HomeMy WebLinkAbout09-0167IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NCO Portfolio Management ASGNE OF
MBNA CIVIL ACTION
507 Prudential Road
Horsham, PA 19044
Plaintiff
vs. NO: QQ_ Ol(o'1 CIYi! ~~
R M WISKEMANN
133 STONEY POINT AVE
SHIPPENSBURG PA 17257
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
NCO Portfolio Management ASGNE OF
MBNA CIVIL ACTION
507 Prudential Road
Horsham, PA 19044
Plaintiff .
vs. NO: Dpi- ~~G7 ~ ~.v~-
R M WISKEMANN
133 STONEY POINT AVE
SHIPPENSBURG PA 17257
Defendant
COMPLAINT
Plaintiff, NCO Portfolio Management ASGNE OF MBNA, by and through its attorneys,
Edwin A. Abrahamsen & Associates, P.C., complains of the Defendant as follows:
1. Plaintiff, NCO Portfolio Management ASGNE OF MBNA, (hereinafter "Plaintiff')
is a Pennsylvania corporation with a principal place of business located at 507 Prudential Road
Horsham, PA 19044
2. The Defendant R M WISKEMANN (hereinafter "Defendant") is an adult
individual residing at 133 STONEY POINT AVE SHIPPENSBURG PA 17257.
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 ASGNE OF MBNA
NCO with the account number 4264298997988392.
5. The within account was sold by ASGNE OF MBNA NCO to NCO FINANCIAL
SYSTEMS, INC for valuable consideration and all rights under said accounts were assigned to
NCO FINANCIAL SYSTEMS, INC.
6• Use of the ASGNE OF MBNA NCO credit card was subject to the terms of the
Cardmember Agreement, a copy of which was sent to the Defendant along with the credit card.
7• Defendant used the ASGNE OF MBNA NCO credit card account
number4264298997988392, for purchases, cash advances and/or balance transfers.
8. The Defendant was mailed account statements relative to the Defendant's use of the
subject credit card.
9• The Defendant defaulted under the terms of the Agreement by failing and refusing
to make monthly payments on the account as they became due.
10. The account became delinquent March 28, 2006.
11. The principal amount was $8,694.33 at the time it was received by Plaintiff.
12. Pursuant to the account agreement, any unpaid balance accrues interest at the rate
of 0.
13. The total amount due and owing the Plaintiff including interest, is $11,167.65.
14. 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 $11,167.65 plus costs of suit, reasonable attorneys' fees and any other relief as the
Court deems just and appropriate.
Respectfully submitted,
t/dwin A. Abrah Assoc.
Michael F. Ratc o ,Esquire
Heather K. W ff, Esquire
Attorney I.D. Nos.: 86285/207805
1729 Pittston Avenue
Scranton, PA 18505
mratchford@eaa-law. com
hwoodruff@eaa-law. com
VERIFICATION
I, Michael F. Ratchford, attorney for Plaintiff, NCO Portfolio Management ASGNE OF
MBNA, 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.
rv
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