HomeMy WebLinkAbout08-19282046268
THIS IS AN ARBITRATION MATTER.
ASSESSMENT OF DAMAGES 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
Vs.
JAMES R GREGG
320 N COLLEGE ST
CARLISLE PA 17013
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
DOCKET NO. : t)8- l q ag C,'Vi I -Teri.
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, FIRST USA BANK 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
$2,324.71.
6. Plaintiff has made demand upon the defendant(s)for
payment of the balance due of $2,324.71 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 10/15/04.
WHEREFORE, plaintiff claims of the defendant(s) the sum of
$2,324.71 plus applicable costs, interest and attorney's fees.
GORDON & WEINBERG, P.C.
BY:
FREDERIC I. WEINBERG, ESQUIRE
JOEL M. FLINK, 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. WEINBE ESQUIRE
EXHIBIT "A"
829
BALANCE AS OF PAYMENT DUE DATE MINIMUM PAYMENT PAYMENT ENCLOSED
ACCOUNT NUMBER 12f2012007 _ ---? -'--
PAST DUE 2,298.96
4366163038608937 2,298.96 oK ramie ro ueiuea
i
UNIFUND STATEMENT
JAMES R GREGG
320 N COLLEGE ST
CARLISLE PA 17013
MESSAGE FROM UNIFUND
YOUR ACCOUNT " IF OU 9 HAVE ALREADY SENT AA PAYMENT FOR THE ABOVE AMOUNTTHANK YOU. PLE?E REMIT
IMMEDIATELY.
TRANSACTIONS:
pie ?? Transaction?..????„_Balance? Due ??Payments_?? New Balan
0 2,298.96
12=Q007 This Account Was Issued Under The 2,298.96 2,298.96
Name Of FIRST USA BANK NAand
Acquired From Titan Recovery Group
LLC.
PROMPT CREDITING OF PAYMENTS. TO RECEIVE CREDIT FOR PAYMENTS AS OF THE
DATE OF RECEIPT, WE MUST RECEIVE YOUR CHECK OR MONEY ORDER AT:
UNIFUND
10525 TECHWOODS CIRCLE
CINCINNATI, OH 45242
PAYMENTS RECEIVED AT THE ABOVE ADDRESS IN THE MANNER SPECIFIED AFTER THAT
TIME WILL BE CREDITED TO YOUR ACCOUNT AS OF OUR NEXT BUSINESS DAY. THE
CREDITING TO YOUR ACCOUNT OF PAYMENTS RECEIVED AT ANY LOCATION OTHER THAN
THE ABOVE ADDRESS MAY BE DELAYED UP TO 5 DAYS OF RECEIPT.
THIS COMMUNICATION IS FROM A DEBT COLLECTOR. FEDERAL LAW REQUIRES US TO INFORM YOU THAT
THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT
PURPOSE.
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SHERIFF'S RETURN - REGULAR
CASE NO: 2008-01928 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
UNIFUND CCR PARTNERS
VS
GREGG JAMES R
RONALD HOOVER , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
r D L'r_C 711MVQ T? the
DEFENDANT at 1812:00 HOURS, on the 4th day of April 2008
at 320 N COLLEGE ST
CARLISLE, PA 17013
by handing to
JAMES R GREGG
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
'00 /or
?
Sworn and Subscibed to
before me this
of
So Answers:
18.00
10.00 ,,.
00 10.00 R. homas Kline s
.00
38.00 04/07/2008
GORDON & WEINBERG
By:
day Deputy Sheriff
A. D.
A
2046268
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.
JAMES R GREGG
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
DOCKET NO. : 08-1928 CIVL TERM
PRAECIPE FOR ENTRY OF JUDGMENT FOR WANT OF AN ANSWER, 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:
$2,324.71
$2,324.71
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, JAMES R GREGG, 320 N COLLEGE ST, CARLISLE
PA 17013.
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
Y
years of age.
AND NOW, this - day of gJme , 2008 Judgment
is entered in favor of the plaintiff(s) and against defendant(s) by
default for want of an answer and damages assessed at the sum of ,
$2,324.71 as per the above ce tification.
Prot notary
GORDON & WEIN ERG, P.C.
BY:
FREDER C I. INBERG, ESQUIRE
JOEL M. FLIN , ESQUIRE
Attorney or Plaintiff
2046268
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.
JAMES R GREGG
TO/PARA
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
DOCKET NO. : 08-1928 CIVL TERM
NOTICE OF INTENTION TO TAKE DEFAULT
JAMES R GREGG
320 N COLLEGE ST
CARLISLE PA 17013
DATE OF NOTICE/FECHA DEL AVISO: May 1, 2008
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
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
GORDON & WEINBERG, P.C.
BY:
•`
FRED IC I. WEINBERG, ESQUIRE
JO M. FLINK, ESQUIRE
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2046268
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
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
VS.
JAMES R GREGG
DOCKET NO
NOTICE
08-1928 CIVL TERM
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.
1xL Judgment by Default $2,324.71
?l Money Judgment $
?L Judgment on Award of Arbitrators$
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
PRO ONOTARY
2046268
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.
JAMES R GREGG
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
DOCKET NO. : 08-1928 CIVL TERM
ORDER TO SATISFY JUDGMENT
TO THE PROTHONOTARY:
Kindly mark the judgment entered June 16, 2008 in the above-
captioned matter satisfied upon payment of your costs only.
GORDON & WEINBERG, P.C.
BY:
FREDERIC I. EI RG, ESQUIRE
JOEL M. FLIN SQUIRE
Attorney for Plaintiff
P005
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