HomeMy WebLinkAbout09-6255IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ASSET ACCEPTANCE LLC
PO Box 2036
Warren, MI 48090
vs.
NETTIE J STOUT
6 LEWISBERRY RD LOT 25
NEW CUMBERLAND PA 17070
Defendant
CIVIL ACTION
NO:
CA - (PASS aw L l Tr?r? m
NOTICE TO DEFEND
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 to
Defend are served, by entering a written appearance personally or by an 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 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.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO
PROVIDE YOU WITH INFORMATION ON AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT REDUCED FEE OR NO FEE.
MIDPENN LEGAL SERVICES
401 EAST LOUTHER STREET
CARLISLE, PA 17013
717-243-9400
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ASSET ACCEPTANCE LLC
PO Box 2036 CIVIL ACTION
Warren, MI 48090
Plaintiff
vs.
NO: O9- 6 o2.5S Ccv mac .
NETTIE J STOUT
6 LEWISBERRY RD LOT 25
NEW CUMBERLAND PA 17070
Defendant
COMPLAINT
Plaintiff, ASSET ACCEPTANCE LLC , by and through its attorneys, Edwin A.
Abrahamsen & Associates, P.C., complains of the Defendant as follows:
1. Plaintiff, ASSET ACCEPTANCE LLC , (hereinafter "Plaintiff") is a Michigan
corporation with a principal place of business located at PO Box 2036 Warren, MI 48090.
2. The Defendant NETTIE J STOUT (hereinafter "Defendant") is an adult individual
residing at 6 LEWISBERRY RD LOT 25 NEW CUMBERLAND PA 17070.
3. At all relevant times herein, Plaintiff was engaged in the business of debt purchase
and collection.
4. Defendant applied for and received a credit card issued by BANK OF AMERICA
with the account number 4888936201231739.
5. The within account was sold by BANK OF AMERICA to ASSET
ACCEPTANCE, LLC for valuable consideration and all rights under said accounts were assigned
to ASSET ACCEPTANCE, LLC.
6. Use of the BANK OF AMERICA credit card was subject to the terms of the
Cardmember Agreement, a copy of which was sent to the Defendant along with the credit card.
7. Defendant used the BANK OF AMERICA credit card account
number4888936201231739, for purchases, cash advances and/or balance transfers.
8. The Defendant was mailed account statements relative to the Defendant's use of the
subject credit card.
9. The Defendant defaulted under the terms of the Agreement by failing and refusing
to make monthly payments on the account as they became due.
10. The account became delinquent July 13, 2007.
11. The principal amount was $11,336.76 at the time it was received by Plaintiff.
12. Pursuant to the account agreement, any unpaid balance accrues interest at the rate
of 24.
13. The total amount due and owing the Plaintiff including interest, is $15,406.82.
14. Pursuant to the terms of the Agreement, Defendant is liable to Plaintiff for court
costs and reasonable attorney's fees.
WHEREFORE, Plaintiff requests judgment in its favor and against Defendant in the
amount of $15,406.82 plus costs of suit and any other relief as the Court deems just and
appropriate.
Respectfully submitted,
Tdwin A. )Zbrahamse Assoc.
squire
Heather K. Wsquire
Michael F. Ra/N/?.86285/207805
Attorney I.D. 120 North Ke Scranton, PA-18504
mratchford@eaa-law.com
hwoodruff@eaa-law.com
VERIFICATION
I, Michael F. Ratchford, attorney for Plaintiff, ASSET ACCEPTANCE LLC, am fully
familiar with the facts set forth in the within Complaint and am authorized to make this
Verification on behalf of Plaintiff. I Verify that the facts set forth in the within allegations are
true and correct to the best of my knowledge, knowing that any false statements are punishable
by law pursuant to 18 C.S.A. 4904.
1 F. Ratchford,
0
FIt LEE-C?,- ;E
OF THE P^k'"'T, r,,?;()TARY
2009 S EP 17 Pll 12' i1 a
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So PO ATrY
C,(G?'F' I X53
i2T'?` iao(A6
ASSET ACCEPTANCE LLC
In the Court of Common Pleas of
Plaintiff CUMBERLAND County, Pennsylvania
Civil Division
VS.
: NO: 09-6255
NETTIE J STOUT
6 LEWISBERRY RD LOT 25 Praecipe to Withdraw Civil Complaint
NEW CUMBERLAND PA 17070
Defendant
To the Prothonotary of CUMBERLAND County Pennsylvania:
Please enter the above Praecipe to Withdraw the Civil Complaint.
Thank you,
Michael F. Ratchford,
Edwin A. Alrahmsm
# 86285
Sworn and
Associates, P.C.
before
O?P?\ O?`T? ?`c ??PG 201
G?'rl, oF,?'Q
SO?P??a R``SS\o
day of ? 20?
Loeh Venditti, Notary Public
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2069 S'1' 28 tail :1^ 17
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