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Home My WebLink About09-49562063005 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 ASSIGNEE OF CITIBANK 28405 Van Dyke Ave Warren MI 48093 VS. NANCY J BLANKENSHIP 10B RICHLAND LN APT T8 CAMP HILL PA 17011 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : Oq - 4g5 (o CtV t? IX° 1"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 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 July 13, 2009 in the amount of $12,617.36. 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 07/25/2005. WHEREFORE, plaintiff claims of the defendant(s) the sum of $12,617.36 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. r BY: FREDERIC I. WEIN RG, ESQUIRE JOEL M. FLI SQUIRE Attorney for Plaintiff P01A.DB VERIFICATION 1 hereby state that I am the agent for the plaintiff herein, and that the facts set forth in the atiac]nPd efljrl$„ji iarl-,irli is ynrmmnraiarl by rP.fP.rP.nr.P. in ihP-. fnrP-.Poinp Coi-nnlaint in Civil Action are true and con-ect to the best of my know) edge, infonnation 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 coiinsel, 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 inaking false statements. Name Deanna Jaso EXIBITH "A" STATE OF MICHIGAN ) ss COUNTY OF MACOMB ) ASSET ACCEPTANCE, LLC ) Plaintiff, ) vs ) AFFIDAVIT NANCY J BLANKENSHIP ) Defendant ) I, 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 $12454.58 representing the charged off amount and interest. That the said account originally with CITIBANK/, account number 5398430022763062, 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. this 23rd day of June, 2009. upervisor Subscribed and sworn to before e, a Notary Public for the State of Michigan, the :23rd of June, 2009 as certified by my hail as set forth immedi ly below. 28395564 1064 °°°D °° °°IN°°R° IIIII?IIU?INI?IN?l?llllll 0 0 2 8 3 9 5 5 6 4 ASSET ACCEPTANCE LLC P.O. Box 2036 Warren, MI 48090 ACCOUNT NUMBER CURRENT BALANCE 5398430022763062 $12454.58 STATEMENT DATE DUE DATE JUN 23 2009 DUE NANCY J BLANKENSHIP 10B RICHLAND LN APT T8 CAMP HILL,PA 17011 ACCOUNT NUMBER DATE OF LAST PAYMENT 5398430022763062 07/25/05 DATE REFERENCE NO ACCOUNT INFORMATION BALANCE DUE JUN 23 2009 28395564 BALANCE DUE $12454.58 ASSET ACCEPTANCE LLC, A LIMITED LIABILITY COMPANY ORGANIZED AND EXISTING UNDER THE LAWS OF THE STATE OF DELAWARE, ASSIGNEE OF 5398430022763062 P.O. Box 2036, Warren, MI 48090 DATE OF DELINQUENCY PURCHASED ON CHARGE OFF AMOUNT* INTEREST RATE 05/08/05 10/18/06 $6690.90 24.00% SERVICE ADDRESS (IF APPLICABLE) INTEREST DUE AS OF JUN 23 2009 $ 5763.68 *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 p? 28395564 1064 GORDON & WEINBERG 0 FILED-?)FF)"E OF THLE TAR 2009 JU . 22 Phi 1: ; 4 1 t"?11NV?`? lYr?111' 4 $18.50 Pb ATN GCS 8(oa31 e aa33 i I Sheriffs Office of Cumberland County R Thomas Kline Sheriff Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant OFFICE GF FNE,$NER1FF ?LL.? ?-f 11 iv?". OF THE Edward L Schorpp Solicitor Asset Acceptance LLC vs. Nancy J. Blankenship 2009 JUL 27 AM 9* 2 5 PE dl`dwl "V'' N 4 Case Number 2009-4956 SHERIFF'S RETURN OF SERVICE 07/23/2009 07:40 PM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on July 23, 2009 at 1940 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Nancy J. Blankenship, by making known unto herself personally, defendant at 10B Richland Lane Apt. T8 Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $41.50 July 24, 2009 SO ANSWER R THOMAS KLINE, SHERIFF 96Y heriff 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 2063005 ASSET ACCEPTANCE LLC ASSIGNEE OF CITIBANK vs. NANCY J BLANKENSHIP COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. 09-4956 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 $6,690.90 Less: Payments on Account ( $100.00) Total: $6,690.90 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 CITIBANK and that the last known address of defendant, NANCY J BLANKENSHIP, lOB RICHLAND LN APT T8, CAMP HILL PA 17011. 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 and day of 'E'~ 2009 Judgment is entered in favor of the plaintiff(s) an against defendant(s) by default for want of an answer and damages assessed at the sum of , $12,830.94 as per the above certification. Prothonotary GORDON & WE BY: FREDERIC JOEL M. Attorne, I. ~~EII~BERG, ESQUIRE LINK, ESQUIRE for Plaintiff FL _' ~,~ ,~ - ~, Th~r_ 9, ~': i~',~y 2~`~'S S~' -2 F~ I ~ 5:~ 1;;1' L ~Pu .: d ~,~ ~ ; ~'! i.,~ ~ r~, 1~ • 00 pp ATTY P.~ a3~1 ~ S IJrrken. ~ 2063005 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 CITIBANK vs. NANCY J BLANKENSHIP 10B RICHLAND LN APT T8 CAMP HILL PA 17011 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. 09-4956 NOTICE Pursuant to Pa.R.Civ.P. you are hereby notified you in the above procee~ ~L 1~ ~l L1 236 of the Supreme Court of Pennsylvania, that a judgment has been entered against Sing as indicated below. Judgment by Default $6,690.90 Money Judgment $ Judgment on Award of Arbitrators$ 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 P THONOTARY 9~a/oy