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Home My WebLink About09-2003v? 2055670 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 AS ASSIGNEE OF CIRCUIT CITY/CHASE 28405 VAN DYKE AVENUE WARREN, MI 48093 VS. ASHLEY L GOODYEAR 75 E WILLOW ST CARLISLE PA 17013 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 0_a0O3 Givit 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 1/13/09 in the amount of $3,842.19. 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 12/15/06. WHEREFORE, plaintiff claims of the defendant(s) the sum of $3,842.19 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDERIC I. #I *ERG, ESQUIRE JOEL M. FLINK, SQUIRE Attorney for Plaintiff P01A.DB VERIFICATION 1 hereby state that I airy 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. §4904 which provides for certain penalties for making false statements. Name`) Judy Melasi STATE OF MICHIGAN ) ss COUNTY OF MACOMB ) ASSET ACCEPTANCE, LLC Plaintiff, vs ASHLEY L GOODYEAR Defendant, 1, Judy Melasi ZG5'?lo? D AFFIDAVIT ) 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 $3796.18 representing the charged off amount and interest. That the said account originally with CIRCUIT CITY/CHASE/, account number 1820000003177793, 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. Dd this 19th day of December, 2008. ?-k kA &4A-? ervisor Subscribed and sworn to before me, a Notary Public for the State of Michigan, the 19th of December, 2008 as certified by my hand as set forth immediately below. Notary Public 37914116 Mul 1?11 Elm loll fin 1111111 1064 GORDON & WEINBERG 11111o I 11,111 0 0 3 7 9 1 4 1 1 6 ASSET ACCEPTANCE LLC P.O. Box 2036 Warren, MI 48090 ASHLEY L GOODYEAR 75 E WILLOW ST CARLISLE,PA 17013 ACCOUNT NUMBER CURRENT BALANCE 1820000003177793 STATEMENT DATE $3796.18 DUE DATE DEC 19 2008 DUE ACCOUNT NUMBER 1820000003177793 DATE OF LAST PAYMENT 12/15/06 DATE REFERENCE NO ACCOUNT INFORMATION BALANCE DUE DEC 19 2008 37914 F16 BALANCE DUE $3796.18 ASSET ACCEPTANCE LLC, A LIMITED LIABILITY COMPANY ORGANIZED AND EXISTING UNDER THE LAWS OF THE STATE OF DELAWARE, ASSIGNEE OF 1820000003177793 P.O. Box 2036, Warren, MI 48090 DATE OF DELINQUENCY PURCHASED ON CHARGE OFF AMOUNT* INTEREST RATE 12/26/06 07/14/08 $3009.56 18.00% SERVICE ADDRESS (IF APPLICABLE) INTEREST DUE AS OF DEC 19 2008 $786.62 *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 37914116 1064 GORDON & WEINBERG 1 ? ..a W D 00 b 000 t` N G.) Q T 'T7 Jr l'.?I a" 0 Sheriffs Office of Cumberland County R Thomas Kline o?titp ntaw6rfa Edward L Schorpp Sheriff $ Solicitor Ronny R Anderson Jody S Smith Chief Deputy OFFICE OF THE SHERIFF Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 04/06/2009 08:05 PM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on April 2, 2001 at 2105 hours, he served a true copy of the within Complaint and Notice, upon the within named defendan to wit: Ashley L. Goodyear, by making known unto herself personally, defendant at 75 E. Willow Street, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $32.50 April 06, 2009 2009-2003 ASSET ACCEPTANCE LLC VS ASHLEY L. GOODYEAR SO ANSWERS, R THOMAS KLINE, SHERIFF By --o Deputy Sheriff FIEDA-)rriCE OF THE FROTKONOTARY 1N9 APR -8 AM 9: 5y4 PENNSYLVANIA V ]ORDON&WEINBERG GORDON & WEINBERG, P.C. BY: FREDERIC 1. WEINBERG, ESQUIRE Identification Nc:. : 41360 JOEL M FLINK, ESQUIRE Identification No.: 41200 1001 E. HECTOR STREET CONSHOHOCKEN, PA 19428::484/351-0500 Fax Apr 28 2009 05:20pm P002/004 2055670 ASSET ACCEPTANCE AS ILSSI(WEE OF CIRCUIT CITY/CHASE VS. ASHLEY GOODYEAR COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 2009-2003 S`a IPQLATION OF BETTLSKMTT It is HEREBY STIPULATYF.I) AND AGREED that the above-entitled action is settled by agreeme.t of the parties under the following terms and conditions: 1. Defendant and Plaintiff desire to settle the above captioned matter and stipulate that Defendant will pay to the order of Gordon and WeinU:!rg, P.C., attorneys for the Plaintiff, at their offices ?t 1001 E. Hector Street, Conshohocken, Pennsylvania 19413, for the sum of Two Thousand Eight Hundred ($2,800.00)Dollars. a. Five (5) eq,a:il and consecutive payments of Five Hundred Sixty ($560.00)Dollars due on or before the 10th of each month beginning May 10, 2009 through September 10, 2009. 2. Defendant appears generally herein and submits to the jurisdiction of *,the Court. 3. In the event (o' a default of any of the above listed J. 4 "GOROON&WEINBERG Fax Apr 28 2009 05:21pm P003/004 conditions and pz?yments, Plaintiff may, upon 10 days notice enter judgment for the relief demanded in the Complaint filed in this matter plus judicial interest of 6% running from the date of filing. :i 4. Upon full and fi, al compliance with this stipulation, this action shall be deemed fully settled, discontinued and/or satisfied. 5. In accordance wit;h the terms of this agreement there appears I to be a related consent order for judgment held in escrow which will automatically extinguish upon compliance with the above mentioned terms. Gordon and Weinberg, P.C. Joel M. Flink, Esquirk: i 04eo?c ? Ashley Goodyear ..,, nv, w Luuj uo. aNm ruuL,uva GORDON & WEINBERG, P.C. BY, FREDERXC I. WEMBISRG, ESQUIRE Identification NoI..: 41360 JOEL M FLINK, USQUIRE Identification NC!.: 41200 1001 9- HEC'T'OR STRS$T CONSHOHOCKM, PA 19428:.- 484/351-0500 ASSET ACCEPTANCE AS ASSIMEE OF CIRCUIT CITY/CHASE Va. ASHLEY (70ODYEAR 2055670 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. ; 2009-2003 01?XF ATYOR O?. 9XTl'L1 W i It is HEREBY STIPULATgp AND AGREED that the above-entitled action is settled by agreement of the parties under the following terms and conditions: Defendant and Plaintiff desire to settle the above captioned matter and stipulate that Defendant will pay to the order of Gordon and Weinberg, P.C., attorneys for the Plaintiff, at their offices at 1001 M. Hector Street, Conshohocken, Pennsylvania 194 .8, for the sum of Two Thousand Bight Hundred ($2,800. 00) Dollaxs. A, Five (5) equal and consecutive payments of Five Hundred Sixty ($560:00)Dollars due on or before the 10th of each month beginning May 10, 2009 through September 10, 2009. 2_ Defendant appears generally herein and submit& to the jurisdiction of the Court. 3. In the event cr a default of any of the above listed Td WdbZ:90 60OZ 8Z 'adb 80L92VZLTL: 'ON XUJ SQ9d -16UO: WOdA wnuvtece?,no?rt? rax RDf [H an U5:Z1Pm N0031UQ4 r n conditions and poyrnents, plaintiff may, upon 10 days notice Ij enter judgment for the relief demanded in the Complaint filed in this matter plus judicial interest of 6% running from the date of filing. 4. Upon full and f4lal compliance with this stipulation, this F action shall be deemed fully settled, discontinued and/or J satisfied. 5_ In accordance wWi the terms of this agreement there appears h to be a related-.consent order for judgment held in escrow which will automatically extinguish upon compliance with the above, mentioned terms. Gordon acrid Weinberg, p _ c. Joel M Fli , Eaquiri Ed WdVZ:90 600E SE 'UdU 80Z9ZbE2-t2-: 'ON Xdd SQ3d INUD: WOdJ OF THE PR'^ T, '-" ? TNqy 2009 MAY 1 1 PM : 0 5 cumbl. • 2055670 L f {)4 j GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUI ' RE Identification No.: 41360 ??? JOEL M. FLINK, ESQUIRE v, Identification No.: 41200 220 St J` e 1001 E. Hector Street, ''f???'?? ,W Conshohocken, PA 19428 484/351-0500 ASSET ACCEPTANCE LLC AS ASSIGNEE COURT OF COMMON PLEAS OF CIRCUIT CITY/CHASE CUMBERLAND COUNTY VS. DOCKET NO. 09-2003 ASHLEY L GOODYEAR 75 E WILLOW ST CARLISLE PA 17013 and Metro Bank - 65 Ashland Avenue Carlisle, PA 17013 GARNISHEE WNW PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue writ of execution in the above matter, directed to the Sheriff of Cumberland County; (1) against ASHLEY L GOODYEAR defendant(s)and (2) against Metro Bank garnishee(s) WN (3) AMOUNT DUE $3,817.19 INTEREST from October 22, 2009 $220.41 COSTS Prothonotary fee Sheriff fee (4) Less: Post-Judgment Payments on Account ($1,000.00) TOTAL ?3?_,5d s l y U " ztt7 F v r s ?Sa D0 y 06 '?ue Co. FREDERIC I. WEII JOEL M. FLINK, Attorney for Pla f IRE fed' 3LIO7f WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 09-2003 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due ASSET ACCEPTANCE LLC AS ASSIGNEE OF CIRCUIT CITY/CHASE Plaintiff (s) From ASHLEY L GOODYEAR, 75 E WILLOW ST, CARLISLE, PA 17013 (1) You are directed to levy upon the property of the defendant (s)and to sell (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of METRO BANK, 65 ASHLAND AVENUE, CARLISLE, PA 17013 GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due$2,817.19 Interest FROM OCTOBER 22, 2009 - $220.41 Atty's Comm % Atty Paid $152.00 Plaintiff Paid Date: November 15, 2010 (Seal) L.L.$.50 Due Prothy $2.00 Other Costs David ell, o tary 07 By: Deputy REQUESTING PARTY: Name FREDERIC I. WEINBERG, ESQUIRE Address: GORDON & WEINBERG, P. C., 1001 E. HECTOR STREET, STE 220. CONSHOHOCKEN, PA 19428 Attorney for: Plaintiff Telephone: 484-351-0500 Supreme Court ID No. 41360 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson C o Sheriff `n3 0 Jody S Smith =rrrrt a r7l Chief Deputy Qr Richard W Stewart r- 2: w o S Solicitor OF; --E ?CD n =-n C)-n Z 3 C?o = Asset Acceptance LLC Case Number vs. Ashley L Goodyear 2009-2003 SHERIFF'S RETURN OF SERVICE 11/24/2010 08:47 AM - Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on November 24, 2010 at 0845 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Ashley L. Goodyear, in the hands, possession, or control of the within named garnishee, Metro Bank, 65 Ashland Avenue, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Jackie George, Customer Service Representative, personally three copies of interrogatories together with three true and attested copies of the writ of execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on November 30, 2010 to Ashley L. Goodyear at 75 E. Willow Street, Carlisle, PA 17013. SO ANSWERS, November 29, 2010 RON R ANDERSON, SHERIFF Ti o y Black, Deputy fci CountySWO Sherff. Tefeosoft in::. s WE 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 ASSET ACCEPTANCE LLC AS ASSIGNEE OF CIRCUIT CITY/CHASE VS. ASHLEY L GOODYEAR and Metro Bank Garnishee C"? -emu "y3 rn -n,m o CD rri - r-- - ;a L!) r 1 C am :;u ' 2055670 " f r = -r, C? "71 C? rr, ?? t rc .o COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. 09-2003 PRAECIPE TO DISSOLVE ATTACMCM TO THE PROTHONOTARY: Kindly dissolve the attachment of the defendant's bank account with Metro Bank, as Garnishee in the above entitled matter. GORDON & WEINBERG, P.C. BY: FREDERIC I. WE G, ESQUIRE JOEL M. FLINK, ESQUIRE Attorney for Plaintiff Poll Q ( I Y 2055670=; ff ? . GORDON & WEINBERG, P.C. , BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.. 41360 = -„ JOEL M. FLINK, ESQUIRE Identification No.: 4120 0' - 77 ?: 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 c3 ?. 484/351-0500 ASSET ACCEPTANCE LLC AS ASSIGNEE OF CIRCUIT CITY/CHASE VS. ASHLEY L GOODYEAR COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 09-2003 ORDER TO SATISFY JUDCbONT TO THE PROTHONOTARY: Kindly mark the judgment entered October 22, 2009 in the above-captioned matter satisfied upon payment of your costs only. GORDON & WEINBERG, P.C. BY: FREDERIC I. W NBERG, ESQUIRE JOEL M. KLIT-MR, ESQUIRE Attorney for Plaintiff P005 cno *