF %.7 -- - -- ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 GORDON & WEINBERG, P.C. BY: FRED IC WEINBERG, ESQUIRE JOE" M. FLINK, ESQUIRE P10D-2 n 7? F? 1?? O 0 ?... .L "tJ '?- `? ?- it v 2042535 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 ASSIGNEE OF PALISADES COLLECTION, LLC VS. PAULA A LEHMER COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 08-1443 CIVIL TERM NOTICE Pursuant to Pa.R.Civ.P. 236 of the Supreme Court of Pennsylvania, you are hereby notified that a judgment has been entered against you in the above proceeding as indicated below. /XL Judgment by Default $14,467.74 L? Money Judgment $ Judgment on Award of Arbitrators$ f? Judgment on Verdict$ IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL ATTORNEYS: FREDERIC I. WEINBERG OR JOEL M. FLINK, ESQUIRES AT THIS TELEPHONE NUMBER: 484/351-0500 ? 4 - - &74'14 -- P THONOTAR 2042535 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 ASSIGNEE OF PALISADES COLLECTION, LLC VS. PAULA A LEHMER COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 08-1443 CIVIL TERM ORDER TO SATISFY JUDGMENT TO THE PROTHONOTARY: Kindly mark the judgment entered May 7, 2008 in the above- captioned matter satisfied upon payment of your costs only. GORDON & WEINBERG, P.C. BY: FREDERIC I. NBERG, ESQUIRE JOEL M. FLINK, ESQUIRE Attorney for Plaintiff P005 C h ? i F-n o o r- -0 a 0 4Ln qu. r:: _ _