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Home My WebLink About08-2737r NC027918 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 NCO PORTFOLIO MANAGEMENT PURCHASER FROM CITIBANK 1804 WASHINGTON BLVD BALTIMORE, MD 21230 COURT OF COMMON PLEAS CUMBERLAND COUNTY VS. FRANK FERRARO 801 WALNUT STREET-APT # A-1 LEMOYNE, PA 17043-1555 DOCKET NO. O$? d737 C jvi ( terpt 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 I 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 $2,492.64. 6. Plaintiff has made demand upon the defendant(s)for payment of the balance due of $2,492.64 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 May 3, 2004. WHEREFORE, plaintiff claims of the defendant(s) the sum of $2,492.64 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDERIC I. EINBERG, ESQUIRE JOEL M. F INK, ESQUIRE Attorney for Plaintiff P01A.DB I VERIFICATION FREDERIC I. WEINBERG, ESQUIRE, hereby states that he is the attorney for the Plaintiff (s) in this action and verifies that the statements made in the foregoing pleading are true and correct to the best of his knowledge, information and belief. The undersigned understands that the statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities. FREDERIC I. WE N RG, ESQUIRE 000 ?o C -D O D r=1?sa 0 w N CO r w I r-, A? ?y 00 SHERIFF'S RETURN - NOT FOUND CASE NO: 2008-02737 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND NCO PORTGOLIO MANAGEMENT VS FERRARO FRANK R. Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT FERRARO FRANK but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT & NOTICE the within named DEFENDANT , FERRARO FRANK 801 WALNUT STREET APT Al NOT FOUND , as to LEMOYNE, PA 17043 ON 3 ATTEMPTS, SOMEONE WAS HOME, TV ON. NO ONE WOULD ANSWER THE DOOR. Sheriff's Costs: Docketing Service Not Found Surcharge sovot ?.. So answerer -' 18.00 30.00 5.00 R. Th as Kline 10.00 Sheriff of Cumberland County Sworn and Subscribed to before me this day of A. D. GORDON & WEINBERG 05/16/2008 A NC027918 THIS IS AN ARBITRATION MATTER. ASSESSMENT OF DAMAGES HEARING REQUIRED. GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 NCO PORTFOLIO MANAGEMENT PURCHASER FROM CITIBANK 1804 WASHINGTON BLVD BALTIMORE, MD 21230 VS. COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : p$ - 9751 0"'v;t-Wrp'% FRANK FERRARO 801 WALNUT STREET-APT # A-1 LEMOYNE, PA 17043-1555 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 t& COPY FROM RECCRG A 'K in Tediaxr "wt rf, I tWe into se my has( Ind k" S" of said Court at Carlisle. Pa. wa N I 4 . 1 .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 $2,492.64. 6. Plaintiff has made demand upon the defendant(s)for payment of the balance due of $2,492.64 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 May 3, 2004. WHEREFORE, plaintiff claims of the defendant(s) the sum of $2,492.64 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: 7FREDERREDERIC PIN EINBERG, ESQUIRE OEL M. , ESQUIRE Attorney for Plaintiff P01A.DB t 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. WE N RG, ESQUIRE tt?,' w S i :b `d b Z M 0001 V6 3' ??IL3NS NC027918 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 NCO Portfolio Management COURT OF COMMON PLEAS PURCHASER FROM CITIBANK CUMBERLAND COUNTY vs. DOCKET NO. : 08-2737 CIVIL FRANK FERRARO 801 WALNUT STREET-APT # A-1 LEMOYNE PA 17043-1555 PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Kindly reinstate the Plaintiffs' Complaint in Civil Action in the above-captioned matter for an additional thirty (30) days. GORDON & WEINBERG, P.C. BY: FREDERIC I. EINBERG, ESQUIRE JOEL M. FLINK, ESQUIRE Attorney for Plaintiff(s) r ism it WN NC027918 THIS IS AN ARBITRATION MATTER. ASSESe?M EN' OF DAMAGES HEARING REQUIRED. GORDON & WEINBERG, P.C. ra:' ? r'7 - BY: FREDERIC I. WEINBERG, ESQUIRE - s _. Identification No.: 41360 N) 00 ) JOEL M. FLINK, ESQUIRE Identification No.. 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 -` 484/351-0500 NCO PORTFOLIO MANAGEMENT PURCHASER FROM CITIBANK 1804 WASHINGTON BLVD BALTIMORE, MD 21230 VS. FRANK FERRARO 801 WALNUT STREET-APT # A-1 LEMOYNE, PA 17043-1555 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : b8 - ,4jSj Lv; ( le'pt 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 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 $2,492.64. 6. Plaintiff has made demand upon the defendant(s)for payment of the balance due of $2,492.64 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 May 3, 2004. WHEREFORE, plaintiff claims of the defendant(s) the sum of $2,492.64 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY, FREDERIC I. I-INBERG, ESQUIRE JOEL M. F INK, ESQUIRE Attorney for Plaintiff P01A.DB Y VE 1FICAT199 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. WE N RG, ESQUIRE ? T 0 1 -- ? Lr) co Sheriffs Office of Cumberland County R Thomas Kline ? k, et Cumber Edward L Schorpp Sherimu? Solicitor Ronny R Anderson Jody S Smith Chief Deputy WICE OF THE SHERIFF Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 03/14/2009 09:10 AM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on March 14, 2009 at 0910 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Frank Ferraro, by making known unto himself personally, defendant at 801 Walnut Street, Apt. A-1 Lemoyne, Cumberland County, Pennsylvania its contents and at the same time handing tc him personally the said true and correct copy of the same. SHERIFF COST: $42.40 (PAID) March 19, 2009 2008-2737 NCO Portfolio Management VS Frank Ferraro SO ANSWERS, R THOMAS KLINE, SHERIFF By Deputy Sheriff iF.gy . ? 4 j ? .y ?? r y ?? ' L? ??r 1 ?? 4 ._- ? -4? ,I NC027918 r COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. 08-2737 CIVIL NONCE 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. /X/ Judgment' by Default $2,422.17 Money Judgment $ L-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 AR THONOTARY ?-- 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 NCO Portfolio Management PURCHASER FROM CITIBANK VS. FRANK FERRARO NCO27918 WE s 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 NCO Portfolio Management PURCHASER FROM CITIBANK COURT OF COMMON PLEAS CUMBERLAND COUNTY VS. FRANK FERRARO DOCKET NO. : 08-2737 CIVIL 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: $2,422.17 $2,422.17 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: NCO Portfolio ManagementPURCHASER FROM CITIBANK and that the last known address of defendant, FRANK FERRARO; 801:fWALNUT STREET-APT # A-1, LEMOYNE PA 17043-1555. 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 cr otherwise within the coverage of the Soldiers and Sailors Civil Relief Act and is (are) over 18 years of age. AND NOW, this 1 day of 2009 Judgment is entered in favor of the plaintiff(s) and gainst defendant(s) by default for want of an answer and damages as tessed at the sum of , $2,422.17 as per the above certification. Prothonotary GORDON & WEIN ERG, .C. BY: FREDERICWEINBERG, ESQUIRE JOEL M. ADINK, ESQUIRE Attorney for Plaintiff jr NC027918 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 FRANK FERRARO NCO Portfolio Management PURCHASER FROM CITIBANK TO/PARA Vs. COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 08-2737 CIVIL NOTICE OF INTENTION TO TAKE DEFAULT FRANK FERRARO 801 WALNUT STREET-APT # A-1 LEMOYNE PA 17043-1555 DATE OF NOTICE/FECHA DEL AVISO: April 7, 2009 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. INSERT MACRO FOR CORRECT COUNTY GORDON & WEINBERG, P.C. BY: FREDERI EINBERG, ESQUIRE JOEL M FLINK, ESQUIRE P10D-2 FILED-{ '["r 2099 MAY - 4 Fil 1: 47 - `t C`„ I ?r ! r ,?Ik .ob Cled '74ysz. M&LLf"Mat6c