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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 735 •V 1 n (- 8fr 4. l ' N N C-Z C-) N) co ,J C 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 T_ _= s 8 K M Cc . -a 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.