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HomeMy WebLinkAbout09-27891 a a s i s 2056723 THIS IS AN ARBITRATION MATTER. ASSESSMENT OF 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 ASSET ACCEPTANCE LLC ASSIGNEE OF HSBC BANK NEVADA, N.A. 28405 VAN DYKE AVENUE Warren MI 48093 VS. SUE S BROMWELL 626 DAVIS DR NEW CUMBERLND COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 09 _ d787 ONOTICE 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 PA 17070-1846 I 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 creditors 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 9, 2009 in the amount of $3,167.69. 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 12/13/07. WHEREFORE, plaintiff claims of the defendant(s) the sum of $3,167.69 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDERIC W NBERG, ESQUIRE JOEL M. FL M, ESQUIRE Attorney for Plaintiff P01A.DB b VERIFICATION I hereby state that I am 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 couulsel 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 p2,tCj q),J STATE OF MICHIGAN ) ss COUNTY OF MACOMB ) ASSET ACCEPTANCE, LLC Plaintiff, vs SUE S BROMWELL Defend THOMAS TRANCHIDA I, 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 $3145.73 representing the charged off amount and interest. That the said account originally with HSBC BANK NEVADA, N.AJ, account number 6011381003666664, 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 this day of January, 2 upervisor Subscribed and sworn to before me, a Notary Public for the State of Michigan, the 06th of January, 2009 as certified by y d as set forth immediately below. Not c ? . •ca?t dYM 38003264 1064 GORDON & WEINBERG 0 0 3 8 0 0 3 2 6 4 Aetal Aii.ap iPnia ... ASSET ACCEPTANCE LLC P.O. Box 2036 Warren, MI 48090 SUE S BROMWELL 626 DAVIS DR NEW CUMBERLND,PA 1 7070-1 846 ACCOUNT NUMBER CURRENT BALANCE 6011381003666664 $3145.73 STATEMENT DATE DUE DATE JAN 06 2009 DUE ACCOUNT NUMBER DATE OF LAST PAYMENT 6011381003666664 12/13/07 DATE REFERENCE NO ACCOUNT INFORMATION BALANCE DUE JAN 06 2009 38003264 BALANCE DUE $3145.73 ASSET ACCEPTANCE LLC, A LIMITED LIABILITY COMPANY ORGANIZED AND EXISTING UNDER THE LAWS OF THE STATE OF DELAWARE, ASSIGNEE OF 6011381003666664 P.O. Box 2036, Warren, MI 48090 DATE OF DELINQUENCY PURCHASED ON CHARGE OFF AMOUNT* INTEREST RATE 01/02/08 08/04/08 $3082.63 4.00% SERVICE ADDRESS (IF APPLICABLE) INTEREST DUE AS OF JAN 06 2009 $63.10 *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 &38003264 1064 GORDON & WEINBERG OF THE 200; 'q'tr -4 PH 2: 18 .*". 80 Po ATr%j Gcw me pj-*-oU f to 40 Sheriffs Office of Cumberland County R Thomas Kline ate cit c+uub, Edward L Schorpp Sheriff4titt l© Solicitor Ronny R Anderson Jody S Smith Chief Deputy f` Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 05/11/2009 05:53 PM - Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on April 11, 2009 at 1753 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Sue S. Bromwell, by making known unto John Sohn, husband of defendant, at 626 Davis Drive, New Cumberland, Cumberland County, Pennsylvania, 17070 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $43.30 SO ANSW S, May 12, 2009 2009-2789 Asset Acceptance v Sue S. Bramwell R THOMAS KLINE, SHERIFF Deput heriff; c? ?-,> C n ..o 3?7 I- _ r -{ M G.1 J lr? r ; r_ co 2056723 ' 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 ASSIGNEE OF HSBC BANK NEVADA, N.A. vs. SUE S BROMWELL COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. 09-2789 PRAECIPE FOR ENTRY OF JUDGMENT FOR WANT OF AN ANSWER, ASSIESSMENT OF DAMAGES, VERIFICATION OF ADDRESS AND NON-MILITARY SE7RVICE 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 $3,082.63 Less: Payments on Account ( $.00) Total: $3,082.63 Understanding the false statements made herein are 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 LLCASSIGNEE OF HSBC BANK NEVADA, N.A. and that the last known address of defendant, SUE S BROMWELL, 626 DAVIS DR, NEW CUMBERLND PA 17070-1846. 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 the 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 ~ day of ~ 2009 Judgment is entered in favor of the plaintiff(s) and against defendant(s) by default for want of an answer and damages assessed at the sum of , $3,323.27 as per the above certification. GORDON & WEINBERG~, .,P~~C . BY: ~ l FREDERIC I. W~dBERG, ESQUIRE JOEL M. FLINK, ESQUIRE Attorney for Plaintiff 2056723 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 ASSIGNEE OF HSBC BANK NEVADA, N.A. vs. SUE S BROMWELL TO/PARA COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. 09-2789 NOTICE OF INTENTION TO TAKE DEFAULT SUE S BROMWELL 626 DAMS DR NEW CUMBERLND PA 17070-1846 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. BY: ~ FREDERIC;' .`~ WEINBERG, ESQUIRE JOEL M.:' LINK, ESQUIRE P10D-2 FI; .. ._ - ~ ___.. r" r , . - ~ ~, nti, ~n~ ~7Ct .- ~_,~ ~: 'v E. ~,.. , . -'y' 1- Cr~'~ DEG/3 9l~°ti~r ~/e ~~ " CORDON & 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 2056723 ASSET ACCEPTANCE LLC ASSIGNEE OF HSBC BANK NEVADA, N.A. vs. SUE S BROMWELL 626 DAVIS DR NEW CUMBERLND PA 17070-1846 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. 09-2789 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 $3,082.63 ~[ Money Judgment $ ~L Judgment on Award of Arbitrators$ ~L Judgment on Verdict$ IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL ATTORNEYS: FREDERIC I. WEINBERG OR JOEL M. FLINK, ESQUIRES AT THIS TELEPHONE NUMBER: 484/351-0500 PROTHONOTARY l~/~s/~~