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HomeMy WebLinkAbout09-6498 2063408 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 ADVANTAGE ASSETS II, INC. AS ASSIGNEE OF CITIBANK (SOUTH DAKOTA N.A.) 600 Broadhollow Road Melville, NY 11747 VS. STEVEN L BLACK 138 OLDTOWN RD GARDNERS PA 17324-9084 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 09 - 10498 awil lem 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 8/7/09 in the amount of $6,098.69. 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 9/17/07. WHEREFORE, plaintiff claims of the defendant(s) the sum of $6,098.69 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDERIC I. W I ERG, ESQUIRE JOEL M. FLINK, ESQUIRE Attorney for Plaintiff P01A.DB 2063408 ADVANTAGE ASSETS II, INC. AS ASSIGNEE OF Citibank (South Dakota N.A.) STEVEN L BLACK 5121079721564505 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. LEONARD PRUZANSKY, CEO R STEVEN L BLACK 5121079721564505 State of Texas County of Harris ADVANTAGE ASSETS II, (South Dakota N.A.) AFFIDAVIT 2063408 INC. AS ASSIGNEE OF Citibank I, Leonard Pruzansky, being duly served sworn according to law, depose and say that: 1. I am the agent for the Plaintiff herein and I have custody and control of the files relating to this account; 2. Plaintiff's files are maintained in the usual and ordinary course of business; 3. This action is based on a claim for breach of contract and that damages are sought as a direct result of said breach; 4. There is now due and owing from defendant to plaintiff, the amount of $5,662.16 plus interest of $406.74 at the rate of 6% less credits in the amount of $.00 totaling $6,068.90 as of July 8, 2009. 5. If called upon, affiant can testify at trial as to the facts pertaining to this matter. The above facts are true and correct to the best of my knowledge, information and belief. LEONARD PRUZANSKY, EO Sworn to and Subscribed before me this 15- day of 7J ?y 2009 Notary Public ?`'p •`e4' LISA D HICKS *3 r NOTARY PUBLIC State o f Texas Comm. Exp. 03-09-2011 "CRY 1009 SELF 28 PH 12: 5 j qS. 5o P 0 ATTI co s9a e 0!.3113) Sheriffs Office of Cumberland County R Thomas Kline Sheriff Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor ~atit,+,t1t' of C~iuibrr/~rd ~, OF THE ~,~~~+lQTAFIY Zoo9 acr -2 AM lo= ~ $ ~~~r~sY~..~~~~ Advantage Assetts II, Inc. vs. Steven L. Black Case Number 2009-6498 SHERIFF'S RETURN OF SERVICE 09/30/2009 07:29 PM -Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on September 30, 2009 at 1929 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Steven L. Black, by making known unto himself personally, at 138 Old Town Road Gardners, Cumberland County, Pennsylvania 17324 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $37.90 October 01, 2009 SO ANSWERS, ~~4. R THOMAS KLINE, SHERIFF y s-~. Deputy Sheriff 2063408 CORDON & 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 ADVANTAGE ASSETS II, INC. AS ASSIGNEE OF CITIBANK (SOUTH DAKOTA N.A.) COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. DOCKET NO. 09-6498 STEVEN L BLACK ORDER TO SETTLE DISCONTINUE AND END TO THE PROTHONOTARY: Kindly mark the above-captioned matter settled, discontinued and ended upon payment of your costs only. CORDON & WEINBERG, P.C. ~ (~ BY: FREDERIC I. BERG, ESQUIRE JOEL M. FLINK, ESQUIRE Attorney for Plaintiff P003 iL~~-~~~~~::-.~ I I I Li!.. 20Q~ P~O~ -3 ~"~ 12~ 2;~ w<i i ~ r,.