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Home My WebLink About09-1249D000482 THIS IS AN ARBITRATION MATTER. ASSESSMENT OF DAMAGES HEARING REQUIRED. GORDON & 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 DIRECT COLLECT, INC. assignee of Household Bank/HSBC a.k.a. Ameritech P.O. Box 2167 Blue Bell, PA 19422 Vs. RONDA J ONEAL 39 TOWN MILLS MOBILE HOME PARK SHIPPENSBURG PA 17257 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : Dq - 1dg4 0,1v4Term 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 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 January 6, 2009 in the amount of $3,552.28. 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. 1 • 7. Defendant's last payment on account was made on 6/20/2007. WHEREFORE, plaintiff claims of the defendant(s) the sum of $3,552.28 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDERIC I. WE WNBEUG, ESQUIRE JOEL M. FLINK, IRE Attorney for Plaintiff P01A.DB DC00482 DIRECT COLLECT, INC. assignee of Household Bank/HSBC a.k.a. Ameritech RONDA J ONEAL 5408010033147337 VERIFICATION 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. 54904 which provides for certain penalties for making false statements. Y1A k1A-M,1 A REN YELLIN 9002 D000482 DIRECT COLLECT, INC. assignee of Household Bank/HSBC a.k.a. Ameritech RONDA J ONEAL 5408010033147337 AFFIDAVIT I, LAUREN YELLIN, being duly served sworn according to law, depose and say that: 1. I am the agent for the Plaintiff herein and I have custody and control of the files relating to this account; 2. I have personal knowledge of the facts and circumstances in connection with this case; 3. Plaintiff's files are maintained in the usual and ordinary course of business; 4. This action is based on a claim for breach of contract and that damages are sought as a direct result of said breach; 5. There is now due and owing from defendant to plaintiff, the amount of $3,363.73 plus interest of $174.73 at the rate of 6% less credits in the amount of $.00 totaling $3,538.46 as of December 12, 2008. 6. If called upon, affiant can testify at trial as to the facts pertaining to this matter. The above facts are true and corr ct to the best of y knowledge, information and belief. 1 L UREN YELLIN Sworn to and Subscribed before me this day of 2008 A /itXzz- r?`???? Notary Public OMMON?NEALTH CiF isENNY?-VAN1F NOTARIAL SEAL Public DAWN M MARSHALL, Notary City of Philadelphia. Phil a. County ? IS, 2- M3 Sion ?x Iras nv Mbe a (n D Sheriffs Office of Cumberland County R Thomas Kline 'a111p of cumbot4w# Edward L Schorpp Sheri` Solicitor Ronny R Anderson" Jody S Smith Chief Deputy OFFICE OF THE SHERIFF Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 03/06/2009 05:39 PM - R. Thomas Kline, Sheriff who being duly sworn according to law states that he made a diligent search and inquiry for the within named defendant to wit: Ronda J. O'Neal at 39 Town Mills Mobile Home Park, Shippensburg, Cumberland County, Pennsylvania but was unable to locate her in his bailiwick he therefore returns the within Complaint and Notice as not found as to the defendant, Ronda J. O'Neal. Post Office advises defendant moved and left no fowarding address. SHERIFF COST: $51.00 (PAID) SO ANSWERS, raC March 16, 2009 R THOMAS KLINE, SHERIFF 2009-1249 By Deputy Sheriff Direct Collect Inc. VS Ronda J. Oneal ? a -c