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HomeMy WebLinkAbout04-0450BURTON NEIL & ASSOCIATES, P.C. By: Burton Nell, Esquire Identification No. 11348 26 South Church Street West Chester, PA 19380 (610) 696-2120 Attorney for Plaintiff WORLDWIDE ASSET PURCHASiNG, LLC 2253 N. W. Parkway, Suite 500, Marietta, GA : iN THE COURT OF COMMON PLEAS Plaintiff 372 Burnthouse Road, Carlisle, PA 17013 Defendant : CUMBERLAND COUNTY, PENNSYLVANIA :NO. : CIVIL ACTION - LAW COMPLAINT 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 (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney m~d filing in writing with the court your defenses or objections to the claim 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. 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. LAWYER REFERENCE AND INFORMATION SERVICE Cumberland County Bar Assoc. 2 Liberty Avenue Carlisle, PA 17013 Telephone No. 717-249-3166 or 800-990-9108 55978 BURTON NEIL & ASSOCIATES, P.C. By: Burton Neil, Esquire Identification No. 11348 26 South Church Street West Chester, PA 19380 (610) 696-2120 Attorney for Plaintiff WORLDWIDE ASSET PURCHASING,LLC 2253 N.W. Parkway, Suite 500, Marietta, Georgia Plaintiff VIRGINIA M. LILLIE 372 Bumthouse Read, Carlisle, PA Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION - LAW Complaint 1. The plaintiffis WORLDWIDE ASSET PURCHASING ,LLC, a business corporation, with place of business located at 2253 N. W. Parkway, Suite 500, Marietta, Georgia. 2. The defendant is Virginia M. Lillie, who resides at 372 Burnthouse Road, Carlisle, Cumberland County, Pennsylvania. 3. At the defendant's request, Bank of Amer/ca issued the defendant a credit card bearing account number 4319041000084782 for defendant's use in making charge purchases subject to the terms and conditions governing the use of the credit card. Attached hereto, made a part hereof and marked Exhibit A is a true and correct copy of the terms and conditions. 4. The defendant accepted the credit card and the terms and conditions governing its use for the purchase of goods, merchandise and services and/or for cash advances from vendors who accepted Bank of America's credit card. In using the credit card, the defendant agreed to comply with the terms and conditions governing its use which included the obligation to pay Bank of America for all charges made in full upon receipt of the statement or in installments subject to monthly finance charges. 5. The defendant utilized the credit card by making/obtaining purchases of goods, merchandise and services and/or cash advances from vendors who accepted the credit card. Monthly statements were sent to the defendant which detailed the charges made to the account including finance charges, late and/or, over limit charges. The balance due for the charges made by the defendant including any finance charges, late or over limit charges is $7,213.72. 6. Defendant did not pay the balance due in full upon receipt of the billing statements and failed to make the required minimum monthly payment set forth in the billing statement. As such, defendant is in default of the terms and conditions governing the use of the credit card. 7. Plaintiffpurchased the defendant's account from Bank of America and is now the holder and owner of the account. 8. Although demand has been made by plaintiff upon defendant to pay the sum of $7,213.72, the defendant failed and refused to pay all or any part thereof. 9. Plaintiff alleges it is entitled to recovery of attorneys fees from defendant pursuant to the terms and conditions governing the account. Plaintiff seeks recovery of attorneys fees in the sum of $1,442.74. Wherefore, plaintiff demands judgment against the defendant in the sum of $7,213.72, attorneys fees in the sum of $1,442.74 and the costs of this action. BURTO & ASSOCIATES, P.C. By: Btt?t~,i~tq~, ~squire '~-~/~'ftorney for Rlaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. Verification (~e of authorized representative) .~.~Title or Position) for WORLDWIDE ASSET PURCHASING, LLC, the within Plaintiff, and makes this statement /ts behalf as to the truthfulness of the facts set forth in the foregoing Complaint subject to the penalties of 18 Pa. C.S. Section 4904, relating to unswom falsification to authorities. Virginia M. Lillie 4319041000084782 SHERIFF'S RETURN - CASE NO: 2004-00450 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WORLDWIDE ASSET PURCHASING LLC VS LEWIS VIRGINIA M REGULAR JODY SMITH Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon LILLIE VIRGINIA M the DEFENDANT , at 0905:00 HOURS, on the 13th day of February , 2004 at CUMBERLAND CO SHERIFF'S OFFICE ONE COURTHOUSE SQUARE CARLISLE, PA 17013 by handing to KEITH DAVIS, POA FOR VIRGINIA LILLIE a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18 Service Affidavit Surcharge 10 28 So AnswErs: 00 00 O0 00 R. Thomas Kline 00 00 02/17/2004 OLIN NEIL HALTRECHT Sworn and Subscribed to before me this ~ day of J~7/~~ ~2~oY A.D. / ~ro~[~onotary' By: Deputy Sheriff Acceptance of Service I accept the service o£ the ~__~t~/~q ~ (on behalf of ~Jl F~i gh~ Cc ~j[. certify that I am authorized to do so.) IX'cb. lB, ~o~ Date ~¢~,% T3~× 'Mailing Address and Authorized Agent WORLDWIDE ASSET PURCHASING, LL~ 9911 Covington Cross Drive, Suite 107 Las Vegas, NV 89144 Plaintiff VS. VIRGINIA M. LILLIE 372 Burnthouse Road Carlisle PA 17013 Defendant IN THE COURT OF COIVI/VION PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 04~450 Civil : CIVIL ACTION - LAW Praeeipe for Default Judgment To the Prothonotary: Please enter judgment by default for want of an answer in the above case in favor of the plaintiff and against the defendant, and assess damages as follows: Principal: $7,213.72 Attorneys Fees: $1,442.74 TOTAL $8,656.46 Understanding that false statements herein made are subject to penalty under 18 Pa. C.S. § 4904 relating to unswom falsification to authorities, I verify that: 1. The above are the precise last-known addresses of the judgment debtor and creditor. 2. The annexed notice of intention to file this praecipe was mailed to all parties against whom judgment is to be entered and to their record attorneys, if any, after the default occurred, and at least ten days prior to the date of the filing of this praecipe. 3. Pursuant to Section 201(b)(1)(A) of the Servicemembers Civil Relief Act of 2003 (SCRA), the defendant is not in the military service of the United States based on information received from the defendant and/or the Department of Defense website. JUDGMENT BY DEFAULT ENTERED AND DAMAGES ASSESSED AS ABOVE. NO~TICE GIVEN UNDl~R P,~A.R.CIV.P. 236 -C/ ~ Ne[1, Esqtfn:e iA~ .o ~l~Y3 ~rPhfmtie` 060 Andrew Drive, Suite 170 W. Chester, PA 19380 The law firm of Burton Neil & Associates is a debt collector. 55978 WOP-.LDWIDE ASSET PURCHASING. LLC Plainti~ VIROINIA M. LILLIE : ~; THE COURT OF COMMON pLEAs : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 04-450 Civil : CIVIL ACTION- LAW Notice of/ntention to FiJe Pmecipe for Default Judgment TO: Virginia M. Lillie 372 Bumflmuse Road C~lisle PA 17013 DATE OF NOTICE: March $, 2004 IMPORTANT NOTICE You are in defimlt because you have failed to eute~ a written ~ce pcrsonally or by sl~omey and file hi writillS with tho cour~ yom' ~s or obli~al~o~s to the claims set forfJl a~tinsl you. Unless you ac~ wigain t~n (10) days f~m the ~,.~ of~_hi~ notice, a judgment may be entered agn~ you without a hearing and you may lose your property or other imlxa*am~ rights. Yo~ should lake this notice to your lawyc~ at once. If you do nm have a lawye~ or cannot afford oue, go to or telephoac the following office to find out where you c~ get legal help. This office can provide you wi~ infortnafion about hiring a lawyer. Ifyou cannot afford to ~ a lawyer, this office may be able to provide you with information about agencies that may offer lcgal services to eligible persons at a reduced fee or no fee. LAWYt~ REFERENCE AND INFORMATION SERVICE Cumberlnd County Bu Assoc. 32 South Bedford Street Cnrlisle, PA 17013 Telephone No. 717-249-3166 or 800-990-~08 / 26 South Church W~st Chester, PA 19382 610-696-2120 The firm of Burton Neff & ~iams, P.C. is attempting to collect a debt. BURTON NEIL & ASSOCIATES, P.C. BY: Burton Neil, Esquire Identification No. 11348 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 ATTORNEY FOR: Plaintiff WORLDWIDE ASSET PURCHASING, LLC Plaintiff VS. VIRGINIA M. LILLIE Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-450 Civil : CIVIL ACTION - LAW RULE OF CIVIL PROCEDURE NO. 236 (REVISED) Notice is given that a JUDGMENT in the above captioned matter has been entered against you on Prothonotary /Deputy /t /] If you have any questions concerning the above, pier,contact: (J Burton Neil, Esquire Attorney for Party Filing 1060 Andrew Drive, Suite 170 West Chester, PA 19380 Phone: 610-696-2120 The law firm of Burton Neil & Associates is a debt collector.