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HomeMy WebLinkAbout09-66642065178 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 ASSET ACCEPTANCE LLC ASSIGNEE OF LITTLE SWITZERLAND/Worl 28405 VAN DYKE AVENUE WARREN, MI 48093 Vs. RYAN R GREENWAY 1107 SAFFRON DR MECHANICSBURG PA 17050 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : OQ - (v lp&4 C ?v Ic°rwt 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 t ' 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 21, 2009 in the amount of $1,220.47. 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 4/27/06. WHEREFORE, plaintiff claims of the defendant(s) the sum of $1,220.47 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. Z;?? - BY: FREDERIC INBERG, ESQUIRE JOEL M. FLINK, ESQUIRE Attorney for Plaintiff P01A.DB VERIFICATION I hereby state that I ain 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 malting false statements. Name ?HOMAJ TPANCHIDA /74 STATE OF MICHIGAN ) ss COUNTY OF MACOMB ) ASSET ACCEPTANCE, LLC Plaintiff, vs RYAN R GREENWAY Defendant, 1, THOMAS TRANCHICA AFFIDAVIT 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 $1207.85 representing the charged off amount and interest. That the said account originally with /LITTLE SWITZERLAND / World Financial Network Na, account number 005856373600057959, has been purchased by ASSET ACCEPTANCE, LLC, who now owns said account and has all rights connected therewith including the right to institute this action. Dated this 13th day of July, 200 Supe visor Subscribed and sworn to before me, a Notary Public for the State of Michigan, the 13th of July, 2009 as certified by my hand as set forth immediately b ow. Notary Public 7:.1hA1AJjP2 I~S? CHA Putfic - P irh igan co :1-, C'a" my E:a:o x vut i 3, 213 c ?-L Q'-"'j of 38140423 Hill ME 1064 GORDON & WEINBERG 0 0 3 8 1 4 0 4 2 3 Ai's al 1.<ti D.lpn C&' ... ASSET ACCEPTANCE LLC P.O. Box 2036 Warren, MI 48090 RYAN R GREENWAY 1107 SAFFRON DR MECHANICSBURG,PA 17050 ACCOUNT NUMBER CURRENT BALANCE 005856373600057959 $1207.85 STATEMENT DATE DUE DATE JUL 13 2009 DUE ACCOUNT NUMBER DATE OF LAST PAYMENT 005856373600057959 04/27/06 DATE REFERENCE NO ACCOUNT INFORMATION BALANCE DUE JUL 13 2009 38140423 BALANCE DUE $1207.85 ASSET ACCEPTANCE LLC, A LIMITED LIABILITY COMPANY ORGANIZED AND EXISTING UNDER THE LAWS OF THE STATE OF DELAWARE, ASSIGNEE OF 005856373600057959 P.O. Box 2036, Warren, MI 48090 DATE OF DELINQUENCY PURCHASED ON CHARGE OFF AMOUNT* INTEREST RATE 07/04/06 08/27/08 $959.89 10.00% SERVICE ADDRESS (IF APPLICABLE) INTEREST DUE AS OF JUL 13 2009 $247.96 *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 38140423 1064 GORDON & WEINBERG D CF I HPIOTARY 2009 OC i -6 PI; 1: 51 CUM' _. ?UNiY Phi NSN'Offi NIt *'78.50 P0, A?Tq cict 934 (01 97t 0231530 Sheriffs Office of Cumberland County R Thomas Kline FfLED-u?? ?c-,E Sheriff F !HIT r ma`''`r ?Qya w ???y,,?lr ql 4.air,Grrft?,? , Ronny R Anderson Chief Deputy 2009 OCT 15 All, 12 Jody S Smith Civil Process Sergeant Orr .F «-+rF _Edward L Schorpp Solicitor Asset Acceptance LLC Case Number vs. Ryan R. Greenway 2009-6664 SHERIFF'S RETURN OF SERVICE 10/09/2009 06:40 PM - Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on October 9 2009 at 1840 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Ryan R. Greenway, by making known unto Nancy Greenway, mother of defendant at 1107 Saffron Drive Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $37.00 October 13, 2009 SO ANSWERS, pe!? 49enr-0 R THOMAS KLINE, SHERIFF Deput Sheriff (David D. (Buell Prothonotary XirkS. Sohonage, ESQ Solicitor Rsnee X Simpson 15` Deputy Prothonotary Irene E. Morrow 2nd Deputy Prothonotary Office of the Prothonotary Cumberland County, (Tennsylvania A01_fw&"_v__CIVILTERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 30TH DAY OF OCTOBER, 2012, AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE -THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R.C.P. 230.2. BY THE COURT, DAVID D. BUELL PROTHONOTARY (717) 240-6573