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Home My WebLink About08-20262044012 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 Atlantic Credit & Finance Inc. Assignee from Household Bank 3353 Orange Avenue Roanoke, VA 24012 VS. ASHLEY K DREHER 124 W PORTLAND ST APT 6 MECHANICSBURG PA 17055-6290 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : CR. 90aCivil -re-rat 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 4 COMPLAINT IN CIVIL-ACTION 1. Plaintiff is a debt buyer and successor in interest to the original creditor as set forth in the caption of this Complaint. 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 $2,531.29. 6. Plaintiff has made demand upon the defendant(s)for payment of the balance due of $2,531.29 but the defendant(s)has failed and refused and still refuses to pay the same or any part thereof. ., 4 7. Defendant's last payment on account was made on 8/30/06. WHEREFORE, plaintiff claims of the defendant(s) the sum of $2,531.29 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDERIC I. WE ERG, ESQUIRE JOEL M. FLINK, ESQUIRE Attorney for Plaintiff P01A.DB VERIFICATION I hereby state that I am the agent for the plaintiff herein, and that the facts set forth in the attached Affidavit which is incorporated by reference in the foregoing Complaint in Civil Action are true and correct to the best of my knowledge, information and belief and is based upon information which plaintiff has furnished to counsel. The language in the Complaint is that of counsel and not of plaintiff. To the extent that the contents of the Complaint are that of counsel, plaintiff has relied upon counsel in making this verification. This verification is made subject to 18 Pa.C.S. §4904 which provides for certain penalties for making false statements Name ATLANTIC CREDIT & FINANCE, INC. ?U\ V. ASHLEY K DREHER AFFIDAVIT OF DEBT AND VERIFIED BILL OF PARTICULARS The undersigned being first duly sworn according to law, deposes and says that she is familiar with the poli ies and practices, as well as the books and records of the Plaintiff with respect to the matters stated ein, and based on information and belief states as follows: 1. Plaintiff s principal business consists of purchasing charged off receivables. 2. he Defendant defaulted on HOUSEHOLD BANK Account No. "'Said ccount was charged off on March 31, 2007 and subsequently sold to At antic Credit & Finance, c with a balance of $2,531.29. laintiff purchased or was otherwise assigned this charged off account along with other debts. As result of the foregoing sale and assignment, the Plaintiff succeeded to all right, title and interest the charged off account, and it now owns the account. 4. Plaintiff conducted a due diligence investigation to determine, among other things, the accuracy of he account information provided to ascertain whether the statute of limitations was a bar to emand or institution of suit. Further, Plaintiff and/or its predecessor entered into a contract where he predecessor made representations and warranties that 1) it had clear right, title and interest in e account; 2) the account was free and clear of all liens and encumbrances; and 3) it had the power, authority, and full right to sell and convey its interest in the account. cording to Plaintiff's records, the last payment date was August 30, 2006. After application of payments, credits, adjustments, and lawful offsets, if any, there is still a balance due and owing this indebtedness of $2,531.29. 6. he internal Account Statement of Plaintiff is attached hereto as Exhibit A and displays the ccount information that was provided to Plaintiff at the time of purchase and assignment. foregoing is true and correct to the best of my knowledge and belief. By: 01AX -- Heather Clary °-- Assistant Director of Forwarding and sworn before me November 8, 2007. N4, ruEQ.1c Jami Jo on Public = P??. Y'^''yX51 My Commission Expires: 2/28/201 c ;;?;nn, _ THIS COMMUNICATION IS FROM A DEBT COLLECT r+r GORDONI& wEINBERG P.C.: JAFF- 3078265 ?? ? ` ?? '? •"-?' `rt f4J _ .? (T1 6• ? ._ ,-. _ ,,. --?: SHERIFF'S RETURN - REGULAR CASE NO: 2008-02026 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ATLANTIC CREDIT & FINANCE INC VS DREHER ASHLEY K DAVID MCKINNEY , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon L nn?uL'0 7\ CUT 7V W the DEFENDANT at 1249:00 HOURS, on the 2nd day of April 2008 at 124 W PORTLAND STREET APT 6 MECHANICSBURG, PA 17055 by handing to 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: So Answers: Docketing 18.00 Service 10 .00 Affidavit 00 Surcharge 10.00 R. Thomas Kline .00 38.00 04/03/2008 GORDON & WEINBERG Sworn and Subscibed to By: l before me this day Deputy Sheriff of A.D. ATLANTIC CREDIT & FINANCE, INC., Assignee from Household Bank, Plaintiff V. ASHLEY K. DREHER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 08-2026 Civil Action PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter the appearance of Evan C. Pappas, Esquire, and the law firm of Shumaker Williams, P.C., as counsel for Defendant Ashley K. Dreher in the above-captioned matter. Dated: qLL(6(CF6 AKE S, P.C. B _ Evan C. Pappas, I.D. #200103 P.O. Box 88 Harrisburg, PA 17108 (717) 763-1121 Attorneys for Defendant 210100 A CERTIFICATE OF SERVICE I, Evan C. Pappas, Esquire, of the law firm of Shumaker Williams, P.C., hereby certify that I served a true and correct copy of the foregoing Praecipe for Entry of Appearance by depositing a copy of the same in the possession of the United States mail, first-class, postage prepaid, addressed as follows: Frederic I. Weinberg, Esquire GORDON & WEINBERG, P.C. 1001 E. Hector Street, Suite 220 Conshohocken, PA 19428 Dated: q(6/? By EvanC.pp P.O. Box 88 Harrisburg, PA 17108 (717) 763-1121 . SHUMAKER WILL S, P.C Pa as s :? ?'_? ?' '? t:?? ? ' ^, ? t? _. ; T-. Q S w `C .. ; ? {'r ? •?.. 1 2044012 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 Atlantic Credit & Finance Inc. Assignee from Household Bank VS. ASHLEY K DREHER COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 08-2026 CIVIL TERM ORDER TO SETTLE, DISCONTINOE AND END TO THE PROTHONOTARY: Kindly mark the above-captioned matter settled, discontinued and ended upon payment of your costs only. GORDON & WEINBERG, P.C. BY: FREDERIC I. E ERG, ESQUIRE JOEL M. FLINK, ESQUIRE Attorney for Plaintiff P003 ;, .. `ra `C Y in f FY :J