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Home My WebLink About09-44862062064 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 COLORADO CAPITAL INVESTMENTS, INC. AS ASSIGNEE OF US BANK NATIONAL ASSOCIATION, ND 409 NORTH MAIN WEATHERFORD, TX 76086 VS. CARLOS N RAMOS II 365 CRISWELL DR BOILING SPRGS PA 17007-9695 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : Oq- L44SCo Ctvit <'e%? 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 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 June 24, 2009 in the amount of $2,634.66. 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 12/20/2007. WHEREFORE, plaintiff claims of the defendant(s) the sum of $2,634.66 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDERIC WEI BERG, ESQUIRE JOEL M. FL , ESQUIRE Attorney for Plaintiff P01A.DB 2062064 493678 COLORADO CAPITAL INVESTMENTS, INC. AS ASSIGNEE OF US BANK NATIONAL ASSOCIATION, ND CARLOS N RAMOS II 4006148565016881 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 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. NAM =EEN ""Ay P 41* as LEW, 2309 2062064 493678 COLORADO CAPITAL INVESTMENTS, INC. AS ASSIGNEE OF US BANK NATIONAL ASSOCIATION, ND CARLOS N RAMOS II 4006148565016881 AFFIDAVIT I, \E`C? WK , 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. I have personal knowledge of the facts and circumstances in connection with this case; 3. Plaintiff's files are maintained in the usual and ordinary course of business; 4. This action is based on a claim for breach of contract and that damages are sought as a direct result of said breach; 5. There is now due and owing from defendant to plaintiff, the amount of $2,419.49 plus interest of $206.42 at the rate of 6% less credits in the amount of $.00 totaling $2,625.91 as of June 2, 2009. 6. 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. AFFI T Sworn to and Subscribed before me this day of 2009 ec,- Notary Public ;o,??er rye KATE BEESON Notary Public, State of Texas X. My Commission Expires December 18, 2012 f 0 OF THE' ???AFY 2009 JUL -b FM 2, 5 #18.50 po ATW +rit $5I (ol M* aa1 4 32. Sheriffs Office of Cumberland County R Thomas Kline Sheri i jF {' THtom Y (1 i A'-CY Ronny R Anderson °?tlr Qt,r,Pfir4 Chief Deputy Cs 2009 A,UG 12 t i !' Jody S Smith - Civil Process Sergeant OFFICE F THE SHERIFF Edward L Schorpp _• Solicitor Colorado Capital Investment, Inc. vs. I Case Number Carlos N. Ramos, II 2009-4486 SHERIFF'S RETURN OF SERVICE 08/05/2009 09:10 PM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on August 5, 2009 at 2110 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Carlos N. Ramos ll, by making known unto melanie Ramos, wife of defendant at 365 Criswell Drive Boiling Springs, Cumberland County, Pennsylvania 17007 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $38.80 August 06, 2009 SO ANSWERS, 4wft ?R THOMAS KLINE, SHERIFF eputy Sheriff 1 2062064 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 COLORADO CAPITAL INVESTMENTS, INC. AS ASSIGNEE OF US BANK NATIONAL ASSOCIATION, ND VS. CARLOS N RAMOS II COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 09-4486 PRAECIPE FOR ENTRY OF JUDGMENT FOR WANT OF AN ANSWER, ASSESSMENT OF DAMAGES VERIFICATION OF ADDRESS AND NON-MILITARY 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 $2,634.66 Less: Payments on Account ( $.00) Total: $2,634.66 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: COLORADO CAPITAL INVESTMENTS,INC. AS ASSIGNEE OF US BANK NATIONAL ASSOCIATION, ND and that the last known address of defendant, CARLOS N RAMOS II, 365 CRISWELL DR, BOILING SPRGS PA 17007-9695. 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. f ? !' w ' 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 ANd - day of 'S-?o`E. , 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 , $2,634.66 as per the above rtification L Pr honotary GORDON & WEINB RG, P.C. BY: FREDERIC I. I$ZINBERG, ESQUIRE. JOEL M. K, ESQUIRE Attorney for Plaintiff It 2062064 GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBER,G, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 41200 0(11 E 1 1 1 `or Street, Ste 220 Conshohocken, PA 19428 484%351-0500 COLORADO CAPITAL INVESTMENTS, INC AS ASSIGNEE OF US BAI4K NATIONAL ASSOCIATION, ND COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. CARLOS N RAMOS II DOCKET N0. : 09-4486 NOTICE OF INTENTION TO TAKE DEFAULT TO;' PARA CARLOS N RAMOS If 365 CRISWELL DR BOILING SPRGS PA 17007-9695 DATE OF NOTICE/FECHA DEL AVISO: August eft, 2009 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY AN ATTORNEY AND FILE IN WPITING WITH THE; COURT.- TOUR DEFENSES OR IDBJECTIOI4S TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU AT 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, LA11YER AT ONCE, IF YOU DO NOT HAVE A LAWrEP., GO TO OR TELEPHONE THE OFFIC SET FORTH BELOW. THIS OFFICE' CA.N PROVIDE YOU hdITH INFORI7ATIpN ABOUT HIFII49 A LAhll"EF. 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 BAP ASSOCIATION 32 S. BEDFORD STREET CAP.LIFLE, PA 17013 (717) 249-3166 GORDON & WEINBERG, P.C. BY: FREDERIC/? , 6ATtINBEP,G, ESQUIRE JOEL M. FLINI;, ESQUIRE b FILED-? ,ter O THE ,'ft?AAY 2OU9 SE-P 23 P11 it : 2 8 41Coo PQ A7t7 av-t Q151o5 e d3sq 4O Nohea. ?a?1a?' 1 4 2062064 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 COLORADO CAPITAL INVESTMENTS, INC. AS ASSIGNEE OF US BANK NATIONAL ASSOCIATION, ND VS. CARLOS N RAMOS II 365 CRISWELL DR BOILING SPRGS PA 17007-9695 09-4486 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. 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. LXL Judgment by Default $2,634.66 Money Judgment $ Judgment on Award of Arbitrators$ Ll Judgment on verdict$ IF YOU HAVE ANY QUESTIONS CONCERNING THIS ATTORNEYS: FREDERIC I. WEINBERG OR JOEL M. TELEPHONE NUMBER: 484/351-0500 NOTICE, PLEASE CALL FLINK, ESQUIRES AT THIS P OTHONOTARY "I-U FOR