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HomeMy WebLinkAbout08-28682039800 THIS IS AN ARBITRATION MATTER. 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 ASSESSMENT OF Atlantic Credit & Finance Inc. Assignee from Household Bank 3353 Orange Avenue Roanoke, VA 24012 VS. THOMAS J OKEEFE 220 BALTIMORE AVE APT CAP MT HOLLY SPRGS PA 17065 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 08 _ 018(08 CIV; ( ( rM 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 $18,864.16. 6. Plaintiff has made demand upon the defendant(s)for payment of the balance due of $18,864.16 but the defendant(s)has failed and refused and still refuses to pay the same or any part i e thereof. 7. Defendant's last payment on account was made on 7/30/07. WHEREFORE, plaintiff claims of the defendant(s) the sum of $18,864.16 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDERIC I. kJAERG, 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 Agm& e?A&f - Name 0 ATLANTIC CREDIT & FINANCE, INC. V. ?? THOMAS J OKEEFE o? 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 policies and practices, as well as the books and records of the Plaintiff with respect to the matters stated herein, andibased on information and belief states as follows: 1. Plaintiff sprincipai business consists of purchasing charged off receivables. 2. The Defendant defaulted on HOUSEHOLD BANK Account No. 5407070008923675. Said Account was charged off on November 30, 2006 and subsequently sold to Atlantic Credit & Finance, Inc with a balance of $18,864.16. 3. Plaintiff purchased or was otherwise assigned this charged off account along with other debts. As a result of the foregoing sale and assignment, the Plaintiff succeeded to all right, title and interest in 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 the account information provided to ascertain whether the statute of limitations was a bar to demand or institution of suit. Further, Plaintiff and/or its predecessor entered into a contract where the predecessor made representations and warranties that 1) it had clear right, title and interest in the 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. 5. According to Plaintiff s records, the last payment date was May 1, 2006. After application of all payments, credits, adjustments, and lawful offsets, if any, there is still a balance due and owing on this indebtedness of $18,864.16. The internal Account Statement of Plaintiff is attached hereto as Exhibit A and displays the account information that was provided to Plaintiff at the time of purchase and assignment. The foregoing is true and correct to the best of my knowledge and belief. By: GA fcGz?sr Heather Clary Assistant Director of Forwarding Subscribed'and sworn before me August 15, 2007. tiU ., per,, Jamie E son, Nota = t : FO?'b?°T94s : z My Commission Expires: 2/28/201 ° ' ??2Pp??FS Si?,y ' ?F ' • `0>> THIS COMMUNICATION IS FROM A DEBT COLLECTOI",OF GORDON & WEINBERG P.C.: JAFF- 2898618 Atlantic Credit & Finance, Inc. Mat Account Statement Report Date 07/30/2007 09:58:00 'CRE?r;Bi FINANCE U?CARP.QRATEp Our Account ID: 2898618 Account Number: 5407070008923675 Status: LGJ Received: 12/20/2006 Charge Off Date: 11/30/2006 i Purchase Balance: $ 18,864.16 Original Creditor Last Pay Date: 05/01/2006 Amount Paid: $ 0.00 Remaining Balance: $ 18,864.16 Name: OKEEFE, THOMAS J Other Name: Streetl: 220 BALTIMORE AVE APT C Streetl: APT C City, State Zip: MT HOLLY SPRGS, PA 17065 ?a?iment???Tn?o Date Type Matched Check: No SSN-Last 4 Digits: 0423 HomePhone: 7178390223 WorkPhone:7174401778 Invoiced Amount Comment No Payments Received raymenL 'iype •ru','VA','PC' - Payment Payment Type 'PUR','PAA','PCR' - Returned Payment NSF Confidential Property of Atlantic Credit E Finance Sac. i t Page No: I 9L) 4 U) 00 C, o0 0 ,o a D SHERIFF'S RETURN - NOT FOUND CASE NO: 2008-02868 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ATLANTIC CREDIT & FINANCE INC VS OKEEFE THOMAS J 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 OKEEFE THOMAS J but was unable to locate Him in his bailiwick. COMPLAINT & NOTICE , He therefore returns the NOT FOUND , as to the within named DEFENDANT OKEEFE THOMAS J 220 BALTIMORE AVE APT C MT HOLLY SPRINGS, PA 17065 PER POST OFFICE, DEFENDANT'S ADDRESS IS 28 FAIRVIEW AVE MT POCONO, PA 18344. Sheriff's Costs: Docketing 18.00 Service 6.00 Not Found 5.00 Surcharge 10.00 % - .00 ? 39.00 So answer R. Thomas Kline Sheriff of Cumberland County GORDON & WEINBERG 05/21/2008 Sworn and Subscribed to before me this day of A. D. 2039800 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. THOMAS J OKEEFE 220 BALTIMORE AVE APT CAP MT HOLLY SPRGS PA 17065 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 0%-a%pS Oivi l jPrn^ 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 04uL COPY FRO 'ECO"" sin TedWWW WW- . I t1?8 ut,0 9,t m, mno -in th4 SW 0, said C4v" at Cadisle, Pa. 00 r J - ntt?0 rv 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 $18,864.16. 6. Plaintiff has made demand upon the defendant(s)for payment of the balance due of $18,864.16 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 7/30/07. WHEREFORE, plaintiff claims of the defendant(s) the sum of $18,864.16 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDERIC I. *ZAERG, ESQUIRE JOEL M. FLINK, ESQUIRE Attorney for Plaintiff POIA.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 U ATLANTIC CREDIT & FINANCE, INC. e VV THOMAS J OKEEFE ),O,? 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 policies and practices, as well as the books and records of the Plaintiff with respect to the matters stated herein, and.lbased on information and belief states as follows: 1. Plaintiff sprincipal business consists of purchasing charged off receivables. 2. The Defendant defaulted on HOUSEHOLD BANK Account No. 5407070008923675. Said Account was charged off on November 30, 2006 and subsequently sold to Atlantic Credit & Finance, Inc with a balance of $18,864.16. 3. Plaintiff purchased or was otherwise assigned this charged off account along with other debts. As a result of the foregoing sale and assignment, the Plaintiff succeeded to all right, title and interest in 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 the account information provided to ascertain whether the statute of limitations was a bar to demand or institution of suit. Further, Plaintiff and/or its predecessor entered into a contract where the predecessor made representations and warranties that l) it had clear right, title and interest in the 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. 5. According to Plaintiff s records, the last payment date was May I, 2006. After application of all payments, credits, adjustments, and lawful offsets, if any, there is still a balance due and owing on this indebtedness of $18,864.16. 6. The internal Account Statement of Plaintiff is attached hereto as Exhibit A and displays the account information that was provided to Plaintiff at the time of purchase and assignment. The foregoing is true and correct to the best of my knowledge and belief. By: t:51 MA Heather Clary Assistant Director of For19 warding Subscribed'and sworn before me August 15, 2007. , Al, C yCo' ?0> : Jamie E son, Nota . o : Fxp9S946 Z , My Commission Expires: 2/28/201 ti A RFS 4 THIS COMMUNICATION IS FROM A DEBT COLLECTOkl,',,?/ OF W9"%,,%' GORDON & WEIN13ERG P.C.: JAFF- 2898618 1 Y {.? V.. 1 1 "'KrA •: Atlantic Credit a? & Finance, Inc. Report Date -: ?t1t1C R Account Statement 07/30/2007 09:58:00 PEW& FKANCE ?1CORPORATEp Our Account ID: 2898618 Account Number: 5407070008923675 Status: LGJ Received: 12/20/2006 Charge Off Date: 11/30/2006 Purchase Balance: $; 18,864.16 Original Creditor Last Pay Date: 05/01/2006 Amount Paid: $ 0.00 Remaining Balance: $ 18,864.16 Name: OKEEFE, THOMAS J SSN-Last 4 Digits: 0423 Other Name: HomePhone: 7178390223 Streetl: 220 BALTIMORE AVE APT C WorkPhone: 7174401778 Streetl; APT C City, State Zip: MT HOLLY SPRGS, PA 17065 L-L L,gj «'ae nyo1 Date Type No Payments Received A, Matched Check No Invoiced Amount Comment .,,- .,, , r., , rc - rayment Payment Type 'PUR','PAA','PCR' - Returned Payment NSF Page No: 1 Confidential Property of Atlantic Credit F Finance Inc. "lyJ?k I I _E d S- ,t v'W 8ou E 2039800 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. THOMAS J OKEEFE 220 N BALTIMORE AVE APT C MT HOLLY SPRGS PA 17065 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 08-2868 CIVIL TERM 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 INBERG, ESQUIRE JOEL M. FLINK, ESQUIRE Attorney for Plaintiff(s) 2039800 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 ?7 ?v 1001 E. Hector Street, Ste 220= Conshohocken, PA 19428 484/351-0500 CA Atlantic Credit & Finance Inc. COURT OF COMMON PLEAS `y = =' Assignee from Household Bank CUMBERLAND COUNTY 3353 Orange Avenue Roanoke, VA 24012 VS. DOCKET NO. pg - agog Cjvi ( T&'t ? ?I THOMAS J OKEEFE 220 BALTIMORE AVE APT CAP MT HOLLY SPRGS PA 17065 ? 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 s 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 . y 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 $18,864.16. 6. Plaintiff has made demand upon the defendant(s)for payment of the balance due of $18,864.16 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 7/30/07. WHEREFORE, plaintiff claims of the defendant(s) the sum of $18,864.16 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDERIC I. AEJAERG, ESQUIRE JOEL M. FLINK, ESQUIRE Attorney for Plaintiff POIA.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 famished 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 . 61?9eo NName EXIBITH "A" ATLANTIC CREDIT & FINANCE, INC. V. THOMAS J OKEEFE Jo? 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 policies and practices, as well as the books and records of the Plaintiff with respect to the matters stated herein, and!based on information and belief states as follows: 1. Plaintiffsiprincipat business consists of purchasing charged off receivables. 2. The Defendant defaulted on HOUSEHOLD BANK Account No. 5407070008923675. Said Account was charged off on November 30, 2006 and subsequently sold to Atlantic Credit & Finance, Inc with a balance of $18,864.16. 3. Plaintiff purchased or was otherwise assigned this charged off account along with other debts. As a result of the foregoing sale and assignment, the Plaintiff succeeded to all right, title and interest in 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 the account information provided to ascertain whether the statute of limitations was a bar to demand or institution of suit. Further, Plaintiff and/or its predecessor entered into a contract where the predecessor made representations and warranties that 1) it had clear right, title and interest in the 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. 5. According to Plaintiffs records, the last payment date was May 1, 2006. After application of all payments, credits, adjustments, and lawful offsets, if any, there is still a balance due and owing on this indebtedness of $18,964.16. 6. The internal Account Statement of Plaintiff is attached hereto as Exhibit A and displays the account information that was provided to Plaintiff at the time of purchase and assignment. The foregoing is true and correct to the best of my knowledge and belief. By: 6ya* a Heather Clary - c Assistant Director of Forwarding Subscribed'and sworn before me August 15, 2007 ??ME ?4?''• RFG oG?`.ggr N Jamie E son, Notafy-Rublit F Karks Z My Commission Expires: 2/28/201 A. °2 ` ?& F"' SON r ? THIS COMMUNICATION IS FROM A DEBT COLLECTOftOF \AWS GORDON & WEINBERG P.C.: JAFF- 2898618 WEM; PMJ,INCE 940WORAM-. Our Account ID: Atlantic Credit & Finance, Inc. Account Statement 2898618 Account Number: 5.407070008923675 Status: LGJ Report Date 07/30/2007 09;58;00 Received: 1 I 2/20/2006 Charge Off Date: 11/30/2006 Purchase Balance: $; 18,864.16 Original Creditor Last Pay Date: 05/01/2006 Amount Paid: $ 0.00 Remaining Balance: $ 18,864.16 Name: OKEEFE, THOMAS J Other Name: Streetl; 220 BALTIMORE AVE APT C Streetl; APT C SSN-Last 4 Digits. 0423 HomePhone: 7178390223 WorkPhone: 7174401778 City, State Zip: MT HOLLY SPRGS, PA 17065 I ,.w![?i?Te ii Date Type Matched Check No Invoiced Amount Comment No Payments Received I f i F I ! f , i rayment 'type 'PU','PA',-PC, - Payment - Payment Type 'PUR','pAR','pCR• - Returned Payment NSF Page No: 1 Confidential Property Of Atlantic Credit ! Finance Ina. o ?.: O r? r*? J ? cx7 W J - ? '7 s t.?? SHERIFF'S RETURN - NOT FOUND CASE NO: 2008-02868 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ATLANTIC CREDIT & FINANCE INC VS OKEEFE THOMAS J 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 OKEEFE THOMAS J but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT & NOTICE the within named DEFENDANT , OKEEFE THOMAS J NOT FOUND , as to 220 BALTIMORE AVE APT C MT HOLLY SPRINGS, PA 17065 PER CURRENT RESIDENT, OKEEFE MOVED. PER POST OFFICE, NEW ADDRESS IS 28 FAIRVIEW AVE, MT. POCONO, PA 18344-1645 Sheriff's Costs: Docketing 18.00 Service 6.30 Affidavit .00 Surcharge 10.00 Not Found 5.00 39.30 So answer R. Thomas Kline Sheriff of Cumberland County GORDON & WEINBERG 02/18/2009 Sworn and Subscribed to before me this day of A. D. J Fr. . CID + •I 2039800 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. THOMAS J OKEEFE COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 08-2868 CIVIL TERM PRAECIPE TO WITHDRAW COMPLAINT TO THE PROTHONOTARY: Kindly withdraw the above-captioned action, without prejudice. GORDON & WEINBERG, P.C. BY: FREDERIC I. INB G, ESQUIRE JOEL M. FLINK, SQUIRE Attorney for Plaintiff P006 , CERTIFICATION OF SERVICE I, FREDERIC I. WEINBERG, ESQUIRE, hereby certify that I, on the date below, served a copy of the Praecipe to Withdraw Complaint to Pa.R.C.P. 1028(c)(1), via First Class Mail, postage pre-paid, to all other parties or their counsel of record. FREDERIC I. WEIN ERG ESQUIRE Dated 1/?&' ?4?J= , ? ,? T c%? ? = ? , , ? '~ ? - >' c,` ?' =x ? ?. ? ?;?