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Home My WebLink About08-2556Burton Neil & Associates, P.C. By: Derek C. Blasker, Esquire ID. NO. 202150 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 Attorney for Plaintiff MIDLAND FUNDING LLC 8875 Aero Drive Suite 200 San Diego CA 92123 Plaintiff V. BERNARD ROSS GIBSON JR 1306 Kingsley Rd, Camp Hill PA 17011 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 6g - 0165 (, Civil -Te r p+ 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 and 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. 32 South Bedford Street Carlisle, PA 17013 Telephone No. 717-249-3166 or 800-990-9108 101987 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 0 P _ -2 SS( : CIVIL ACTION - LAW Complaint 1. The plaintiff is Midland Funding LLC with place of business located at 8875 Aero Drive Suite 200, San Diego CA. 2. The defendant is Bernard Ross Gibson Jr, who resides at 1306 Kingsley Road, Camp Hill, Cumberland County, Pennsylvania. 3. A Household credit card was issued to the defendant with account number 5499440912521627 hereinafter referred to as the credit card account. 4. Defendant made purchases, balance transfers and/or cash advances on the credit card account. 5. The balance due on the credit card account is $10,971.00. 6. Defendant did not pay the balance due on the credit card account as required by the credit card agreement. As such, defendant is in default on the credit card account. 7. Plaintiff purchased defendant's account and is now the holder and owner of the account. Burton Neil & Associates, P.C. By: Derek C. Blasker, Esquire ID. NO. 202150 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 Attorney for Plaintiff MIDLAND FUNDING LLC 8875 Aero Drive Suite 200 San Diego CA 92123 Plaintiff V. BERNARD ROSS GIBSON JR 1306 Kingsley Rd, Camp Hill PA 17011 Defendant 8. Although demand has been made by plaintiff upon defendant to pay the sum of $10,971.00, defendant failed and refused to pay all or any part thereof. Wherefore, plaintiff demands judgment against the defendant in the sum of $10,971.00 and the costs of this action. Burt e' & A ciates, P.C. By: Derek C. Blasker, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. Verification I, Nicole VanDerSchaaf , am an employee of Midland Credit Management, Inc. which is by contract the servicer for plaintiff Midland Funding LLC retained to collect delinquent debt. I am authorized to make this verification pursuant to a servicing agreement from plaintiff to Midland Credit Management, Inc. The foregoing averments of fact in the within pleading are true and correct to the best of my knowledge, information and belief. I understand that the statements made herein are subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to the authorities. Date: ?A I OY AW Nicole VanDerSchaaf Bernard Ross Gibson Jr 5499440912521627 -l oho R? rv r- ? SHERIFF'S RETURN - REGULAR CASE NO: 2008-02556 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MIDLAND FUNDING LLC VS GIBSON BERNARD ROSS JR SGT BRYAN D WARD Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon GIBSON BERNARD ROSS JR the DEFENDANT , at 1453:00 HOURS, on the 28th day of April 2008 at CUMBERLAND CO SHERIFF'S OFFICE ONE COURTHOUSE SQUARE CARLISLE, PA 17013 by handing to BERNARD ROSS GIBSON JR 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 18.00 Service 15.00 Affidavit .00 Surcharge 10.00 .00 `??d??b3' ? 43 .00 Sworn and Subscibed to before me this day of , So Answers: R. Thomas Kline 04/28/2008 BURTON NEIL & ASSOCIATES By: ?'1 Deputy S Uri A.D. ?/ Burton Neil & Associates, P.C. By: Derek C. Blasker, Esquire ID. NO. 202150 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff Midland Funding LLC IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 08-2556 CIVIL TERM BERNARD ROSS GIBSON JR Defendant : CIVIL ACTION - LAW Praecipe to Discontinue To the Prothonotary: Kindly discontinue the above-captioned action without prejudice. Burton T Ml MUsociates, P.C. By: Derek-CrIlasker, Esquire Attorney fo Plaintiff The law firm of Burton Neil & Associates is a debt collector. 101987 ._1 2 - Crl