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Home My WebLink About08-3098 NCO28114 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., Dept. 500, Baltrimore, MD 21230 TODD M YOHN 310 S YORK ST MECHANICSBURG vs. PA 17055-6302 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO . d$ - 3og8 l.iiVi ~ TL°t'M 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 $7,980.47. 6. Plaintiff has made demand upon the defendant(s)for payment of the balance due of $7,980.47 but the defendant(s)has failed and refused and still refuses to pay the same or any part M ti thereof. 7. Defendant's last payment on account was made on 6/30/04. WHEREFORE, plaintiff claims of the defendant(s) the sum of $7,980.47 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDERIC I. EIN RG, ESQUIRE JOEL M. FLINK, SQUIRE Attorney for Plaintiff POlA.DB VERIFICATION FREDERIC I. WEINBERG, ESQUIRE, hereby states that he is the attorney for the Plaintiff(s) in this action and verifies that the statements made in the foregoing pleading are true and correct to the best of his knowledge, information and belief. The undersigned understands that the statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities. FREDERIC I. BERG, ESQUIRE .,~ ~? C:. ^' ~ `rt '~ a ~ ~ Y ,j M W ,y.: ~ J':..~ jyn ~,~ ~. ... ~'C3 ~ _ , , _/ ~ .r fy. ~ ~ ~ w "~ n SHERIFF'S RETURN - NOT FOUND CASE N0: 2008-03098 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND NCO PORTFOLIO MANAGEMENT VS YOHN TODD M R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT YOHN TODD M but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT & NOTICE the within named DEFENDANT YOHN TODD M NOT FOUND as to 310 S YORK STREET MECHANICSBURG, PA 17055-6302 DEFENDANT'S ADDRESS IS 2711 BOOSER AVENUE HARRISBURG, PA 17103-1930 Sheriff's Costs: Docketing 18.00 Service 10.00 Not found 5.00 Surcharge 10.00 s/~~/D~ n .00 `JS~• 4 3 . 0 0 So answers : ~..,--~- ~ ,yam:=- ~~ R. Thomas Kline Sheriff of Cumberland County GORDON & WEINBERG 05/19/2008 Sworn and Subscribed to before me this day of A.D. NC028114 THIS IS AN ARBITRATION MATTER. ASSESSMENT OF DAMAGES HEARING REQUIRED. GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 984/351-0500 ~~~ ~ FRO#~ ~ECQ~t~ ~~ '~e~s~norty wl~Ot, I h€~'e unto sit mil hams ~d r~ a ~a~ court ~~ Car~~sl+~k Pa+ ~N~~ of +~~.°.~-°0$ __ L 1" M ~ n+a NCO Portfolio Management PURCHASER FROM CITIBANK 1804 Washington Blvd., Dept. 500, Baltrimore, MD 21230 vs. TODD M YOHN 310 S YORK ST MECHANICSBURG PA 17055-6302 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET N0. ~$ _ 309$ ~tVil ~~'~ 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 { ~ ' 1 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 $7,980.47. 6. Plaintiff has made demand upon the defendant(s)for payment of the balance due of $7,980.47 but the defendant(s)has failed and refused and still refuses to pay the same or any part j thereof. 7. Defendant's last payment on account was made on 6/30/04. WHEREFORE, plaintiff claims of the defendant(s) the sum of 57,980.47 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDERIC I. EIN RG, ESQUIRE JOEL M. FLINK, SQUIRE Attorney for Plaintiff POlA.DB 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. BERG, ESQUIRE ~.~°~ tC./f L' . ~,, ~~~~ V a~~~,, -~~ :-'' . , ~==c ;~~~ ~ ~~ /~~w t,~~~' /rjjfJJ~ i 'y' ~'~ ,. ~ S; I d S i 1,tl1~ BUOl ~~Iti~~ ~,~~ . _: _ ~ _~_