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Home My WebLink About09-0189 .= ,_, ._. -_ ..:.. ~,~. .~. ~_ .~ ~~ -~ .~. 2054619 THIS IS AN ARBITRATION MATTER. DAMAGES HEARING REQUIRED. CORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 NU ISLAND PARTNERS, LLC AS ASSIGNEE OF HSBC BANK NEVADA, N.A P.O. Box 3395 Little Rock, AR 72201 VS. ANGELA L MINICH 437 N EAST ST CARLISLE PA 17013-2010 ASSESSMENT OF COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. (~- p~$q cjv~l T r(wt NOTICE 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 ARE SERVED, BY ENTERING A WRITTEN APPEARANCE PERSONALLY OR BY 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 JUDGEMENT 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. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 T COMPLAINT IN CIVIL-ACTION 1. Plaintiff is a debt buyer and successor in interest to the original creditor as set forth in the caption of this Complaint. 2. At all times relevant hereto, the defendant(s) was the holder of a credit card, which at the request of the defendant(s) was issued to the defendant(s) by the plaintiff under the terms of which the plaintiff agreed to extend to defendant(s)the use of plaintiff's credit facilities. 3. Defendant(s) accepted and used the aforesaid credit card so issued and by so doing agreed to perform the terms and conditions prescribed by the plaintiff for the use of said credit card. 4. The defendant(s)received and accepted goods and merchand- ise and/or accepted services or cash advances through the use of the credit card issued by the Plaintiff. A true and correct copy of the Statement of Account, if available, is attached hereto as Exhibit "A" 5. All the credits to which the defendant(s)is entitled have been applied and there remains a balance due as of December 31, 2008 in the amount of $1,419.69. 6. Plaintiff has made demand upon the defendant(s)for payment of the balance due but the defendant(s)has failed and refused and still refuses to pay the same or any part thereof. 7. Defendant's last payment on account was made on 8/23/06. WHEREFORE, plaintiff claims of the defendant(s) the sum of $1,419.69 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDERIC I. NBERG, ESQUIRE JOEL M. FLINK, ESQUIRE Attorney for Plaintiff P01A.DB 2054619 NU ISLAND PARTNERS, LLC A5 ASSIGNEE OF HSBC BANK NEVADA, N.A I hereby state that I am the agent for the plaintiff herein, and that the facts set forth in the attached Affidavit which is incorporated by reference in the foregoing Complaint in Civil Action are true and correct to the best of my knowledge, information and belief and is based upon information which plaintiff has furnished to counsel. The language in the Complaint is that of counsel and not of plaintiff. To the extent that the contents of the Complaint are that of counsel, plaintiff has relied upon counsel in making this verification. This verification is made subject to 18 Pa.C.S. 84904 which provides for certain penalties for making false statements. (Affiant's ame) 2047 2054619 NU ISLAND PARTNERS, LLC AS ASSIGNEE OF HSBC BANK NEVADA, N.A ANGELA L DaINICH 5155970001449962 AFFIDAVIT _~ CRYSTAL PETTIT being duly served sworn according to law, depose aad say that: 1. I am the agent for the Plaintiff herein aad I have custody aad control of the files relating to this account; 2. I have personal knowledge of the facts aad circumstances in connection with this case; 3. Plaintiff's files are maintained is the usual and ordinary course of business; 4. This action is based oa a claim for breach of contract aad that damages are sought as a direct result of said breach; 5. There is now due aad owing from defendant to plaintiff, the amount of $1,243.67 plus interest of $170.30 at the rate of 69a less credits is the amount of $.00 totaling $1,413.97 as of December 3, 2008. 6. If called upon, affiaat can testify at trial as to the facts pertaining to this matter. The above facts are true and correct to the best of my knowledge, information and belief. Name ,,, .,,, ~~t Fi~q~, ~" J~ tiny Comm. Ex;:iras ~= FpRIL 15, 2013 \J•'~ ct ' ~~ co~`~•`° ~. Sworn to aad Subscribed before me this ~ day ~ ~ U ~ O [~ r_ :~ '^., '~ ~' ~, ~p o .o ~ ~~' ~;-. ~ y Ot ~ d ~- ~ ' . f -:~ ~~ 9~ (1~ ~ : ' ~ _~ ~ _.a ~ ~ ~~ ~ "~" -~ c ~ _ ~, :~ w o ~c