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Home My WebLink About08-3112NC027920 THIS IS AN ARBITRATION MATTER. ASSESSMENT OF DAMAGES HEARING REQUIRED. GORDON & WEINBERG, P.C. BY:,/F'REDERIC 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 as assignee of Citibank 1804 Washington Blvd. Baltimore MD 21230 VS. JANICE JONES, a/k/a JANICE NEIDIGH 3 KAIL AVE SHIPPENSBURG PA 17257-8229 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : Q$ - 31101 e't-vo Ierk 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 $10,815.79. 6. Plaintiff has made demand upon the defendant(s)for payment of the balance due of $10,815.79 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 June 1, 2004. WHEREFORE, plaintiff claims of the defendant(s) the sum of $10,815.79 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDERIC fl. W$INBERG, ESQUIRE JOEL M. F , ESQUIRE Attorney for Plaintiff P01A.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. EIN ERG, ESQUIRE C) ? 00 ? . m 00 v c, SHERIFF'S RETURN - REGULAR CASE NO: 2008-03112 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND NCO PORTFOLIO MANAGEMENT VS JONES JANICE ET AL RONALD E HOOVER Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon JONES JANICE AKA JANICE NEIDIGH the DEFENDANT , at 0017:25 HOURS, on the 22nd day of May 2008 at 3 KAIL AVENUE SHIPPENSBURG, PA 17257 JANICE JONES by handing to DEFENDANT 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: Docketing 18.00 Service 20.00 Affidavit .00 Surcharge 10.00 00 4 Sworn and Subscibed to before me this day So Answers: Ir R. Thomas Kline 05/23/2008 GORDON & WEINBERG By: Deputy Sheriff of A. D. NC027920 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 as assignee of Citibank VS. JANICE JONES COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 08-3112 Civil Term NOTICE 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. /Xj Judgment by Default $10,815.79 ?L Money Judgment $ 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 PROTHONOTARY (?, a 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 NC027920 NCO Portfolio Management as assignee of Citibank VS. COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 08-3112 Civil Term JANICE JONES 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: $10,815.79 $10,815.79 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 Managementas assignee of Citibank and that the last known address of defendant, JANICE JONES, 3 KAIL AVE, SHIPPENSBURG PA 17257-8229. 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 or otherwise within the coverage of the Soldiers and Sailors Civil Relief Act and is (are) over 18 years of age. AND NOW, this day of 2008 Judgment - q"j'_ is entered in favor of the plaintiff(s) and against defendant(s) by default for want of an answer and damages assessed at the sum of , $10,815.79 as per the above certification. 1-5- &A? R. Prothonotary 17 GORDON & WEINBERG, P.C. BY: FREDERIC I.`WEINBERG, ESQUIRE JOEL M. FLINK, ESQUIRE Attorney for Plaintiff 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 NC027920 NCO Portfolio Management as COURT OF COMMON PLEAS assignee of Citibank CUMBERLAND COUNTY JANICE JONES TO/PARA VS. DOCKET NO. : 08-3112 Civil Term NOTICE Or INTENTION TO TAKE DEFAULT JANICE JONES 3 KAIL AVE SHIPPENSBURG PA 17257-8229 DATE OF NOTICE/FECHA DEL AVISO: June 12, 2008 32eORTANT 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. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 BY: FR RIC I. WEINBERG, ESQUIRE JO L M. FLINK, ESQUIRE P10D-2 ? o ?' cx y Cl n 4 r --i w GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 CAVALRY PORTFOLIO SERVICES, LLC AS ASSIGNEE OF CAVALRY SPV I, AS ASSIGNEE OF NCO PORTFOLIO MANAGEMENT AS ASIGNEE OF ILI4U?a t ICE. j ¢ oNOTARI 027920 2flt! FEB 23 P? 1 ? :? 1 CUPENNS LV ANIA 7Y COURT OF COMMON PLEAS CUMBERLAND COUNTY CITIBANK VS. DOCKET NO.: 08-3112 Civil T JANICE JONES Praecipe for Voluntary Substitution of Cavalry Portfolio Services, LLC as Assignee of Cavaary SPV I, as Party Plaintiff Cavalry Portfolio Services, LLC as Assignee of Cavalry SPV I, LLC is the successor in interest to NCO Portfolio Management, which is the plaintiff herein, and desires to substitute itself for NCO Portfolio Management as plaintiff herein. 2. The material facts on which my right of succession and substitution is based are as follows: Cavalry Portfolio Services, LLC as Assignee of Cavalry SPV I, LLC purchased the judgment from and was assigned all rights by NCO Portfolio Management pursuant to the Bill of Sale and Assignment attached hereto as Exhibit "A". Cavalry Portfolio Services, LLC as Assignee of Cavalry SPV I, LLC does hereby voluntarily substitute itself as a plaintiff herein in the place and stead of NCO Portfolio Management. Cdvalry Portfolio Cavalry SPV I, L BY: Mohammad LLC as Assignee of ,'SCANNED BILL OF SALE Closing Date: December 15, 2010 NCO Portfolio Management, Inc ("Seller'), for valuable consideration, the receipt of which is hereby acknowledged, hereby sells, assigns and transfers all right, title and interest in the Accounts identified in the Sale File specified in Exhibit 1 of the Agreement (as defined below) entitled Cavalry_dj24to36.xlsx (which may be in electronic form) to Cavalry SPV I, LLC ("Buyer'), without recourse or representation except as expressly provided herein or on the terms, and subject to the conditions, set forth in the Agreement. This Bill of Sale is delivered pursuant to that certain Receivable Sale Agreement, dated as of December 15, 2010, by and between Seller and Buyer (the "Agreement"). All capitalized terms used, but not defined, in this Bill of Sale shall have the meanings assigned to such terms in the Agreement. NAPio gement, Inc. BN nski Title: President CERTIFICATE OF SERVICE I, FREDERIC I. WEINBERG, ESQUIRE, hereby certify that I, on the date below, served a copy of Plaintiff's Praecipe for Voluntary Substitution of as a party plaintiff, via First Class Mail, postage pre-paid, to all other parties or their counsel of record. FREDERIC . WE BERG, ESQUIRE Dated:/1