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Home My WebLink About08-6941 HAYT, HAYT & LANDAU, LLC By: Arthur Lashin, Esquire Identification No. 23425 400 Market Street Suite 600 Philadelphia, PA 19106-2513 (215) 928-1400 Attorney for Plaintiff CUMBERLAND COUNTY (ASSET ACCEPTANCE LLC P.O. BOX 2041 WARREN, MI 48090 VS. THOMAS E BARD 18 BARD RD SHIPPENSBURG PA 17257 CIVIL ACTION "NOTICE 'You two been sued in cart N you wish lo defend against the oleirs sat foM in the folswig papas, you 'Ulm action vAd*% km*y 9Mdays atMr this complaid and notios are served, by anlwirrp a wMan appaararroe pwwrm ly a by an=W and Tipp 1n wd ft with #w cart your datansas or objeabonrs ioIn A . eat fatly apeirrst you. You an wand that N you fa1 /o do so the assn may proceed vAftt t you and a j m*m t may be on- 9you by the court wtlhort Rrtlw notion for cry mon- ey dairnad to the compleb or lor any odw deim or reW requed- od by the ph*M. You mar lose money or propeft or adw rWft inpordnt to you. IF YOU CANNOT AFFORD TO HIRE A LAWYELTH6S OFD MAY BE ABLE TO PROVIDE YOU WITH RVORMA11ON ABOUT AGENCIES THAT MAY OFFER LEGAL SERVRMS TO >L1003 F PERSONS AT A REDUCED FEE ORNO FEE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE PA, 17013 717-249-3166 COURT OF COMMON PLEAS CIVIL DIVISION No. 6$ - (oqq I TERM. eivi(Term "AVISO 'Le han dsmsndodo a uded on Is corb. S1 udsd quwne deAndersa cis edas danrandes azpueaias an In pdpinas stpndsrdes. uaMd lisps Mamie aq dim. do plaza al patir de Y fedra de M darner . y 1m notllir c" . Haos tabs assnir ups conrpannota esaft o on pareorra o con tin abopado y arynWin a Is Dais an ft.. asorita aus defence o wn ab}donas ems danrrarrdas on r, m kb de ou parsons. Sae sviaado qua at used no se daI Im. m 00" iennari rnsdidas y puede candbum r demand. sn contra sure sin provb avian o nroilicaoi l Adernia„ r aorta pus 1 daA& a favor dal derrranrdsria y N*6mrs qua udad a-Wb con todes In prwAsiones de ado dwende. Uded grade pander dirsro o aus propiededes u otrcs derechm irrponl-d- pare usI . 'LLEVE EsTA DEMANDA A UN ABOGADO 1W10ATAi1ENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUMENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEi+ONO A LA ORCINA CUYA DIRECC16N SE ENCUENTRA ESCRITA ABANO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL CIVIL ACTION 1. Plaintiff ASSET ACCEPTANCE LLC is a business entity securing or collection debts, with offices located at: P.O. BOX 2041, WARREN, MI 48090. 2. Defendant(s) THOMAS E BARD is/are individual(s) residing at: 18 BARD RD, SHIPPENSBURG, PA 17257. 3. Upon application by Defendant(s) a Credit/Revolving Charge Account was established for Defendant(s), which was assigned account number 71330300121335; a copy of the account Agreement is attached hereto, made a part of hereof, and marked Plaintiff's Exhibit "A". 4. Defendant(s) subsequently utilized the aforesaid account to make various purchases and/or receieve cash advances, thereby incurring payment obligations to Plaintiff and/or Plaintiff's predecessor in interest under the terms of The Agreement. 5. Defendant(s) defaulted upon The Agreement by failing to adhere to the repayment terms contained therein, and in accordance therewith, the entire remaining balance became due and immediately payable. 6. Plaintiff's predecessor in interest assigned to the Plaintiff all of its right, title and interest in and to its account with Defendant(s) so that Plaintiff is now the owner of said account. 7. As a consequence of the foregoing there is presently due and owing to Plaintiff by Defendant(s) the following amounts: Unpaid Balance: Interest: TOTAL DUE: $8,194.51 $909.29 $9,103-.n 8. Despite repeated demand by Plaintiff, Defendant(s) has/have failed and refused to pay the aforesaid sum. WHEREFORE, Plaintiff demands that judgment Defendant(s) in favor of Plaintiff in the together with interest and costs. HAYT By: be entered against amount of $9,103.80 Attorney for Plaintiff s folell "Ka O • O r d O r O r O 03 C r •• ti r 0 r r r W W O W O W r r 0 °O O 0 0 f o? o ?, c cw,N _ ro pwA-• {A-d S7N \ ?1 0SAO 00b- Aoax 05ba0 Y' r T\O ? -3 m A?a<? Lan N0 xo o OW ?cr fu00 a 00 mac ? '0 ?cc d NO [0520002781 07/01/2005 _ 826792942 a ; 1 r L ?? ? ? 1 V j r O0 t' is a }? O D . : y c r W a i O 1MM° + ? W Q s ??? O f • 4 0 ?Y z m y Y ? a s yr g g? t a o 0 -i to u+ N W ru O O O O O O O O o r w T ru o R? -- .s unobo oOR ,i i . w Yr r• w r ru a _0621 6+461 ®2736 o « e- Oe26 a 62 01521+4 0 ! . 00 65 ?u :` ' 0 I '? t v°- i A o ru s ! 1 a 6665 PK-O! C" - "t^ u a. D .a o 710-0030-1 ?. ~•. '?, \ O D -'N7= 1560 TRC=1409 PI:-O•? - ???• " i D w b- f 0 O O J?i1 ?•? D D O Wo mt tllMMminft bsbu ft AssA gw18tI "KS )U7O3HFr"-- 000010171330300171'335 HFC D0 BOX 60174 Statement of Your Account OF INDUS CA 91714 uayment Account Number New Balance Closing Date Payment Due Minimum Amount Coupon Date Due 713303-00-121335-u 9.808.23 08-10-2007 09-01-2007 2.757.50 AUTO PRESORTED FIRST-CLASS Mail Payment Tot 0081000366( THOMAS E BARD 18 BARD RD HFC SHIPPENSBURG PA 17257-8143 POST OFFICE BOX 4153-K CAROL STREAK IL 60197-4153 0 1002757507133030012133500009808235 For Assistance: ACCOUNT SUMMARY 800-333-4758 Account Number Closing Date Payment Due Standard Payment Amount Past Minimum Amoun Dae Due 713303-00-121335-0 08-10-2007 09-01-2007 212.82 2.544.68 2.757.50 Account Detail Since Last Statement Interest and Amount Applied Date Transaction Description Amount Other Charges To Balance New Balance OT-10-2007 Starting Balance 9.808.23 To evaluate and maintain the quality of our service to you. you permit us to listen to and/or retard telephone calls between you and our representative. To reach a Customer Service Specialist. please call toll free 1-877-812-6523. YOUR ACCOUNT IS NOW SERIOUSLY OVERDUE. WE EXPECT YOU TO PAY THE AMOUNT PAST DUE IMMEDIATELY. WE MAY REPORT INFORMATION ABOUT YOUR ACCOUNT TO CREDIT BUREAUS. LATE PAYMENTS. MISSED PAYMENTS. OR OTHER DEFAULTS ON YOUR ACCOUNT MAY BE REFLECTED IN YOUR CREDIT REPORT. TO ENSURE PROPER AND PROMPT CREDIT IS APPLIED TO YOUR HFC ACCOUNT. ALWAYS RETURN THE TOP PORTION OF YOUR BILLING STATEMENT WITH YOUR PAYMENT. IF YOUR NAME OR ADDRESS APPEARS INCORRECT. PLEASE LET US KNOW. WE TAKE PRIDE IN ADDRESSING OUR CUSTOMER Page 1 of 2 9110" Balance may or may not include interest accrued since the billing date. If you would pike to determine your payoff balance or if you have questions on this billing. please call Customer Service at 800-373-4739. Address written inquiries and all nonpayment correspondence to HFC Customer Service. P 0 BOX 1547. CHESAPEAKE VA 23320. ATTN. QWR DEPT. Mail payment tol HFC. POST OFFICE BOX 4153-K. CAROL STREAM IL 50197. NOTE: PLEASE SEE REVERSE SIDE FOR IMPORTANT INFORMATION 3 552°IUBP ,•E' EVIBIT "K' 007 N ")10271330300121335 HFC Pc BOX 60175 Statement of Your Account ` '•'TY OF INOJS CA 41714 Y Prvnent Account Number New Balance Closing Date Payment Due Minimum Amount c:o?,aon Data Due 713303.00-121335-0 9.808.23 08-10-2007 09-01-2007 2,757.50 0081000361 AUTO PRESORTED FIRST-CLASS Mail Payment To: THOMAS E BARD HFC POST OFFICE BOX 4153-K CARDL STREAM IL 60197-4153 0 10027575C7133030012133500009806235 For Assistance: ACCOUNT SUMWY 800-333-4758 PROPERLY. Get service when you want it. manage your account onlinel Make Payments, view statements or recent transactions. Register today at www.hfc.com .- see insert for details. TRADE IN your auto loan! Lower your payments--apply for a HFC auto refinance. Plus--no payments for 45 days. Call or stop by your local branch today. ` DELINQUENCY CHARGES ACCRUE AFTER 10 DAYS • • • Page 2 of 2 -New Balance may or my not include interest accrued since the billing date. If you would like to determine your payoff balance or if you have questions on this billing, please call Customer Service at 800-333-4758. Address written inquiries and all nonpayment correspondence to HFC Customer Service. P 0 BOX 1547, CHESAPEAKE VA 23320, ATTNv QNR DEPT. Mail payment t0: li:*C, POST OFFICE BOX 4153-X. CAROL STREAM IL 50197. NOTE: PLEASE SEE REVERSE SIDE FOR IMPORTANT INFORMATION ASSIGNMENT AND BILL DE SALE HSBC Consumer Lending (USA) Inc. on behalf of and as managing company for Beneficial Company LLC and HFC Company LLC and their respective subsidiaries (hereinafter called "Seller") has entered into an Account Purchase and Sale Agreement dated November 19, 2007 ("Agreement") for the sale of accounts dated in the initial paragraph of the Agreement thereof to Asset Acceptance LLC, (hereinafter called 'Purchaser"), upon the terms and conditions set forth in that Agreement. NOW, THEREFORE, for good and valuable consideration, Seller hereby sells, assigns, and transfers to Purchaser, its successors and assigns, all of Seller's rights, title, and interest in each and every one of the Accounts described in the Agreement. Purchaser and Seller agree that the Purchase Price shall be as stated in Paragraph 3 of the Agreement. fN WITNESS WHEREOF, Seller has signed and delivered this instrument on the 19th day of November, 2007. HSBC Consumer"ndinpIUSA) Inc. By: Printed Name: Title: Vice-President is HS SCConLendingAssetA=epNer4clean.doc OWS11 "N' AtaYt ec•Ptan [Y .at ASSET ACCEPTANCE LLC P.O. Box 2036 Warren, MI 48090 THOMAS E BARD 18 BARD RD SHIPPENSBURG, PA 17257-8143 ACCOUNT NUMBER CURRENT BALANCE 71330300121335 $9103.8 STATEMENT DATE DUE DATE - I- I DUE ACCOUNT NUMBER DATE OF LAST PAYMENT 71330300121335 08/29/06 DATE REFERENCE NO ACCOUNT INFORMATION BALANCE DUE 35529686 BALANCE DUE $9103.8 ASSET ACCEPTANCE LLC, A LIMITED LIABILITY COMPANY ORGANIZED AND EXISTING UNDER THE LAWS OF THE STATE OF DELAWARE, ASSIGNEE OF 71330300121335 P.O. Box 2036, Warren, MI 48090 DATE OF DELINQUENCY PURCHASED ON CHARGE OFF AMOUNT* INTEREST RATE 11/04/06 11/19/2007 $8194.51 18.00% SERVICE ADDRESS (IF APPLICABLE) INTEREST DUE AS OF $909.29 *For purposes of this Statement only, Charge Off Amount reflects credits for payments received by Asset, if any. THIS COMMUNICATION IS FROM A DEBT COLLECTOR DRIBIT "A" 910 H 35529686 J ? " 910 AYT, HAYT **PA** STATE OF MICHIGAN ) ss COUNTY OF MACOMB ) ASSET ACCEPTANCE, LLC Plaintiff, vs THOMAS E BARD Defendant, AFFIDAVIT I, Judy Melasi being first duly sworn deposes and states: That I am the Supervisor of ASSET ACCEPTANCE, LLC, a Limited Liability company organized and existing under the laws of the State of Delaware and doing business at P.O. BOX 2041, WARREN, MI 48090. That there is justly due and owing on the account the sum of $9103.80 representing the charged off amount and interest. That the said account originally with HSBC CONSUMER LENDING USA / , account number 71330300121335, has been purchased by ASSET ACCEPTANCE, LLC, who now owns said account and has all rights connected therewith including the right to institute this action. I certify that the facts contained in the D (7d this 08 th day of October, 2008. attached pleading are true and correct to the best of my information, knowledge and belief. Su isor Subscribed and sworn to before me, a Notary Public for the State of Michigan, the 08 th of October, 2008 as certified by my hand as set forth immediately below. a ? ? ZIZL? L), Iyublic Notary P,,?bi.. - "Iigcn Wc!yre Cou^rfv y Comm!ssion Exp. o- Fe 1 2012 [Zc t ing in the County of 35529686 910 HAYT, HAYT **PA** OG - 0 CASE NO: 2008-06941 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ASSET ACCEPTANCE LLC VS BARD THOMAS E NOAH CLINE , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE BARD THOMAS DEFENDANT at 18 BARD RD the at 0017:15 HOURS, on the 19th day of December-, 2008 SHIPPENSBURG, PA 17257 THOMAS E BARD DEFENDANT was served upon by handing to a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: So Answers: Docketing 18.00 Service 18.00 Affidavit .00 Surcharge 10.00 R. Thomas Kline Postage ? /b9 ? 1b2 .?2 x/46.42 12/23/2008 HAYT HAYT & LANDAU Sworn and Subscibed to By: before me this day ,Deputy Sheriff of A.D. pRtiG6NAV- ^R1GIN ?x IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL DIVISION ASSET ACCEPTANCE LLC NUMBER: 08-6941-CIVIL TERM vs. THOMAS E. BARD PRAECIPE FOR DEFAULT JUDGMENT AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of Plaintiff and against the Defendant(s) Thomas E. Bard for failure to answer Plaintiffs Complaint, endorsed with twenty (20) day notice to plead, served upon Defendant(s) on December 19, 2008 and assess damages as follows: Unpaid Balance $8,194.51 Plus Interest 909.29 Additional Charges .00 Plus Attorney's Fees .00 Less Credits, if any .00 TOTAL DUE $9,103.80 Pursuant to PaR.C.P. 237.1, I hereby certify that notice to file this Praecipe was mailed to the above named Defendant(s) and the Attorney of Record (if applicable) on January 14, and copy/copies of same is/are attached hereto ARTHUR LASHIN, ESQUIRE #23425 Attorney For Plaintiff I HAYT, HAYT & LANDAU 400 Market Street 6th Floor Philadelphia, Pennsylvania 19106 (215) 928-1400 COURT OF COMMON PLEAS AFFIDAVIT OF NON-MILITARY SERVICE ASSET ACCEPTANCE LLC STATE OF PENNSYLVANIA VS. SS THOMAS E. BARD : COUNTY OF PHILADELPHIA Arthur Lashin, being duly sworn according to Law, deposes and says that he represents the Plaintiff in the above entitled case; that he is authorized to make this Affidavit on behalf of the Plaintiff; and that the above named Defendant(s) is (are) 18 + years of age; the address of Defendant(s) is 18 Bard Road, Shippensburg, Pennsylvania 17257 Occupation of Defendant(s) is unknown; and the Defendant(s) is (are) not in the Military Service of the United States, nor any State of Territory thereof or its Allies as defined in the Soldiers' and the Sailors' Civil Relief Act of 1940 thereto. Arthur Lashin, Esquire, #23425 Attorney for Plaintiff Prothonotary Sworn to and subscribed before me this 2nd 20 09 C Notarv Piu, hli day of February A.D., My commission expires: COMMONWEALTh OF PENNSYLVANIA Notarial Seal Shari Deana Outen, Notary Public City Of Philadelphia, Philadelphia County i My Commission Expires kne 27, 2010 j Member, Pe-sa!_ o{ Notaries HAYT, HAYT & LANDAU, LLC By: Arthur Lashin, Esquire Identification No. 23425 400 Market Street Suite 600 (Philadelphia, PA 19106-2513 (215) 928-1400 Attorney for Plaintiff DATE: JANUARY 14, 2009 ACCEPTANCE LLC P.O. BOX 2041 WARREN, MI 48090 VS. THOMAS E BARD 18 BARD RD SHIPPENSBURG PA 17257 CUMBERLAND COUNTY COURT OF C0kG40N PLEAS CIVIL DMSION TERM. No. 08-6941-CIVIL TERM NOTICE OF INTENTION TO TAKE DEFAULT PURSUANT TO PA.R.C.P 237.1 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 days from the date of this notice, a judgment may be entered against you without a hearing and you may lose your proper 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 2 LIBERTY AVENUE CARLISLE PA, 17013 717-249-3166 By: BAR ASSOCIATION C L Y _ 0 ' ' --° s LAW OFFICES OF HAYT, HAYT & LANDAU, LLC By: Arthur Lashin, Esquire Identification No. 23425 123 S. Broad Street Suite 1660 Philadelphia, PA 19109-1003 (215) 928-1400 OUR FILE NO: 264540 Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION No. 08-6941-CIVIL TERM r Zrn u,r rs _ r) ORDER TO MARK JUDGMENT SATISFIED ITO THE PROTHONTARY: Kindly mark the Judgment Statisfied with regard to above captioned matter upon payment of your costs only. LAW OFFICES OF HAYT, HAYT & LANDAU, LLC By: Attorney for Plaintiff Fri w a ?' --? ?s ; 3 t? g-v ?p? 77 ?? a?sgs-3