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Home My WebLink About09-62522065593 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 Atlantic Credit & Finance Inc. COURT OF COMMON PLEAS Assignee from HSBC CUMBERLAND COUNTY 2727 Franklin Road Roanoke, VA 24014 e'lly, Vs . DOCKET NO . : Qq - 601 A ( TL°?P`M1. ANTHONY L COONS 549 RIDGE RD SHIPPENSBURG PA 17257-9764 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 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 17, 2009 in the amount of $2,949.26. 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 03/16/2008. WHEREFORE, plaintiff claims of the defendant(s) the sum of $2,949.26 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDERIC I. WEI RG, ESQUIRE JOEL M. FLI 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 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. EXIBITH "A" ATLANTIC CREDIT & FINANCE, INC. V. ANTHONY L COONS AFFIDAVIT OF DEBT AND VERIFIED BILL OF PARTICULARS The undersigned being first duly sworn according to law, deposes and says that she is familiar with the policies and practices, as well as the books and records of the Plaintiff with respect to the matters stated herein, and based on information and belief states as follows: 1. Plaintiffs principal business consists of purchasing charged off receivables. 2. The Defendant defaulted on HSBC Account No. 5480420018292506. Said Account was charged off on 7/31/2008 and subsequently sold to Atlantic Credit & Finance, Inc with a balance of $2949.26. 3. Plaintiff purchased or was otherwise assigned this charged off account along with other debts. As a result of the foregoing sale and assignment, the Plaintiff succeeded to all right, title and interest in the charged off account and it now owns the account. 4. Plaintiff conducted a due diligence investigation to determine, among other things, the accuracy of the account information provided to ascertain whether the statute of limitations was a bar to demand or institution of suit. Further, Plaintiff and/or its predecessor entered into a contract where the predecessor made representations and warranties that 1) it had clear right, title and interest in the account; 2) the account was free and clear of all liens and encumbrances; and 3) it had the power, authority, and full right to sell and convey its interest in the account. 5. According to Plaintiff's records, the last payment date was3/16/2008 in the amount of $ 75.00. After application of all payments, credits, adjustments, and lawful offsets, if any, there is still a balance due and owing on this indebtedness of $2,949.26. 6. The internal Account Statement of Plaintiff is attached hereto as Exhibit A and displays the account information that was provided to Plaintiff at the time of purchase and assignment. The foregoing is true and correct to the best of my knowledge and belief. 14'tz" 6?1 By: 11"Ak /dbecca B Authorized Representative Subscribed and sworn before me, July 21, 2009. Notary Pu 'c: C Gray THIS COMMUNICATION IS FROM A DEBT COLLECTOR Gordon & Weinberg, P.C.: CGAFF- 3646945 - 0001714 0 ti CREDT c RNANCF p 4TEf PO Box 13386 • Roanoke, VA 24033 Account Statement Original Creditor Account Number: 5480420018292506 ANTHONY L COONS 549 RIDGE RD SHIPPENSBURG, PA 17257-9764 Original Creditor: HSBC Original Creditor Last Pay Date: 3/16/2008 Original Creditor Last Payment Amount: $ 75.00 Original Creditor Charge Off Date: 7/31/2008 ACF ID Number: 3646945 SSN: XXX-XX-4532 Purchased Balance $2,949.26 ACF Payment Activity $ .00 ACF Payment Date: Current Balance $2,949.26 CONFIDENTIAL PROPERTY OF ATLAN'T'IC CREDIT & FINANCE, INC. Q ??iJ I ICJ i? OF THE: 2069 StiP 17 PM 12: 4 !# *'78.5o PAD AT W c?? ?4q 9 a3o?oQa Sheriffs Office of Cumberland County R Thomas Kline Sheriff ??tr ci?t+nbrrt Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant OFFICE „,E ?E S-ERI€F Edward L Schorpp Solicitor FILED-D CF OF T!-' _.' F! !T-t" ;TORY 2009 SEP 22 AH 10: 4;0 V'vP? _, ..1fivTY I L '; 7 I Atlantic Credit & Finance Inc. vs. Anthony L. Coons Case Number 2009-6252 SHERIFF'S RETURN OF SERVICE 09/21/2009 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: Anthony L. Coons, but was unable to locate him in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant Anthony L. Coons. The resident of 549 Ridge Road Shippensburg, PA 17257 is Anthony L. Coons Sr., he advised Deputy's that his son Anthony L. Coons is the defendant for this complaint and he resides in Harrisburg. An exact address is not available. SHERIFF COST: $51.00 September 21, 2009 SO ANSWERS, R THOMAS KLINE, SHERIFF SS: a MOR S1w SS= 2065593 17 11 r0-07FICE r zr ,, [1 T ff R (y afi Pi J GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQ F,j F,rj 1. ;. Identification No.: 41360 O JOEL M. FLINK, ESQUIRE Identification No.: 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 Atlantic Credit & Finance Inc Assignee from HSBC VS. ANTHONY L COONS 68 AIRPORT RD SHIPPENSBURG PA 17257 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 09-6252 PRAECIPE TO REINSTATE CCIGM& T TO THE PROTHONOTARY: Kindly reinstate the Plaintiffs' Complaint in Civil Action in the above-captioned matter for an additional thirty (30) days. GORDON & WEINBERG, P.C. 13U 310 o7/S5/ BY: FREDERIC I. W BERG, ESQUIRE JOEL M. FLI , ESQUIRE Attorney for Plaintiff(s) I SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor Atlantic Credit & Finance Inc. vs. Anthony L. Coons Case Number 2009-6252 SHERIFF'S RETURN OF SERVICE 11/29/2010 03:40 PM - Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on November 29, 2010 at 1540 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: thony L. Coons now known as Anthony L. Coons Sr., by making known unto Wendy Coons, Wife of defer dant at 68 Airport Road, Shippensburg, Cumberland County, Pennsylvania 17257 its contents and at the same time handing to her personally the said true and correct copy of the same. TIM B , DEPUTY SHERIFF COST: $46.00 SO ANSWERS, November 30, 2010 RON R ANDERSON, SHERIFF FILED-OFFICE OF THE' PROTHONO BAR) 20 40 DEC -7 AM 8: 2 C C CU PENNSYLVANIA, (c) CountySuite Sheriff. Teleosoft nc Y 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 Atlantic Credit & Finance Inc. Assignee from HSBC VS. ANTHONY L COONS ? C C ? 2065593 rn :. rn ;VC:) ?a 6-6 C-a r- ;;0 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 09-6252 PRRECIPE FOR ENTRY OF JQDGMNT FOR VANT OF AN ANSWER, ASSESSNMT OF DANNGES, 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 $2,949.26 Less: Payments on Account ( $.00) Total: $2,949.26 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: Atlantic Credit & Finance Inc.Assignee from HSBC and that the last known address of defendant, ANTHONY L COONS, 68 AIRPORT RD, SHIPPENSBURG PA 17257. 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 .? 4 the Soldiers and Sailors Civil Relief Act and is (are) over 18 arATIL160 5 years of age. 14 J a.Ab pass sr ?Nrsl?'c{ ,N?U;? led V AND NOW, this day of ? Or\ • , 2014 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 , $2,949.26 as per the above cQrtificationj Prot FREDERIC JOEL M. Attorney W NBERG, ESQUIRE N , ESQUIRE r Plaintiff 2065593 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 Atlantic Credit & Finance Inc. Assignee from HSBC VS. ANTHONY L COONS 68 AIRPORT RD SHIPPENSBURG PA 17257 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 09-6252 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. /X1 Judgment by Default $2,949.26 L_L Money Judgment $ L_L Judgment on Award of Arbitrators$ " Judgment on Verdict$ IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, ATTORNEYS: FREDERIC I. WEINBERG OR JOEL M. FLINK, TELEPHONE NUMBER: 484/351-0500 )-13-// PLEASE CALL ESQUIRES AT THIS 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 2065593 Atlantic Credit & Finance Inc. Assignee from HSBC Vs. ANTHONY L COONS TO/PARA COURT OF C014MON PLEAS CUMBERLAND COUNTY DOCKET NO. : 09-6252 NOTICE OF INTENTION TO TAKE DEFAULT ANTHONY L COONS 68 AIRPORT RD SHIPPENSBURG PA 17257 DATE OF NOTICE/FECHA DEL AVISO: December 21, 2010 n4PORTANT 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 FFF OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 GORDON & WEINBERG, P.C. BY: FREDERIC7 r' INBERG, ESQUIRE JOEL M//LINK, P10D-2 ESQUIRE