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Home My WebLink About09-1595 Blatt, Hasenmiller, Leibsker & Moore, LLC Attorney for Plaintiff, Daniel Santucci DELL FINANCIAL SERVICES L.L.C. Attorney I.D. #92800 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 800-850-1079 DELL FINANCIAL SERVICES L.L.C. c/o Blatt, Hasenmiller, Leibsker & Moore, LLC 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 Plaintiff, vs. MARK A HERSH 212 CONSTITUTIONAL CT MECHANICSBURG PA 17050-4608 Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. OQ - (mss CtVta Texft 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 2216257 PPTCHDFI A Blatt, Hasenmiller, Leibsker & Moore, LLC Daniel Santucci Attorney I.D. #92800 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 800-850-1079 DELL FINANCIAL SERVICES L.L.C. c/o Blatt, Hasenmiller, Leibsker & Moore, LLC BERLAND COUNTY, PA VS. MARK A HERSH Plaintiff, 212 CONSTITUTIONAL CT MECHANICSBURG PA 17050-4608 Defendant(s). Attorney for Plaintiff, N THE COURT OF COMMON PLEAS VIL ACTION 0 9 - is 9s, COMPLAINT Plaintiff DELL FINANCIAL SERVICES L.L.C., claims as follows: 1. The Defendant(s), MARK A HERSH , is a resident of Cumberland County, Pennsylvania. 2. The Defendant(s) obtained extensions of credit with DELL FINANCIAL SERVICES L.L.C., (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 $2346.33. 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. 2216257 PPTCDBCI WHEREFORE, the Plaintiff, DELL FINANCIAL SERVICES L.L.C., prays for judgment in its favor and against Defendant(s), MARK A HERSH in the amount of $2346.33, plus costs. Respectfully submitted, DELL FINANCIPA*6ERVICES L.L.C. Ong'%A Attomey-t - Daniel Santucci, Attorney 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 STATE OF -T eXdS COUNTY OF "T 1'0a1ZS AFFIDAVIT OF INDEBTEDNESS The undersigned, being duly sworn, deposes and states that he/she is an employee/agent of: DELL FINANCIAL SERVICES L.L.C. and has knowledge of the account balance, and is duly authorized to make this affidavit. Affiant states that the amounts shown below are taken/calculated from the original books and records of the above named plaintiff, and based on information and belief, affiant states that the amount due to DELL FINANCIAL SERVICES L.L.C. by MARK A HERSH for funds advanced to defendants(s) or paid to another at defendant(s) request, or for goods or services provided to defendant(s) or to another at defendant's request, is the following on the following account(s): CREDITOR/ACCOUNT NUMBER CURRENT BALANCE DELL FINANCIAL SERVICES L.L.C. 6879450129041718167 $2346.33 Affiant states that the amount shown above is true and correct and that there are no setoffs or counterclaims available to defendant(s). Further affiant sayeth not. Subscribed and Sworn to Before me day of J30.6--.,20-d-. Notary Public My Commission Expires: Erin Towns, Affiant Recove[y Manager Date of Service:/ /20 ffwNolary :ANIOINETTE L. BENSON y Commiss lres s Reference #: 2216257 optombw 05, 2011 Forwarder ID #: R Account #: 6879450129041718167 Client Account #: 4745387 BAFFDELL(11/02)EEO. DELL FINANCIAL SERVICES i I I ?INII?I?HII?IIN?11111181 r oo.. C> v f V' ? i c r V v ) -?• GJ t iT. a > l:` C ,. 3 Blatt, Hasenmiller, Leibsker & Moore, LLC Daniel Santucci Attorney I.D. #92800 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 800-850-1079 DELL FINANCIAL SERVICES L.L.C. c/o Blatt, Hasenmiller, Leibsker & Moore, LLC 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 Plaintiff, VS. MARK A HERSH 212 CONSTITUTIONAL CT MECHANICSBURG PA 17050-4608 Attorney for Plaintiff, DELL FINANCIAL SERVICES L.L.C. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. (A - 15Q 5 (2,04;t Text. PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY: Kindly ENTER my appearance in the above-captioned matter on behalf of PLAINTIFF DELL FINANCIAL SERVICES L.L.C.. 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 By: 2216257 PPTXPEAI BLATT, HASENMILLER, LEIBSKER P MOORS 1 1 Sheriffs Office of Cumberland County R Thomas Kline i'oovp of CHI"bEdward L Schorpp Sheri Solicitor dot Ronny RAnderson - Jody S Smith Chief Deputy OFPiCe F THE SHERIFF Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 03/24/2009 03:24 PM - Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on March 23, 2009 at 1524 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Mark A. Hersh, by making known unto himself personally, defendant at 212 Constitutional Court, Mechanicsburg, Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $37.00 SO ANSWERS, O0 March 24, 2009 2009-1595 DELL FINANCIAL SERVICES LLC VS R THOMAS KLINE, SHERIFF a By Deputy Sheriff MARK A. HERSH C L.i- Lysy., Y^' Cl_ U-) N N s `'t Blatt, Hasenmiller, Leibsker & Moore, LLC Daniel Santucci Attorney I.D. #92800 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 800-850-1079 ext. 4151 Attorney for Plaintiff, DELL FINANCIAL SERVICES L.L.C. DELL FINANCIAL SERVICES L.L.C. c/o Blatt, Hasenmiller, Leibsker & Moore, LLC 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 Plaintiff, VS. MARK A HERSH 212 CONSTITUTIONAL CT MECHANICSBURG PA 17050-4608 Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. 09-1595-CV PRAECIPE FOR ENTRY OF JUDGMENT BY DEFAULT FOR FAILURE TO PLEAD TO THE PROTHONOTARY: Kindly ENTER a JUDGMENT BY DEFAULT FOR FAILURE TO PLEAD against the DEFENDANT MARK A HERSH in this matter in the amount of $2346.33 plus court costs. I also hereby certify that a true and correct copy of the Notice required by Pa.R.C.P. 237.1(a)(2) was mailed separately to each defendant on 03/24/09 by regular mail. A true and correct copy of each Notice is attached hereto. Respectfully submitted, BLATT, HASENMILLER, LEIBSKER & MOORE, LLC Dated: May 18, 2009 By: Danie ntucci 2216257 PPTJPRJI II INN EMN Nil 101 1 Blatt, Hasenmiller, Leibsker & Moore, LLC Attorney for Plaintiff, Daniel Santucci DELL FINANCIAL SERVICES L.L.C. Attorney I.D. #92800 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 800-850-1079 DELL FINANCIAL SERVICES L.L.C. c/o Blatt, Hasenmiller, Leibsker & Moore, LLC 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 Plaintiff, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION VS. MARK A HERSH 212 CONSTITUTIONAL CT MECHANICSBURG PA 17050-4608 Defendant(s). AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: County of Chester: I, Daniel Santucci, being duly sworn according to law, depose and say I am the attorney for Plaintiff and I am authorzied to make this affidavit on Plaintiff's behalf. I hereby certify that the Defendant is at least 18 years of age and not in the Military Service of the United States, nor any State or Territory thereof or its allies as defined in the Soldiers' and Sailors' Civil Relief Act of 1940 and any amendments thereto. I also herby certify that the statements made in the foregoing Affidavit of Non-Military Service are true and correct to the best of my information, knowledge, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to No. 09-1595-CV unsworn falsification to authorities. BLATT, HASENMI LER, LEIBSKER & MOORE, LLC Dated: May 18, 2009 By: Santucci 2216257 PPTJCAMI ,4 DELL FINANCIAL SERVICES LL C. Plaintiff, VS. MARK A HOW 212 CONSTITUTIONAL CT MECHANICSBURG PA 17050-4806 Defendant(s). TO: MARK A HERSH Date of Notice: April 21, 2009 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. 09-1595-CV IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. 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 BLATT, HASE LLER, LEIBSKER &MO7,L By: nie ntuoci 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 800-850-1079 x 4151 This is a communication from a debt collector. This Is an attempt to collect a debt and any Information obtained will be used for that purpose. 2216257 PPTNLRSI II111 '1II (1111 4 o), Sheriffs Office of Cumberland County R Thomas Kline ?? t et Edward L Sclicrrpp Sheriff Ronny R Anderson Jody S Smith Chief Deptay OMM OF "a Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 03/2412009 03:24 PM - Michael Barrick, Deputy Sheriff, who being duty sworn according to law, states that on March 23, 2009 at 1524 hours, he served a true copy of the within COmplaint and Notice, upon the within named defendant, to wit: Mark A. Hersh, by making known unto himsgif personally, defendant at 212 Constitutional Court, Mechanicsburg, Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and correct copy of the some. SHERIFF COST: $37.00 SO ANSWERS, March 24, 2009 R THOMAS KLINE, SHERIFF r 2009-1595 By ?-Xl DELL FINANCIAL SERVICES LLC Deputy Sheriff ,l\ ? FILE , THE 2009 JUN PH 3: J *4.00 ft fAcelp a 44 wT* ,?, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. No. 09-1595-CV DELL FINANCIAL SERVICES L.L.C. Plaintiff, vs. MARK A HERSH Defendant(s). TO: MARK A HERSH NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Default Judgment has been entered against you in the above proceeding. Dated: 1,11 By: PROTHONOTARY IF YOU HAVE ANY QUESTIONS CONCERNING THE ABOVE, PLEASE CONTACT: Attorney of Record for Plaintiff: Blatt, Hasenmiller, Leibsker & Moore, LLC Daniel Santucci Attorney I.D. #92800 P.O. Box C3800 Southeastern, PA 19398 800-850-1079 2216257 PPTNDJNI III ?N? \ S J