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Home My WebLink About09-2788r a s 00 _- x 2055727 THIS IS AN ARBITRATION MATTER. DAMAGES HEARING REQUIRED. GORDO & WEINBERG, P.C. BY: XEDERIC 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 CITIBANK 28405 Van Dyke Avenue Warren MI 48093 VS. JUAN A ACOSTA 4420 Gettysburg Rd. Apt 7 CAMP HILL PA 17011-6614 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. a188 O-AjVilTCf`Mh 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 r 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 16, 2009 in the amount of $776.47. 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. i r 7. Defendant's last payment on account was made on 1/18/2008. WHEREFORE, plaintiff claims of the defendant(s) the sum of $776.47 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDERIC I. WEI ERG, ESQUIRE JOEL M. FL K, SQUIRE Attorney fo laintiff P01A.DB EXHIBIT "A?? ?o5E2-)? STATE OF MICHIGAN COUNTY OF MACOMB ss ASSET ACCEPTANCE, LLC Plaintiff, vs ) JUAN A ACOSTA AFFIDAVIT Defendant, ) PAMELA McCULLOUGN I, ) being first duly sworn deposes and states: am the Supervisor of ASSET existing Thatder the laws of the State Delaware anACCEPTANCE, ng business at P.O. BOX L2041,tWARppaarrny organized and REN, MI 48090. That there is justly due and owing on the account, the sum of $769.53 representing the charged off amount and interest. That the said account originally with CITIBANK/, account number 61080868, 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. Dated 21nd day of Subscribed and sworn to before me, a Notary Public for the State of Michigan, the 22nd of December, 2008 as certified by my hand as set forth immediately below. Notary Public .• C t'; iDF'Ry.C0D ilotory Puh}ic - 1.1 Ca igon i::•; Commi?s:on Frp<<c., . ? 21:12 r,; tir•^, in ih° County cf 26379180 1064 GORDON & WEINBERG muss 0 0 2 6 3 7 9 1 8 0 r ASSET ACCEPTANCE LLC P.O. Box 2036 _ Warren, MI 48090 JUAN A ACOSTA 4420 GE7TYSBURG RD APT 7 CAMP HILL,PA 17011-6614 ACCOUNT NUMBER 61080868 ACCOUNT NUMBER 61080868 STATEMENT DATE DEC 22 2008 e CURRENT BALANCE $769.53 DUE DATE DUE DATE OF LAST PAYMENT 01/18/08 DATE REFERENCE NO ACCOUNT INFORMATION BALANCE DUE DEC 22 2008 26379180 BALANCE DUE $769.53 ASSET ACCEPTANCE LLC, A LIMITED LIABILITY COMPANY ORGANIZED AND EXISTING UNDER THE LAWS OF THE STATE OF DELAWARE, ASSIGNEE OF 61080868 P.O. Box 2036, Warren, MI 48090 DATE OF DELINQUENCY Ftkt] CHARGE OFF AMOUNT* INTEREST RATE I O/11/00 736.54 4.00% SERVICE ADDRESS (IF APPLICABLE) INTEREST DUE AS OF DEC 22 2008 $32.99 *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 26379180 1064 GORDON & WEINBERG ` 0 PD, OF T[- u 2 C09 ?iE- -4 Ff" 1 2: 17 11.60 PO ATW e ouq&39 Sheriffs Office of Cumberland County R Thomas Kline HIV of CINN41 Edward L Schorpp Sheriff va?? ?r'?6 Solicitor Ronny R Anderson Jody S Smith Chief Deputy FrIc Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 05/08/2009 04:15 PM - Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on May 8, 2009 at 1615 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Juan A. Acosta by making known unto Juan A. Acosta personally, at 4420 Gettysburg Road, Apt. 7, Camp Hill, Cumberland County, Pennsylvania, 17011 its contents and at the same time handing to him the said true and correct copy of the same. SHERIFF COST: $40.60 May 11, 2009 SO ANSWERS, R THOMAS KLINE, SHERIFF p ySer f 2009-2788 Asset Acceptance v Juan Acosta r' .. , :' Un f •• 2055727 GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 81894 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 ASSET ACCEPTANCE LLC AS ASSIGNEE OF CITIBANK vs. JUAN A ACOSTA COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. 09-2788 PRAECIPE FOR ENTRY OF JUDGMENT FOR WANT OF AN ANSWER, ASSESSMENT OF DAMAGES, VERIFICATION OF ADDRESS AND NON-MIL:LTARY SERVICE TO THE PROTHONOTARY: Enter judgment for want of an answer for plaintiff and against defendant(s) above named only and assess damages certified to be calculable as a sum certain from the complaint, as follows: Principal $736.54 Less: Payments on Account ( $.00) Total: $736.54 Understanding the false statements made herein area subject to penalty under 18 Pa.C.S.A. §4904, Unsworn Falsification to Authorities, I verify that: 1. The last known addresses of the parties are: ASSET ACCEPTANCE LLCAS ASSIGNEE OF CITIBANK and that the 1<~st known address of defendant, JUAN A ACOSTA, 4420 Gettysburg Rd. Apt 7, CAMP HILL PA 17011-6614. 2. The annexed notice(s) of intention to file this praecipe was (were) mailed to all parties, defendant and to their record attorneys, if any, after default occurred, and at least ten days prior to the date of filing of this praecipe. 3. The said defendant (s) is (are) not in tY:~e military service of the United States or otherwise within the coverage of the Soldiers and Sailors Civil Relief Act and is (are) over 18 years of age. AND NOW, this is entered in favor default for want of $903.08 as per the ~~ day of ~ ~ _, 2009 Judgment of the plaintiff(s) and against def.=_ndant(s) by an answer and damages assessed at t:he sum of , above certification. CORDON & WEINBERG, P.C. BY: FREDERIC I. E P~ERG, ESQUIRE JOEL M . FLI t, .;QUIRE Attorney for ai.ntiff k 2055727 CORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FUNK, ESQUIRE Identification No.: 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 ASSET ACCEPTANCE LLC AS ASSIGNEE OF CITIBANK vs. JUAN A ACOSTA TO/PARA COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET N0. 09-2788 NOTICE OF INTENTION TO TAKE DEFAULT JUAN A ACOSTA 4420 Gettysburg Rd. Apt 7 CAMP HILL PA 17011-6614 DATE OF NOTICE/FECHA DEL AVISO: June 2, 2009 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY AN 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. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 CORDON & WEINBERG, P.C. g BY: i/ r FREDERI ~I`. EINBERG, ESQUIRE JOEL M` FUNK, ESQUIRE P10D-2 F~~ ~ ! - ,;;~ ~r-,.7 i ^f L ~ ~, ~~l ~i~~ ov ~~ /~P~ ~o~~~i~ ~~~~ ~~ ,~, 2055727 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 CITIBANK vs. JUAN A ACOSTA 4420 Gettysburg Rd. Apt 7 CAMP HILL PA 17011-6614 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. 09-2788 NOTICE Pursuant to Pa.R.Civ.P. 236 of the Supreme Court of Pennsylvania, you are hereby notified that a judgment has been entered against you in the above proceeding as indicated below. L~ Judgment by Default $736. °>4 LL Money Judgment $ ~L Judgment on Award of Arbitrators$ ~L Judgment on Verdict$ IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEA>E CALL ATTORNEYS: FREDERIC I. WEINBERG OR JOEL M. FLINK, ESQUIRES AT THIS TELEPHONE NUMBER: 484/351-0500 PROTHONOTARY /~~~~