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Home My WebLink About08-6308 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Velocity Asset Management 3100 Route 138W CIVIL ACTION Wall, NJ 07719 Plaintiff VS. NO: 08 - 6306 C ly i t Term Gail M Yespy 431 LAMP POST IN Camp Hill PA 17011-1428 Defendant : NOTICE TO DEFEND 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 to Defend are served, by entering a written appearance personally or by an 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 judgment 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. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ON AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT REDUCED FEE OR NO FEE. MIDPENN LEGAL SERVICES 401 EAST LOUTHER STREET CARLISLE, PA 17013 717-243-9400 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Velocity Asset Management 3100 Route 138W Wall, NJ 07719 vs. Gail M Yespy 431 LAMP POST LN Camp Hill PA 17011-1428 Plaintiff Defendant CIVIL ACTION NO: O r- G 3 61' c m( --u^ COMPLAINT Plaintiff, Velocity Asset Management, by and through its attorneys, Edwin A. Abrahamsen & Associates, P.C., complains of the Defendant as follows: 1. Plaintiff, Velocity Asset Management, (hereinafter "Plaintiff") is a Delaware corporation with a principal place of business located at 3100 Route 138W, Wall, NJ 07719. 2. The Defendant Gail M Yespy (hereinafter "Defendant") is an adult individual residing at 431 LAMP POST LN Camp Hill PA 17011-1428. 3. At all relevant times herein, Plaintiff was engaged in the business of debt purchase and collection. 4. Defendant applied for and received a credit card issued by FIRST USA BANK with the account number 4388549000763730. 5. The within account was sold by FIRST USA BANK to Plaintiff for valuable consideration and all rights under said accounts were assigned to Plaintiff. (See, Bill of Sale, attached as Exhibit "A.") 6. Defendant used the FIRST USA BANK credit card account number4388549000763730, for purchases, cash advances and/or balance transfers. 7. The Defendant was mailed account statements relative to the Defendant's use of the subject credit card and the account was subject to the terms of the Cardmember Agreement. (See, Cardmember Agreement, attached as Exhibit "B.") 8. The Defendant defaulted under the terms of the Agreement by failing and refusing to make monthly payments on the account as they became due. 9. The account became delinquent on April 28, 2005 10. The principal amount was $7,072.96 at the time it was received by Plaintiff. 11. Pursuant to the account agreement, any unpaid balance accrues interest at the rate of 6. 12. The total amount due and owing the Plaintiff including interest, is $8,551.89. 13. Pursuant to the terms of the Agreement, Defendant is liable to Plaintiff for court costs and reasonable attorney's fees. WHEREFORE, Plaintiff requests judgment in its favor and against Defendant in the amount of $8,551.89 plus costs of suit, reasonable attorneys' fees and any other relief as the Court deems just and appropriate. submitted, Zdwin A. Abraham Assoc. Michael F. Ratchfor squire Heather K. Wo , Esquire Attorney I.D. .: 86285/207805 1729 Pittsto enue Scranton, PA" 18505 mratchford@eaa-law.com hwoodruff@eaa-law.com VERIFICATION I, Michael F. Ratchford, attorney for Plaintiff, Velocity Asset Management, am fully familiar with the facts set forth in the within Complaint and am authorized to make this Verification on behalf of Plaintiff. I Verify that the facts set forth in the within allegations are true and correct to the best of my knowledge, knowing that any false statements are punishable by law pursuant to 18 C.S.A. 4904. -J 00 ev 0 ,-T,'?z? c? SHERIFF'S RETURN - NOT FOUND CASE NO: 2008-06308 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND VELOCITY ASSET MANAGEMENT VS YESPY GAIL 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 YESPY GAIL M but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT & NOTICE , the within named DEFENDANT YESPY GAIL M 431 LAMP POST LN NOT FOUND , as to CAMP HILL, PA 17011-1428 PER CURRENT RESIDENT, DEFENDANT MOVED OUT 6 MONTHS AGO. NO FORWARDING ADDRESS ON FILE AT POST OFFICE. Sheriff's Costs: Docketing 18.00 Service 15.00 Not Found 5.00 Surcharge 10.00 .00 48.00 Sworn and Subscribed to before me this day of So answer-si - - R . Thomae Kline Sheriff of Cumberland County EDWIN ABRAHAMSEN & ASSOCIATES 11/07/2008 A. D. (David 1D. Buell 1tothonotary KirkS. Sohonage, ESQ Solicitor C i; 7750 Wnee X Simpson 1S` Deputy 1totFionotary Irene E. Morrow 2"d Deputy 1tothonotary office of the ftothonotary Cumberland County, Pennsylvania c/) O "(O .30 9 CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 25TH DAY OF OCTOBER, 2011, AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R.C.P 230.2 BY THE COURT, DAVID D. BUELL PROTHONOTARY One Courthouse Square • Suite 100 0 Carfisfe, DA 17013 • (717)240-6195 0 T'ax (717 240-6573