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Home My WebLink About09-7139b V IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ASSET ACCEPTANCE LLC PO Box 2036 CIVIL ACTION Warren, MI 48090 Plaintiff VS. c1v-l NO: o7-713q RYAN GREENWAY 1107 SAFFRON DR MECHANICSBURG PA 17050 Defendant 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 I A. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ASSET ACCEPTANCE LLC PO Box 2036 CIVIL ACTION Warren, MI 48090 Plaintiff VS. RYAN GREENWAY 1107 SAFFRON DR MECHANICSBURG PA 17050 Defendant NO: 0 9- 7/ S9 c av ./ COMPLAINT Plaintiff, ASSET ACCEPTANCE LLC, by and through its attorneys, Edwin A. Abrahamsen & Associates, P.C., complains of the Defendant as follows: I. 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 RYAN GREENWAY (hereinafter "Defendant") is an adult individual residing at 1107 SAFFRON DR MECHANICSBURG PA 17050. 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 AMERICAN EXPRESS with the account number 371347175521000. 5. The within account was sold by AMERICAN EXPRESS to ASSET ACCEPTANCE, LLC for valuable consideration and all rights under said accounts were assigned to ASSET ACCEPTANCE, LLC.(See, Affidavit attached hereto as Exhibit "A".) 6. Use of the AMERICAN EXPRESS 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 AMERICAN EXPRESS credit card account number371347175521000, 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.(See, Account Statement attached hereto as Exhibit "B".) 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 June 25, 2006. 11. The principal amount was $14,216.10 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 $23,311.28. 14. Pursuant to the terms of the Agreement, Defendant is liable to Plaintiff for court costs. WHEREFORE, Plaintiff requests judgment in its favor and against Defendant in the amount of $23,311.28 plus costs of suit and any other relief as the Court deems just and appropriate. Respectfully Edwin A. Abrah aigsen & Assoc. Michael F. rd, Esquire Heather K. to!druff, Esquire Attorney I.D. Nos.: 86285/207805 120 North Keyser Ave. 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. 6 OCT 19 2 l0 ck 2# .13 .may s Sheriffs Office of Cumberland County R Thomas Kline Sheriff Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant OF 12FzM1Xor?r 2049 OCT 26 AM 9: 15 Edward L Schorpp Solicitor Asset Acceptance LLC Case Number vs. Ryan R. Greenway 2009-7139 SHERIFF'S RETURN OF SERVICE 10/21/2009 02:40 PM - Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on October 21, 2009 at 1435 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 Ryan R. Greenway personally, at 1107 Saffron Drive, Mechanicsburg, Cumberland County, Pennsylvania, 17050 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $37.44 SO ANSWERS, October 22, 2009 R THOMAS KLINE, SHERIFF DeFSuW Sheri f f -- (David (D. Bue(C Prothonotary XirkS. Sohonage, ESQ Soficitor :,f Ci; 7750 Wfnee X Simpson ?11 15` Deputy Prothonotary o?? Irene E. W orrow Td Deputy Prothonotary Office of the Prothonotary Cumder(and County, (Pennsy(vania CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 30T' 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) 240-6195 • Fax (717) 240-6573