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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. cD 71 So -r- 0 N f?? J cr' 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 P10D-2 8 O r, d Ca ? -rt M al t J _A C.Ii 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 7 ? C-j