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HomeMy WebLinkAbout04-2336BURTON NElL & ASSOCIATES, P.C. By: Burton Neil, Esquire Identification No. 11348 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 Attorney for Plaintiff WORLDWIDE ASSET PURCHASING, LLC 9911 Covington Cross Drive, Suite 107 Las Vegas, NV 89144 IN THE COURT OF COMMON PLEAS Plaintiff MICHAEL SURMA 150A Rodgers Drive New Kensington PA 15068--000 Defendant CUMBERLAND COUNTY, PENNSYLVANIA CIV1L ACTION - LAW COMPLAINT 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 (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 claim set forth against you. You are warned that if you fail to do so, the case may proceed without you and a judgment 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. 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. LAWYER REFERENCE AND INFORMATION SERVICE Cumberland County Bar Assoc. 32 South Bedford Street Carlisle, PA 17013 Telephone No. 717-249-3166 or 800-990-9108 56863 BURTON NEIL & ASSOCIATES, P.C. By: Burton Nell, Esquire Identification No. 11348 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 Attorney for Plaintiff WORLDWIDE ASSET PURCHASING, LLC 9911 Covington Cross Drive, Suite 107 Las Vegas, NV 89144 Plaintiff MICHAEL SURMA 150A Rodgers Drive, New Kensington, PA Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 1. The plaintiffis WORLDWIDE ASSET PURCHASING, LLC, a business corporation, with place of business located at 9911 Covington Cross Drive, Suite 107, Las Vegas, NV 89144. 2. The defendant is Michael Surma, who resides at 150A Rodgers Drive, New Kensington, Cumberland County, Pennsylvania. 3. At the defendant's request, Nextcard Inc. issued the defendant a credit card bearing account number 4254983001023730 for defendant's use in making charge purchases subject to the terms and conditions governing the use of the credit card. Attached hereto, made a part hereof and marked Exhibit A is a tree and correct copy of the terms and conditions. 4. The defendant accepted the credit card and the terms and conditions governing its use for the purchase of goods, merchandise and services and/or for cash advances from vendors who accepted Nextcard lnc.'s credit card. In using the credit card, the defendant agreed to comply with the terms and conditions governing its use which included the obligation to pay Nextcard Inc. for all charges made in full upon receipt of the statemem or in installments subject to monthly finance charges. 5. The defendant utilized the credit card by making/obtaining purchases of goods, merchandise and services and/or cash advances from vendors who accepted the credit card. Monthly statements were sent to the defendant which detailed the charges made to the account including finance charges, late and/or, over limit charges. The balance due for the charges made by the defendant including any finance charges, late or over limit charges is $38,540.83. : CIVIL ACTION - LAW Complaint 6. Defendant did not pay the balance due in full upon receipt of the billing statements and failed to make the required minimum monthly payment set forth in the billing statement. As such, defendant is in default of the terms and conditions governing the use of the credit card. 7. Plaintiffpurchased the defendant's account from Nextcard Inc. and is now the holder and owner of the account. 8. Although demand has been made by plaintiffupon defendant to pay the sum of $38,540.83, the defendant failed and refused to pay all or any part thereof. 9. Plaintiffaileges it is entitled to recovery of attorneys fees from defendant pursuant to the terms and conditions governing the account. Plaintiff seeks recovery of attorneys fees in the sum of $7,708.16. Wherefore, plaintiff demands judgment against the defendant in the sum of $38,540.83, attorneys fees in the sum of $7,708.16 and the costs of this action. BURTON N~I~I~ & ASSOCIATES, P.C. By: ~, Esqu'~'~'J Attorney for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. NextCard Account Agreement Please print ~ copy of Ihi~ Account Agreement for your records, Account Agreement and Disclosure Statement Genera[ This NexLCard® Account Agreement and Disclosure Statement C"Agreement~) contains the terms and conditions which govern you r NextCard Visa® (or HasterCard®) Account ("Account") which is issued by NextBank, N .A., Phoenix, AZ. This Agreement includes this document and the terms provided in the qupplementa~ Disclosure enclosed with this document and the card carrier accompanying your Card, and any amendments thereto. The Supplemental Disclosure includes your Account Annual Percentage Rates. Please read this Agreement carefully, including the section on Finance Charges, and keep it for your records. In this Agreement, tho word "Card" means the credit card(s) issued to yell. [he word.~ ~you," "your" ~nd ~yours" rorer Lo each person who has boon approved for this Account. I-he wu[ds 'we,' "oul'" 0r "Ll~" re/er tn NextlSank, N.A., or it~ a~sig~qees, tn addition, tho words "Tra~action Data' refer to the date the goo~s or servJcgg were purchaged or the date the Cash Adven~ was made. Ihe words ~Posting Da~e" refer [o the date that the charge was debited and/or credited to your Account. I~y applying for this Account, you agree to the terms and conditions provided in this Agreement, [nduding the Supplemental Disclosure. You agree to sign your Card as soon as you receive it. Liability You become bound by :hfs Agreement when you use your Card or Accounf.. You are also bour~d by this Agreement for the use of your Card or Account number by ~y person who ha~ been given authority by you to use your Card or Accoun~ mumber. [f you authorize another person to LiSa ymJr C~rd~ slt~h mJthority will exLend until ~uch time ~s we have re~rieved ~hc Car~ er yau haw received ~he Ca~ batE. Using Your Card and Account You may usa your Card to purchase goods or services w~erever your Card is honored, You may obtain Cash Advances on your Card from financial institutions and automated teller machines that accept your Card. tn addition, you may obtain Cash Advances by using the Convenience Checks that we may provide to you from time to time. These checks may no~ be used to make payments on this or any other account with us. You may use your Account for Balance Transfers, by which you pay off other credit card outstanding balances. Balance Transfers may include Initial and promotionar offers. we have ne responsibility for any refusal to honor your Card or the Convenience Checks we provide, nor for the r~LenLJun o[your Card by any financial institution or merchant, Promise to Pay You promise to pay the total amount of the Purchases, Cash Advances and Balance Transfers made with your Card or Account. 'You aJso promise to pay any Finan=e Charges or other charges as described herein; and any costs incurred by us in enforcing LhJs Agreement, including reasonable attorneys' fees and court costs. "Attorneys' fees" includes the cost to us of the services of our in-house counsel, Personal Zdentification Number After your Account is opened, we may issue you a Personal identification Number O"PiN") which you may use with your Card to obtain Cash Advances an your Account at any automated teJler machine in any system or network cf which we are a member, of' to make purchases at any designated point of sale macE[ne. You may use your Card and PiN at on automated teller machrne to obtain Cash Advances of up to $300 put day, up to your available Credit LilTllt fei' Ca'-h Advance-.. There will be no charge Ior t:he · Issuance of e PiN. (Other buxrks' automated teller machines may have lower Cash Advance limi~ or may asses~ surcharges.) Statements . You can access your Accoun. t information and $i:atements online, in addition, we will send or deliver to you a Statement at the end of each billing period [intervals of approximately one month celled "Billing Cycfes"} if there rs a debit or credit baJance on your Account of $[ or more, or a balance on which a Finance Charge has been assessed. Upon your request or approval, we may deliver your statement electronically. Payment Arf payments must be made in U.S. Dollar-- and delivered, or malred to us at the address .~hown an your SLuternent. Payolas]ts by check i~ust bo drawn on a U.$, bank. YnLJ mu~t pay at roast the Hinim[mm Payment Due showrl Dr1 y~ur Statement by the Payment Duc Datc- approximately 25 days a~er the Statement Cl&sing Date - t~ avord delinquency. if your.payment is more than ~hc Hinimum Payment Due, [t will be treated as e 5ingte payment and none of it will be a~p[ied to furore N[nimum Payment~ Duc. We may apply payments to amounts owing ~n your Ac~un~ in our sole discretion end are ~o~ required to do so [na manner that reduces the Finance Charges you must pay. Paymen~ may also be made via the NextCard online bill payment system, For details on using ~he No,Card online bill payment feature, please go t? Hy. Nex[~ard.com. For information regarding your Minimum Payment each month, see the Supplemental D[scJosure to l;hi~ Account Agreement. credit Limit Your Credit Limit ic ~hown on the card carrier with which your NextCard Vise or Ma~tel'Ca~'d was delivered and on your Statement. Your Statement wirl also show the amount of credit ava]labia to you ('Credi~ Available"). You agree that your Purchases, Cash Advents and Balance Transfe~ together with all charges and fees, will not exceed your Credit Limit From time to [Jme~ we may change your Credit ~mit based upon information wa obtain from you or from your credit records. [fyour Credit Limit changes we will notl~ you. Under ce~aJn circumstances we may allow you to exceed y~r Credit Limit; however, you agree to, p~y at least the Minimum Paymen~ Due by the next Payment Due Date. The total amount of Cash Advance, (including Dra~s, if avaJJable, withdrawals from ATMs, origination I'rum Um Card itself, arid c~si~-Iike tran~actinn.% including but nat limited to wire transters~ money ortlers~ Io~t~ tlc~ets, and ~slno gaming chl~) you can rer~ive a~ ~ny time is shown on your ~onthty ~t~temen~s and }s designated as your '~otal Credit Unit f~r Cash Advances". You agree not to De, it your unpaid Cash Advance balance ~o exceed ~his I~mit. [f you currently exceed, or once you reach this rimit, you will not be eligrbJe For additional Cash Advances until your unpaid Cash Advance balance is below this limit. At this time, you may access the amount of[he difference between your unpaid Cash Advance balance and your Cash Advance Credit Limit. You agree that we may change your Cash Advance Credit Limit at any time, and' we wit[ noti~ you of any such change. We have the righ~ to limit authorizations to make Purchases or obtain Cash Advances if we consider it necessary to verify payments received on your Account. Finance Charges The types of Finance Charges that may be assessed on your Account are as ~ollows: Periodic Finance Charges; Transaction Finance Chargeg; Annua~ Membership Fee Finance Charges; and Accmmt Openin~ Fee Finance Charges. Your total Finance Charge each Bilring Cycle is the sum of each type of Finance Charges. We calculate Periodic Finance Charges separately for Purchases, Cash Advances and ~a[ance Transfers. To determine the Periodic Finance Charge we apply the Daily Periodic Re[es for Purchases~ Cash Advances and BalanCe Transfers to the daily balance of= Purchases, Cash Advances end Balance TransFers. The sum ef these daily calculations for each day in the Billing cyfre rs the total Periodic Finance Charge for the Billing Cycle. The Deity Periodic Rates For your Account are the corresponding Annual Percentage Rates that currently may apply divided by Tu d~Lermi~e your' daily balance of Pur'cha~s, C~sh Advance~ and Balance T~r~[~ ~t~ with the ~utA~nding hel~nc~ ~ [hR b~gJnnJng ~f ~h~ d~y including ~ny P~riodJc Finance Chai'ges ca~culated on ~lqe previous day's balance, add any new Purchases, Cash Advances and Balance 'l'rensfem or other debits for ~he day and then subtract any payments or credi~ appfied to Purchese~, Cash Advances and 5elancc Tr~n~crs that Ray. This gives us the separate daily balances for Purchases, Cash Advances and Balance Transfers. Purchases, Cash Advances and Balance Transfers are included in your daily balances as of the later of the t. ransac~ion date or the beginning of the Billing Cycle in which they are posted to your Account. Periodic Finance Charges for Purchases, Cash Advances ~nd Balance Transfers for a day are added to the daily balances of Purchases~ Cash Advances and Balanc~ Transfe~ at thc end of the day and inctudod in the beginning batances for the next day. Other Cherge~, Annual Hembership Fee Finance Charges nnd Account Opening FCC Finance Charges are added to the dally balance of Purclqnses when posted. Tfansdc[Jon Finance Charges are added t.o the daily balanc: ul' Cash Advunce.~ when pa,~ted. Far ~.ach Cash Advance transactions InclLJdlng but not limited to each Convenience Check presented to us for payment and each Cash Advance obtained through a financial institution or ATH, we may assess a Transaction Finance Charge equal to 3% of the amount al= [:he advance, but not less than $5.00. A Transaction1 Finance Charge is included in I:he caiculatien of the Annual Percentage Rate shown on your Statement; therefore~ for any Bilffng Cyfe in which you have drawn ~ Cash Advance or used a C~nvenrence Check, the Annual Percentage Rate that will appear on your Statemeni: may be higher than the Annual Percentage I~ate degcribed In the disclosures provided to you. NextCard oilers optional Rewards programs and an optiooat Picture Card Program. Refer to the Suppremental Disclosure for data[Es regarding the Annual Membership Fee for these programs. tn any Billing Cycle in which theEe is a Finance Charge, the minimum Finance Charge will be SO.50. Grace PeriOd Purchases, Cash Advances and Balance Transfers accrue Periodic Finance Charges from Lhe date they are iHcluded ill your Daily Ba]arlCe until paid. However, Periodic Finance Charges are not a.~.~e~ed ir, a Billing Cycle on Purchases if you paid in full the Ncw Balance~ if any, shown on your previous sLaLemer~t Ioy the Payment Due Date shown on that statement or if that New Balance was a zero or credit balance. Other Charges Your Account also has the following other fees and charges ("Other Charges"); There may be an Annual Fee on your Account. Refer to the Supplemental Disclosure for detai~s regarding the Annual Fee. Late Fee: You agree that a late charge of $~'9.C)0 will be due and payable and added to the balance on your Account If you' do not make a paym~n~ oil your Account equal to or greater than the Minimum Payment on or before the Pnym~_nt Due Date. OYedlmit Fee: You ngrcc that in addition tn payDtfq ~,l"ly eXc~-g~ upon demand or ~S nthe~ise provided herein, ~n overlimit charge Of ~2~.H0 will be due and payable if you exceed your Total Credi~ Limit. Returned Payment Fee: You agree to pay ~29.00 for each check, draft or automatic payment ("Payment Order") issued by you as a payment on your Account which fails to clear and is returned unsatisfied by your financial institution. We may post this charge to your Account even if: we re-present your Paymen~ Order, and even if the Payment Order is paid upon re-presentment. Authorized Users Y~u may request ~nd, at our discretion, we may provide an addit'i~naJ Card or1 this Account for use by a~ individual you authorize ("Authorized U~er"). You may ala~ n~ake a single request ~r a new Card ("Replacement Ca~~} tar yon ar an Authorize0 User on this Account. In addition, we may p~riodically send yo~ sLmb~titufe Ca~(~) for your use, Cards iooued ~n any of these ways are not stmbjec~ to se~ice charges. However, if you have p~viously requested a single Replacement Ca~ we will cha~e u Card Repla~ment Fee of $~5 for any additional Card(s) you re~uest. YOU may el~o request rush delivery of any new or Replacement Ca~(s) foran additional $[9 for overnight deliver. Default and Zmmedlate Payment You will be in default and we can require immediate payment of all amounts you owe if: you provide inaccurate or incomplete information when you apply for your Account or therea~er> you fail to make the minimum payment on your Account by the Payment; Due Date; your New ~alance amount exceeds your Credit Limit; your outstanding Cash Advai~ce ~,alance exceeds your- Cash Advance Credit Limit, i~'appllcable; you fail to pay your other debts er obligations; you fail to abide by any term or condition of this Agreement; we be[ieve~ tn good faith, that you may not be able to meet the obligations of this Agreement; or, upon your death, You also agree to notify us promptly upon any change in name, address or employer. Termination We may suspend or terminate your right~ to obtain credit al any time for any reason. Your obJigation$ under this Agreement will continue even after your ri~]ht~ to obtain credit hove been suspended or terminated. N et Secured Credit Your Account is not secured credit. We have no security interest in any transaction you make with this Card, regardless el' any ether agreement you may have with us. Foreign Currencies Depending on whether your Card is a Visa or r, lasLerCard, if you charge a transaction in a foreign currency, the transactioD will be converted into a U.S. doIlar amount by Vise or MasterCard based on their operating procedures and regulations. Generally, currency cm~versioes are made using either a government-mandated rate ar wholesale market rate in effect one day prior' to the Processing Date, increased by one percent. The ~ffect on Lhu Transaction Date or the Posting Date. Unauthorized Use You must contact us immediately at 1-800-556-LOST if your Card is lost or stolen or if you suspect unauthorized use of your Account. We may investigate any cases of unauthorized use of your Card or Account. If you report or we suspect unauthorized use of your Card or Account, we may suspend your credit privileges until we resolve the problem to'our satisfaction or issue you a new Card, You agree to sign each Card upon receipt. You agree to safeguard the Card, your PIN, which provides access to automated toiler machines, and Password, which provides [ntemet acce~s~ fram theft. You ~gree Eo keep your PIN and Password confidential and separate from your Ca~. Tf ~n unauthorized Lrar]sactJon occurs oil ti~e lntemet or your Account number is obtained over the mnternet and subsequentfy used rot u nautliorized tr'ansections, you will ~lot be liable for that transaction. Updating Your Account/nformation From time to time, we may obtain updated credit information from a credit reporting agency. You are hereby notified that a negative credit report reflecting on your credit record may be submitted to a credit reporting agency if you fail to fulfill the terms of your credit obrlgatJon. Jif you believe we hove reported inaccurate information about you to a credit bureau, please notffy us at the address appearing on your statement. We may sham information regarding our experiences or transactions with you or ~/eur at.'t;ounL with u[hers, includfng merchal~tS and companies affiliated with us by common c~ntroJ or owne~hip (our r'AffjJJates"). We may a]so share additional infurmaCion regaling yot~ or your account (such as intnrmntion from credit reporting agencle~ with our Affflia~es. You ~n request that we do no~ furnish to our Affiliates informaUon that does not ~alate to our experiences or transactions w~h you or your accoun~ by calling us at Z-888-974-z265. You can also request that we do not share information about you for ma rket]ng purposes with unaffiliated part]es by contact]Kg ut at 1-888-974-2265. Amendrnent~ and Assignments After we provide you any notice required hy law, we may change any par[ of this Agreement arid add, remove or' alter requ[r'eme~ts, if A CHANGE ~5 MADE TO TH~5 AGReeMENT, YOU AGREE THAT, FROM THE bFF~C[':VE DATE OF THE CHANGE, THE NEW TERMS, iNCLUDiNG ANY NEW OR [NCR~SED Finance ~harges, W:LL APPLY BOTH TO ANY NEW CHARGES TO YOUR ACCOUNT AND TO YOUR ENTRE OUTSTANDING BA~NCE, INCLUDING :TEM$ POSTED TO YOUR ACCOUNT BEFORE TH~ EFFEC~VE DATE OF CHANGE. We also reserve the right to review your creditwo~hiness f~m time to time, including your pe~ormance with ether credtt~, and to change the terms of your Account based on that ~v[ew. You agree that we may assign your Account and any amoun~ that Y°u owe us to a~other enti~ or pe~en at any time, with or without notice to you. Governing Law Thl9 A0reement J~ gnverned by the Jaws of Lhe State of Arizund and by a~ly applicable federal law~- no matter whom you live, You agree that ~ny liUgaL[or~ br~ucjh[ by you ~udir~St us regardJllg this ACCOUIqt or this Agreement shmtJ be brought in a ~tate or federRI court located tn the SLate of Arize.a. [[ any part of this Agreement is found ~o be invalid, tile rest remains effective. Generai [~tformation No delay or failure in enforcing our rights under this Agreement will prejudice any of our rights hereunder. Tf you defaurt, unFess prohibited by applicable law, we may require you to pay ali collection costs, including reasonable attorneys' fees and court costs. Our failure to exercise any of our rights when you default or exercise other of our rights does ~ot mean that we are unable to exercise those rights upon later default or otherwise. Payments Marked "Paid Zn Full" We m,~y accept letler~, checks or other type.~ of payments showing "payrr~ent in (ell" ur usi~3g other language to indicate satisfa~len of your dcbt, wrtnout waiving any of our rights to re~ive Full payrnanL under LII[~ Agre~ma~]L SuLisf~'LJun uf yuur dabL [or J~s~ than the tLdl amoLmt requires a wriffen agreemRntz ~igned by one of ~tJr atJth~rized omployees. YOUR BZLLZNG RZGPITS; KEEP THZS NOT~ZCE FOR FUTURE USE This notice contains important information about your right5 and our responsibilities under the Fair Credit Billing Act. Notify Us in Cases of Billing Errors or Questions about Your Statement. [f you think your Statement i~ wrong, or you I~eed more informaLion about a transaction u~, y~ur ,cJtatement~ write us at: I',O, Box 62648 Phoenix, AZ 850B2-gg62 Write us as soon as pos~Jbla. We must hear rre[Tz you no tater than 60 days after we sent you the first Statement on which the error or prDblem appeared. You can ~elep~one us~ but doing so will not presage your rights. In your letter, give us the following information: Your name and account Thc dot}ar .~mount of thc suspcctcd error, Describe the error and explain, if you can, why you berieve there is an error. you need more information, describe the item you are not sure about. ~f you have authorized us to pay your credit card bill automatically from your savings or checking account, you can stop the payment on any amount you think is wrong. To stop the payment your letter must reach us three business days before the automatic payment is scheduled to occur. Your Rights and Our Responsibilities after We Receive Your Written Notice. We midst acJ<nowledge your Jotter within 313 day.% unle.~s we have corrected the error by then. Within 90 days, we must either caf'root the erl-o~- Ol- explain why we believe your Stattmen'c wa3 corrcct, Aft. er We receive your lottoG we cannot try to collect any amount you question, or repair you as derfnquent. We can continue to bfrl you for the amount you questiont including Finance Charges, and we can apply any unpaid amount against your Credit Limit. You do not have to pay any questioned amount while we are investigating, but you are stfll obligated to pay the pa~.s of your Statement that are not in question. If we find that we made a mistake an your S~Latement, you will not have to pay any Finance Charges related to the questioned amount, If we did not make a mistake, you may have to pay Finance Cha~rges~ and yah will have to make LJp any missed payments on the questioned amount. In either case, we will send you a statement of the amount you owe ~md ~he date that it is due. If you fall to pay the amount that we think you owe, we may report you as c~elfnquent. However, if our explanation does not satisfy you dud you wrile lu u~ wilhJ~l te[~ d,~ys telling us that'you ~till refuse to pay, we must tell anyone we report you to that you have a question about your Statement. And, we must tell you the name of anyone we reported you ~o, We must tell anyone we report you to that the matter has been settled between us when it finally is, If we do not follow these rules, we cannot collect the first $50 of the questioned amount, even Jf your Statement was correct. Special Rule for Credit Card Purchases. If: you have a problem with the qual[ty of property or services that you purchased witl; your Card, and you have tried in go~d farLh to carrect the problem with the merchant, you may have the ri0ht not to pay the I'em~l~J~g amount due o~ the property or services. There are two limniLaLi~n5 u~ thi~ right: You must have made the purchase in your home state or, if not within your home state~ within 100 miles of your current mailing address; and The purchase price must have been more than $50. These limitations de not apply if we own or operate the merchant, or if we mailed you the advertisement for the property or service~;. Verification k~me of authorized representative) osi for WORLDWIDE ASSET PURCHASING,LLC, the within Plaintiff, and makes this statement on its behalf as to the truthfulness of the facts set forth in the foregoing Complaint subject to the penalties of 18 Pa. C.S. Section 4904, relating to unswom falsification to authorities. Date: Michael Surma 4254983001023730 BURTON NElL & ASSOCIATES, P.C. BY: Burton Neil, Esquire Identification No. 11348 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 ATTORNEY FOR: Plaintiff WORLDWIDE ASSET PURCHASING, LLC Plaintiff VS. MICHAEL SURMA Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-2336 Civil : CIVIL ACTION - LAW _PRAECIPE TO DISCONTIN~JE TO THE PROTHONOTARY: Kindly discontinue the above-captioned action without prej~adice. BURTON NETS& A, SSOCIATES, P.C. · ........... Burton-- - iNei~, Esquire Attorney roi' Plaintiff The law firm of Burton Nell & Associates is a debt collector. 56863