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Home My WebLink About08-19262046341 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. PALMER G STRAWSER 1014 BELLE VISTA DR ENOLA PA 17025 DOCKET NO. : 08- Aa(o O ivt 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, 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 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 $11,561.16. 6. Plaintiff has made demand upon the defendant(s)for payment of the balance due of $11,561.16 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 8/5/04. WHEREFORE, plaintiff claims of the defendant(s) the sum of $11,561.16 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDERIC I WE BERG, ESQUIRE JOEL M. FL 1141(-, ESQUIRE 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. WEINBERG, ESQUIRE EXHIBIT "A" AFFIDAVIT OF INDEBTEDNESS ?6 q (? 31tl State of Ohio ) County of Hamilton ) ss. Kim Kenney, being sworn, deposes and says that she is an authorized representative of Un;fund CCR Partners, servicer, which is doing business at 10625 Techwoods is authorized to make the following statements and representationsr Cincinnati, Ohio 45242, and that knowledge, and that she is competent to testify we to the matters stated hich are within her personal she To the best of her knowledge the Defendant is not now in the Military herein, Service as defined Sailor's Civil ReliefAct of 1940 and amendments ther in the Soldier's There is due and payable from PALMER eto. amount of $11196.61 G STRAWSE.R, Account Number 5410654441058119, the This account was issued under the name of CITIB (South Dakota) was is Said account has been forwarded to OUTH D Gordon Unifund CCR Partners assignee of Palisades Collection LLC f DAKOTA NA and acquired from Citibank legal suit, with full power and authority to do and perform all acts & Weinberg P. C, , as attorn ey for Plaintiff compromise or satisfaction of said claim or the purpose of the commencement of a necessary for the collection, adjustment, I do solemnly declare and affirm under the permitted by law. y knowledge correct to the best of m penalties of perjury that the matters set forth above are true and I hereby certify that on 12/23/2007, before me, the State/County aforesaid, personally appeared the a6t form of law. 829 i ?;J EaENIFER A DUNCAN = NO T,'%Ry PUBLI / _ STATE OF OHI / Comm. Expire July 04, 2012 or DATED is 12/23/2007 UNIFUND C PARTNERS, By: Kim Kenney, Authorized Re resentative Title 10625 Techwoods Circle Cincinnati OH 45242 Address ublic for the made oath in due My commission Expires J S? 00 C_ 3 G) SHERIFF'S RETURN - REGULAR CASE NO: 2008-01926 P COMMONWEALTH OF PENNSYLVANIA: ' COUNTY OF CUMBERLAND UNIFUND CCR PARTNERS VS STRAWSER PALMER G STEPHEN BENDER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon STRAWSER PALMER G the DEFENDANT , at 1107:00 HOURS, on the 1st day of April , 2008 at 1014 BELLE VISTA DR ENOLA, PA 17025 by handing to 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 Service Affidavit Surcharge 18.00 15.00 .00 10.00 .00 43.00 Sworn and Subscibed to before me this of day So Answers: R. Thomas Kline 04/02/2008 GORDON & WEINBERG By: Deputy Sheriff A. D. 2046341 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. PALMER G STRAWSER COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 08-1926 CIVIL TERM PRAECIPE TO WITHDRAW COMPLAINT TO THE PROTHONOTARY: Kindly withdraw the above-captioned action, without prejudice. GORDON & WEINBERG, P.C. BY: FREDERIC I NBERG, ESQUIRE JOEL M. FLINK, ESQUIRE Attorney for Plaintiff P006 L --,. CERTIFICATION OF SERVICE I, FREDERIC I. WEINBERG, ESQUIRE, hereby certify that I, on the date below, served a copy of the foregoing, via First Class Mail, postage pre-paid, to all other parties or their counsel of record. FREDERIC I ESQUIRE Dated: 4/23/08 c-. ? ?°?; = c=. ?? ?:? ? -ca3 ?,?, ..? ? ?_ .-,-, i : u ,;,_: ?:, ' ?- r?.? - ' - , ; ,: ? ? , ?^ ? } - ?? ..` .. ?,