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Home My WebLink About09-1594Blatt, Hasenmiller, Leibsker & Moore, LLC Attorney for Plaintiff, Daniel Santucci MERRICK BANK CORPORATION Attorney I.D. #92800 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 800-850-1079 MERRICK BANK CORPORATION c/o Blatt, Hasenmiller, Leibsker & Moore, LLC 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 Plaintiff, VS. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. 09- 16 Civil -Teak VICTORIA S STOUT 6280 CARLISLE PIKE LOT 405 MECHANICSBURG PA 170505249 Defendant(s). 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 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 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, 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. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 267-2032 2171762 PPTCHDFI Blatt, Hasenmiller, Leibsker & Moore, LLC Daniel Santucci Attorney I.D. #92800 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 800-850-1079 Attorney for Plaintiff, MERRICK BANK CORPORATION c/o Blatt, Hasenmiller, Leibsker & Moore, LLC Plaintiff, VS. VICTORIA S STOUT 6280 CARLISLE PIKE LOT 405 MECHANICSBURG PA 170505249 Defendant(s). N THE COURT OF COMMON PLEAS 3UMBERLAND COUNTY, PA -aIVIL ACTION COMPLAINT Plaintiff MERRICK BANK CORPORATION, claims as follows: 1. The Defendant(s), VICTORIA S STOUT, is a resident of Cumberland County, Pennsylvania. 2. The Defendant(s) obtained extensions of credit with , (Original Credit Grantor) agreeing to make monthly payments as required by the terms of the account, for purchases charged to the account. 3. The Defendant(s) did make purchases and charged same to the account but failed to make the monthly payments called for on the account. There is a balance due and owing of $2261.97. 4. Plaintiff is the successor in interest of said account having purchased the account in the regular course of business in good faith and value. 5. Plaintiff declared Defendant(s) to be in default and demands payment of the balance. 2171762 PPTCDBCI WHEREFORE, the Plaintiff, MERRICK BANK CORPORATION, prays for judgment in its favor and against Defendant(s), VICTORIA S STOUT in the amount of $2261.97, plus costs. Respectfully submitted, MERRICK BANK COOPORA Daniel Santucci, Atto- iey No. 92800 Blatt, Hasenmiller, Leibsker & Moore, LLC 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 (800) 850-1079 Dated: February 20, 2009 THIS COMMUNICATION IS FROM A DEBT COLLECTOR. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. VERIFICATION I, DANIEL SANTUCCI, the undersigned attorney for the Plaintiff, hereby verify that the statements made in the foregoing Complaint are true and correct to the best of my knowledge, information, and belief, based upon information provided by the Plaintiff, that the Plaintiff is presently located outside of this jurisdiction, and that in order to file the within document in an expedient and timely manner I am authorized to sign this verification on behalf of the Plaintiff. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsifications to aut PPTXVERI Attorney for Plaintiff Exhibit ''A'' PPTXEXAI ona? In court Judicial (Circuit/District) Original Creditor Name: MERRICK BANK Debtor Name: STOUT, VICTORIA S Co-Debtor Name: Account Number: 4120613067300696 TION AFFIDAVIT OF INDEBTEDNESS, NON-MILITARY SERVICE & PURCHASE OF ACCOUNT STATE OF PENNSYLVANIA COUNTY OF ALLEGHENY ss.: The undersigned, being duly sworn, deposes and says: 1. That I am a competent person over eighteen years of age. I am employed by MERRICK BANK CORPORATION within the debt collection operation of that corporation, and as such, I am fully familiar with the facts and circumstances set forth herein. 2. My job responsibilities include the performance and monitoring of collection and recovery services. In that capacity, I am familiar with the manner and method by which MERRICK BANK CORPORATION creates and maintains its normal business books and records including computer records of its collection and recovery accounts. 3. Based upon my personal knowledge of MERRICK BANK CORPORATION's business records and practices for the servicing of its receivable accounts, the contents of this Affidavit are true and correct. If called upon and sworn to testify hereto, I could and would so competently testify thereto. 4. This action is based upon a Credit Card Agreement entered in to by defendant(s),kith defendant(s)'s original credit grantor. Pursuant to the Credit Card Agreement, Defendant(s) agreed to pay all amounts charged to account 4120613067300696. 5. MERRICK BANK CORPORATION purchased the defendant(s)'s defaulted receivable from defendant(s)'s original credit grantor, and, succeeded to all the rights of the original credit grantor as against defendant(s). MERRICK BANK CORPORATION purchased the account on or about 07/25/2008. 6. In the ordinary course of business, MERRICK BANK CORPORATION maintains or has access to copies of account documentation including credit agreements entered into between the original credit grantor and the defendant(s). The credit agreement entitles the original credit grantor to recover, to the extent permitted by applicable law, reasonable attorney's fees and costs incurred in any action to enforce its rights under the credit agreement. MERRICK BANK CORPORATION, as purchaser of the defendant(s)'s defaulted accounts receivable, succeeded to all rights of the original credit grantor set forth in the credit agreement. 7. MERRICK BANK CORPORATION maintains, as a regular practice of its business, computer records of activity on its accounts, including payments received, amounts owing on such accounts, credits and offsets. Entries are made in such computer records by individuals at MERRICK BANK CORPORATION who have examined account information or who have relied on account information from the original credit grantor. Such entries are made by, at, or near the time the events occurred. 8. The just and true balance due and owing to MERRICK BANK CORPORATION by the accountholder(s) on Account number 4120613067300696 is $2261.97 after all just an,0 lawful bffsets, payment and credits have been allowed together with interest as allowed by applicable law. Defendant(s) has incurred charges by the use of the charge account, but has defaulted in the payment to be made pursuant to the terms of the account. 9. Demand for payment of the just amount owing Plaintiff by Defendant(s) has been made and payment for the amount owing has not been tendered. 10. Upon information and belief, none of the above named defendant(s) is active in the military service of the United States or any of its allies as defined in the Soldiers & Sailor's Relief Act of 1940 with amendments. 11. All documents attached hereto (if any) are certified to be correct originals or true and correct copies of the originals being reproductions from the records of MERRICK BANK CORPORATION and/or the original credit grantor or being evidence to establish the contents of a lost or destroyed document. ,:eclare penalty of perjury that the foregoing is true and correct. i 't -D 1 - . 01 Agent Date The forgoing affidavit sworn to and subscribed before me this 2/3/2009 3:41:38 PM day of 2/3/2009 3:41:38 PM, by the Declarant who is personally known to me. My commission expires: Public COMMONW T R' VANW 'Ca nY41on 'Ay ?+ NOV. 20, 2012 A021 BLATT, HASENMILLER, LEIBSKER & MOORE, L.L.C. -M- C7 ^? ?""1 ,.c? ? .,.,? ? ? _"' ? ? .D b GJ J ? ? ?? ., ' ` ? j f`f1 ~ _? ,.+ -? 7 .«. -? Blatt, Hasenmiller, Leibsker & Moore, LLC Attorney for Plaintiff, Daniel Santucci MERRICK BANK CORPORATION Attorney I.D. #92800 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 800-850-1079 MERRICK BANK CORPORATION c/o Blatt, Hasenmiller, Leibsker & Moore, LLC 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 Plaintiff, VS. VICTORIA S STOUT 6280 CARLISLE PIKE LOT 405 MECHANICSBURG PA 170505249 Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION `( /? No. - l5g4 0,A W le-m PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY: Kindly ENTER my appearance in the above-captioned matter on behalf of PLAINTIFF MERRICK BANK CORPORATION. Papers may be served at the address set forth below: Blatt, Hasenmiller, Leibsker & Moore, LLC 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 Telephone Number: 1-800-850-1079 ext. 4151 Dated: February 20, 2009 BLATT, HASENMILLER, LEIBSKER & MOORE, LLC By: Daniel antucci 2171762 PPTXPEAI f'a rV ur -V CA) Sheriffs Office of Cumberland County R Thomas Kline 4'04var at Cumbcrtfi Edward L Schorpp Sheri r Solicitor t t tr ?+ Ronny R Anderson Jody S Smith Chief Deputy 0MCE OF T'-? s4Ea re Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 03/27/2009 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: Victoria S. Stout, Mechanicsburg, Cumberland County, Pennsylvania, 17050, but was unable to locate her in his bailiwick he therefore returns the within Complain' as not found as to the defendant, Victortia S. Stout. Post Office advises new address is 218 S. Main Street Marysville, Perry County, Pennsylvania, 17053. SHERIFF COST: $42.00 SO ANSWERS, March 30, 2009 R THOMAS KLINE, SHERIFF Docket No. 2009-1594 Merrick Bank v Victoria S.Stout