HomeMy WebLinkAbout08-5168
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
WORLDWIDE ASSET PURCHASING II, LLC
101 Convention Cntr, 4850
Las Vegas, NV 89101
Plaintiff
V.
IN THE COURT OF COMMON
CUMBERLAND COUNTY,
ELIZABETH W KENYON .NO. 08 - .J`
6116 Wallingford Way, Mechanicsburg PA 17050
Defendant : CIVIL ACTION -LAW
Complaint - Notice
You have been sued in court. If you wish to defend against the claims set forth
pages, you must take action within (20) days after this complaint and notice ar
entering a written appearance personally or by attorney and filing in writing wi
defenses or objections to the claim set forth against you. You are warned that i
the case may proceed without you and a judgment may be entered against you
without further notice for any money claimed in the complaint or for any other
requested by the plaintiff. You may lose money or property or other rights imp
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE.
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEP]
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN G1
THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT
LAWYER.
YLVANIA
h ?C l
I u L ?.?
in the following
served, by
th the court your
you fail to do so,
)y the court
claim or relief
)rtant to you.
YOU DO NOT
!NE THE
LEGAL HELP.
[RING A
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MA BE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT M Y OFFER
LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE O NO FEE.
LAWYER REFERENCE AND INFORMATION SER
Cumberland County Bar Assoc.
32 South Bedford Street
Carlisle, PA 17013
Telephone No. 717-249-3166 or 800-990-9108
110660
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
WORLDWIDE ASSET PURCHASING II, LLC: IN THE COURT OF COMMON
101 Convention Cntr, #850
Las Vegas, NV 89101
Plaintiff : CUMBERLAND COUNTY,
v.
: NO.
ELIZABETH W KENYON
6116 Wallingford Way, Mechanicsburg PA 17050
Defendant : CIVIL ACTION - LAW
Complaint
1. The plaintiff is Worldwide Asset Purchasing II, LLC, with place
at 101 Convention Cntr, #850, Las Vegas, NV.
2. The defendant is Elizabeth W Kenyon, who resides at 6116 W
Mechanicsburg, Cumberland County, Pennsylvania.
3. A Bank of America credit card was issued to the defendant with
ending in 6602 hereinafter referred to as the credit card account.
4. Defendant accepted the credit card by making purchases, balance
cash advances.
5. Monthly statements were sent to defendant each month which
credits made to the credit card account for the prior month.
6. The balance due on the credit card account is $11,308.00.
VANIA
business located
Way,
number
and/or
il?d the charges and
7. Defendant did not pay the balance due on the credit card account in
of the monthly billing statements and also did not make the required minimum
set forth in the monthly billing statement. As such, defendant is in default on
upon receipt
payment
credit card
account.
8. Plaintiff purchased defendant's account and is now the holder and
account.
of the
9. Although demand was made by plaintiff upon defendant to pay the ?um of $11,308.00,
defendant failed and refused to pay all or any part thereof.
Wherefore, plaintiff demands judgment against defendant in the sum o? $11,308.00 and
the costs of this action.
P.C.
By:
Derek C. BYasker,
Attorney for Plain i
The law firm of Burton Neil & Associates, P.C. is a debt collector.
i
Verification
I, Chelvis Bell am an employee of Gera E. Moore &
Associates, P.C. by contract the service provider for plaintiff Worldwide Asset Purchasing
retained to perform services including but not primarily limited to collecting d linquent debt,
custodian of records and execution of documents. I am authorized to make thi verification as
attorney-in-fact for plaintiff under powers of attorney from plaintiff to Gerald. Moore &
Associates, P.C. and to me. The foregoing averments of fact in the within pleading are true and
correct to the best of my information and belief. I understand that the statements made herein are
subject to the penalties of 18 Pa. C.S. Section 4904, relating to unworn falsification to the
i
authorities.
Date: 07- 17-09
Signature
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SHERIFF'S RETURN - REGULAR
CASE NO: 2008-05168 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
WORLDWIDE ASSET PURCHASING II
VS
KENYON ELIZABETH W
WILLIAM CLINE
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE
was served upon
KENYON ELIZABETH W the
DEFENDANT , at 1047:00 HOURS, on the 6th day of September, 2008
at 6116 WALLINGFORD WAY
MECHANCISBURG, PA 17050
ELIZABETH W KENYON
by handing to
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 11.00
Affidavit .00
Surcharge 10.00
00
V/ 39.00
Sworn and Subscibed to
before me this day
So Answers:
R. Thomas Kline
09/08/2008
BURTON NEIL & ASSOCIATES
By:
Deputy Sheriff
of A. D.
-a
WORLDWIDE ASSET PURCHASING II, LLC:
101 Convention Cntr, #850
Las Vegas, NV 89101
Plaintiff
V.
ELIZABETH W KENYON
6116 Wallingford Way
Mechanicsburg PA 17050
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 08-5168 CIVIL TERM
CIVIL ACTION - LAW
Praecipe for Default Judgment
To the Prothonotary:
Please enter judgment by default for want of an answer in the above case in favor of the
plaintiff and against the defendant, and assess damages as follows:
Principal:
TOTAL
$11,308.00
$11,308.00
Understanding that false statements herein made are subject to penalty under 18 Pa. C.S. §
4904 relating to unworn falsification to authorities, I verify that:
1. The above are the precise last-known addresses of the judgment debtor and creditor.
2. The annexed notice of intention to file this praecipe was mailed to all parties against
whom judgment is to be entered and to their record attorneys, if any, after the default occurred, and
at least ten days prior to the date of the filing of this praecipe.
3. Pursuant to Section 201(b)(1)(A) of the Servicemembers Civil Relief Act of 2003
(SCRA), the defendant is not in the military service of the L
received from the defendant and/or the Department of Defense
JUDGMENT BY DEFAULT ENTERED
AND DAMAGES ASSESSED AS ABOVE.
NOTICE GIVEN DER PA.R.CIV.P. 236
Po Prothoff o
The law firm of Burton Neil & Associates is a debt collector.
States based on information
P.C.
Blasker, Esquire
for Plaintiff
I.D. NO. 202150
1060 Andrew Drive, Suite 170
West Chester, PA 19380
110660
•
WORLDWIDE ASSET PURCHASING 11,
LLC
Plaintiff
V.
ELIZABETH W KENYON
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 08-5168 CIVIL TERM
CIVIL ACTION - LAW
Notice of Intention to File Praecipe for Default Judgment
TO: Elizabeth W Kenyon
6116 Wallingford Way
Mechanicsburg PA 17050
IMPORTANT NOTICE
110660
You are in default because you have failed to enter a written appearance personally or by attorney and file in
writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10)
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 notice to your lawyer at once. If you do not have a lawyer
or cannot afford one, go to or telephone the following office 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
DATE OF NOTICE: October 2, 2008
In making this communication, we advise our office is a
debt collector.
By:
Derek . quire
Attorney for PI inti
Identification No. 2 150
1060 Andrew Drive, Suite 170
West Chester, PA 19380
(610) 696-2120
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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
WORLDWIDE ASSET PURCHASING 11, LLC : IN THE COURT OF COMMON PLEAS
Plaintiff
: CUMBERLAND COUNTY, PENNSYLVANIA
V.
NO. 08-5168 CIVIL TERM
ELIZABETH W KENYON
Defendant CIVIL ACTION -LAW
Rule of Civil Procedure NO. 236 (Revised)
Notice is given that a JUDGMENT in the above captioned matter has been entered
against you on ?'o
?.sy?o8
Prothon
By:
Deputy
If you have any questions concerning the above, please contact:
Derek C. Blasker, Esquire
Attorney for Party Filing
1060 Andrew Drive, Suite 170
West Chester, PA 19380
Phone: 610-696-2120
The law firm of Burton Neil & Associates is a debt collector.