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Home My WebLink About09-1997 2056974 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 ASSET ACCEPTANCE LLC ASSIGNEE OF CHASE BANK 28405 Van Dyke Avenue Warren MI 48093 Vs. KEITH E KUNTZ 187 FROST RD GARDNERS PA 17324 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : Cq- (q47 Civil kIclr*A 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 23, 2009 in the amount of $2,720.75. 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 3/17/2006. WHEREFORE, plaintiff claims of the defendant(s) the sum of $2,720.75 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDERIC I. W N RG, ESQUIRE JOEL M. FLINK, QUIRE Attorney for Plaintiff P01A.DB VERIFICATION FREDERIC I. WEINBERG, ESQUIRE, hereby states that he is the attorney for the Plaintiff(s) in this action and verifies that the statements made in the foregoing pleading are true and correct to the best of his knowledge, information and belief. The undersigned understands that the statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities. FREDERIC I. WEINBERG, ESQUIRE STATE OF MICHIGAN COUNTY OF MACOMB ss ?os6??y ASSET ACCEPTANCE, LLC ) Plaintiff, ) vs ) AFFIDAVIT KEITH E KUNTZ ) Defendant, ) 1, ?AAAA??- being first duly sworn deposes and states: That I am the Supervisor of ASSET ACCEPTANCE, LLC a Limited Liability company organized and existing under the laws of the State of Delaware and doing business at P.O. BOX 2041, WARREN, MI 48090. That there is justly due and owing on the account, the sum of $2701.40 representing the charged off amount and interest. That the said account originally with CHASE BANK/Heritage Chase / CHASE, account number 5260364295115327, has been purchased by ASSET ACCEPTANCE, LLC, who now owns said account and has all rights connected therewith including the right to institute this action. this 06th day of January, 2009. Subscribed and sworn t befor me, a Notary Public for the State of Michigan, the 06th of January, 2009 as certified by my hand as seet,forth mmediately below. v ? Notary Pu 1 wxbo? CHERYL Notary PubllC - chlgan Macomb County my Commission expires Jul 16, 2013 .wtlna in the County of 38063164 1064 GORDON & WEINBERG 0 0 3 8 0 6 3 1 6 4 Ass l? A<W<p IQ?Si .ni ASSET ACCEPTANCE LLC P.O. Box 2036 Warren, MI 48090 KEITH E KUNTZ 187 FROST RD GARDNERS,PA 17324 ACCOUNT NUMBER CURRENT BALANCE 5260364295115327 $2701.40 STATEMENT DATE DUE DATE JAN 06 2009 DUE ACCOUNT NUMBER DATE OF LAST PAYMENT 5260364295115327 03/17/06 DATE REFERENCE NO ACCOUNT INFORMATION BALANCE DUE JAN 06 2009 38063164 BALANCE DUE $2701.40 ASSET ACCEPTANCE LLC, A LIMITED LIABILITY COMPANY ORGANIZED AND EXISTING UNDER THE LAWS OF THE STATE OF DELAWARE, ASSIGNEE OF 5260364295115327 P.O. Box 2036, Warren, MI 48090 DATE OF DELINQUENCY PURCHASED ON CHARGE OFF AMOUNT* INTEREST RATE 05/05/06 08/08/08 $1961 44 18 00% . . SERVICE ADDRESS (IF APPLICABLE) INTEREST DUE AS OF JAN 06 2009 $739.96 *For purposes of this Statement only, Charge Off Amount reflects credits for payments received by Asset, if any. THIS COMMUNICATION IS FROM A DEBT COLLECTOR 38063164 1064 GORDON & WEINBERG El? N CJ Q u; d C ? . .4 y! ^? 4.4J r1,J 0 Sheriffs Office of Cumberland County R Thomas Kline ?,? of at+P% Edward L Schorpp SheriffSolicitor Ronny R Anderson Jody S Smith Chief Deputy OFFICE ' w-ERIFF Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 04/13/2009 08:50 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: Keith E. Kuntz, but was unable to locate him in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant Keith E. Kuntz. Per a post office check the mail is still delivered to 187 Frost Road,Gardners, Cumberland County, Pennsylvania 17324 for the defendant. However, the defendant's father,Richard Kuntz,states Keith E. Kuntz moved 6 weeks ago, exact address is not available. SHERIFF COST: $40.20 April 14, 2009 SO ANSWERS, R THOMAS KLINE, SHERIFF 2009-1997 Asset Acceptance LLC VS. Keith E. Kuntz CAF THE 2009 APR 20 AN 0* 4 7