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Home My WebLink About09-2750 m 2058541 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 ADVANTAGE ASSETS, II, INC. AS ASSIGNEE OF SEARS GOLD MASTERCARD 7322 Southwest Freeway, S Houston, TX 77074 VS. DOROTHY A BEAM 92 2ND ST APT 1 ENOLA PA 17025-3201 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : -.Z70 0,,;, Lc- Q m 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 P 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 original creditor under the terms of which the original creditor agreed to extend to defendant(s)the use of original creditor'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 original creditor 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 original creditor. 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 March 13, 2009 in the amount of $2,845.71. 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. r 7. Defendant's last payment on account was made on 7/20/07. WHEREFORE, plaintiff claims of the defendant(s) the sum of $2,845.71 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. 41- BY: FREDERIC I. ERG, ESQUIRE JOEL M. FLINK, ESQUIRE Attorney for Plaintiff P01A.DB 2058541 ADVANTAGE ASSETS, II, INC. AS ASSIGNEE OF SEARS GOLD MASTERCARD DOROTHY A BEAM 5121075030868058 VERIFICATION or I hereby state that I am the agent fo facts set forth in the attached Affidavit in the foregoing Complaint in Civil Action my knowledge, information and belief and plaintiff has furnished to counsel. The 1 counsel and not of plaintiff. To the exten are that of counsel, plaintiff has relied verification. This verification is made provides for certain penalties for making the plaintiff herein, and that the which is incorporated by reference are true and correct to the best of is based upon information which anguage in the Complaint is that of t that the contents of the Complaint upon counsel in making this subject to 18 Pa.C.S. §4904 which false statements. LEONARD PRUZANSKY, CEO r 2058541 ADVANTAGE ASSETS, II, INC. AS ASSIGNEE OF SEARS GOLD MASTERCARD DOROTHY A BEAM 5121075030868058 State of Texas County of Harris AFFIDAVIT I, Leonard Pruzansky, being duly served sworn according to law, depose and say that: 1. I am the agent for the Plaintiff herein and I have custody and control of the files relating to this account 2. Plaintiff's files are maintained in the usual and ordinary course of business; 3. This action is based on a claim for breach of contract and that damages are sought as a direct result of said breach; 4. There is now due and owing from defendant to plaintiff, the amount of $2,835.46 plus interest of $.47 at the rate of 6W less credits in the amount of $.00 totaling $2,835.93 as of February 25, 2009. 5. 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. LEONARD PRUZANSKY, CEO Sworn to and Subscribed before me this o ?O day of S??r- 2009 Notary Public f'??"''??• LISA D HICKS NOTARY PUBLIC State of Texas ?!!ia•'r Comm. Exp. 03-05-2011 QS FILE r r THr F" TARY 2C'i9 P Y - I Fill C= a O CluiJ. gle. 96-?? A eKd 7s9a? Sheriffs Office of Cumberland County R Thomas Kline 19 of clurib", Sheriff COO, Edward L Schorpp Solicitor Ronny R Anderson Chie Deputy Jody S Smith f 'CE E "?`'R'Fr Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 05/05/2009 07:30 PM - Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on May 5, 2009 at 1930 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Dorothy A. Beam, by making known unto Melissa Beam, daughter of defendant at 92 2nd Street, Apt. 1 West Fairview, Cumberland County, Pennsylvania 17025 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $41.50 May 07, 2009 2009-2750 Advantage Assets II VS Dorothy A. Beam SO ANSWERS, R THOMAS KLINE, SHERIFF By ? Deputy Sh re iff cm r -17 -1 C 2058541 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 ADVANTAGE ASSETS, II, INC. AS COURT OF COMMON PLEAS ASSIGNEE OF SEARS GOLD CUMBERLAND COUNTY MASTERCARD DOCKET NO. : 09-2750 VS. - DOROTHY A BEAM ORDER TO SETTLE DISCONTINUE AND END TO THE PROTHONOTARY: Kindly mark the above-captioned matter settled, discontinued and ended upon payment of your costs only. GORDON & WEINBERG, P.C. BY FREDERI I. WE IN ERG, ESQUIRE JOEL M. F NK, SQUIRE Attorney laintiff '- P003 EI; 'r llis'I 4