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Home My WebLink About09-6064 2065658 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 ASSET ACCEPTANCE LLC ASSIGNEE OF AMEX 28405 VAN DYKE AVENUE WARREN, MI 48093 Vs. MATTIE GOODMAN 1150 CAMP HILLBYP CAMP HILL PA 17011 ASSESSMENT OF COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : bq- I,oo(oy?v?lT?.t 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 August 24, 2009 in the amount of $8,025.38. 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 9/25/05. WHEREFORE, plaintiff claims of the defendant (s) the sum of $8,025.38 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDERIC INBERG, ESQUIRE JOEL M. FLINK, ESQUIRE Attorney for Plaintiff P01A.DB VERIFICATION I hereby state that I am the agent for the plaintiff herein, and that the facts set forth in the attached Affidavit wluch 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 ftimished 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. Name PAMELA WCULLOUGH STATE OF MICHIGAN COUNTY OF MACOMB ASSET ACCEPTANCE, LLC ss Plaintiff, ) vs ) AFFIDAVIT MATTIE GOODMAN ) Defendant, ) 1, PAMELA MGCLIL I Ot IrN 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 $8025.38 representing the charged off amount and interest. That the said account originally with AMERICAN EXPRESS/, account number 371711856722007, has been purchased by ASSET ACCEPTANCE, LLC, who now owns said account and has all rights connected therewith iijQuding the right to institute this action. Dated Ais 17jh d4y of July, Supervisor Subscribed and sworn to before me, a Notary Public for the State of Michigan, the 17th of July, 2009 as certified by my hand as set forth immediately below. Notary Public 39254591 1064 GORDON & WEINBERG 11111 5 4 5 9 4 Aa'ai? A4 C8440nci' . ASSET ACCEPTANCE LLC P.O. Box 2036 Warren, MI 48090 MATFIE GOODMAN 1150 CAMP HILL BYP CAMP HILL,PA 17011 ACCOUNT NUMBER CURRENT BALANCE 371711856722007 $8025.38 STATEMENT DATE DUE DATE JUL 17 2009 DUE ACCOUNT NUMBER DATE OF LAST PAYMENT 371711856722007 09/25/05 DATE REFERENCE NO ACCOUNT INFORMATION BALANCE DUE JUL 17 2009 39254591 BALANCE DUE $8025.38 ASSET ACCEPTANCE LLC, A LIMITED LIABILITY COMPANY ORGANIZED AND EXISTING UNDER THE LAWS OF THE STATE OF DELAWARE, ASSIGNEE OF 371711856722007 P.O. Box 2036, Warren, MI 48090 DATE OF DELINQUENCY PURCHASED ON CHARGE OFF AMOUNT* INTEREST RATE 05/24/05 04/16/09 $8025.38 0.00% SERVICE ADDRESS (IF APPLICABLE) INTEREST DUE AS OF JUL 17 2009 $0.00 *For purposes of this Statement only, Charge Off Amount reflects credits for payments received by Asset, if any. ** Not previously sent to consumer. THIS COMMUNICATION IS FROM A DEBT COLLECTOR 14?? 39254591 1064 GORDON & WEINBERG 0 OF THE PRA ;,, TARY 11 2009 SEP -4 PM 2: 02 `tv.r?- N Y 41&50 PD AT" CO 8q a!)% wr* aZD2a7 R Thomas Kline Sh Sheriffs Office of Cumberland County O ?pt?txtit' at ?:iI A nhrrl,??fG u ? enff ?r+9 JL.? c ?~ c Ronny R Anderson ?U? I pt°l Chief Deputy r _ Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor Asset Acceptance LLC Case Number vs. Mattie Goodman 2009-6064 SHERIFF'S RETURN OF SERVICE 09/14/2009 R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Mattie Goodman, but was unable to locate her in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant Mattie Goodman. The Penn Harris Convention Center management advised Deputy's the defendant was a long term guest 2 years ago, and they do not have a current forwarding address for her. An exact address is not available. 1-1 SHERIFF COST: $33.00 September 14, 2009