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Home My WebLink About09-1462 D000420 THIS IS AN ARBITRATION MATTER 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 ASSESSMENT OF DIRECT COLLECT, INC. assignee of Household Bank/HSBC P.O. Box 2167 Blue Bell, PA 19422 Vs. CLARISSA M KUHN 127 DARR AVE CARLISLE PA 17013 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 09 - 14toa ?Vtl (p_tM 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 f a 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 24, 2008 in the amount of $1,144.28. 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. 7. Defendant's last payment on account was made on 6/13/07. WHEREFORE, plaintiff claims of the defendant(s) the sum of $1,144.28 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDERIC INBERG, ESQUIRE JOEL M. FL K, ESQUIRE Attorney for Plaintiff P01A.DB D000420 DIRECT COLLECT, INC. assignee of Household Bank/HSBC CLARISSA M KUHN 5155920000139304 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 course -im- rakrng!l}is- -v-erifi_Cation. This verification is made subject to 18 Pa.C.S. §4904 which provides for certain penalties for making false statements. LAUREN YELLIN 9002 CLARISSA M KUHN 5155920000139304 D000420 DIRECT COLLECT, INC. assignee of Household Bank/HSBC AFFIDAVIT I, LAUREN YELLIN, depose and say that: being duly served sworn according to law, 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 $1,085.74 plus interest of $56.40 at the rate of 6% less credits in the amount_of $._00_ totaling $1,142.14 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,correct to the best of my knowledge, information and belief. LAUREN YELLIN Sworn to and Subscribed - day before me this -/-5' of 2008 Notary Public ?.:OMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL DAWN M. MARSHALL, Notary Public City of Philadelphia. Phila. County Commission Ex Ires November 18 2009 tl- d v U a +v grn o =c Sheriffs Office of Cumberland County R Thomas Kline 4V0 et C1eL161,r ? Edward L Schorpp Sheri 46 r Solicitor Ronny R Anderson Jody S Smith Chief Deputy OFFICE OF THE 611ERIFF Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 03/11/2009 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: Clarissa M. Kuhn, but was to unable to locate her in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant Clarissa M. Kuhn. Per defendant's mother her new address is 9120 Newfield Street, Charlotte, North Carolina 28216. SHERIFF COST: $37.50 (PAID) March 19, 2009 ;S;0ANSWVVERP,r R THOMAS KLINE, SHERIFF Docket NO. 2009-1462 Direct Collect, Inc. v Clarissa M.Kuhn C? ?- ? ,,.? ? r ? ? ? ,,? ; L ? ; -?. r ..? :, ...w- i 1 L? 1 ,.?;,