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Home My WebLink About09-7794a THIS IS AN ASSESSMENT 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 2070253 ARBITRATION MATTER. OF DAMAGES HEARING REQUIRED. UNIFUND CORPORATION 10625 Techwoods Circle Cincinnati, OH 45242 VS. WILLIAM J RIORDAN 251 REESER RD CAMP HILL PA 17011 NOTICE COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : Qq - ?7qq Cy-1 Ter-a1 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, 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 FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 COMPLAINT IN CIVIL-ACTION 1. Plaintiff, Unifund Corporation is a debt buyer and successor in interest to the original creditor, CITIBANK SOUTH DAKOTA NA. 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 October 22, 2009 in the amount of $13,333.94. 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 7/25/07. WHEREFORE, plaintiff claims of the defendant(s) the sum of $13,333.94 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDERIC I. WE BERG, ESQUIRE JOEL M. FLINK, ESQUIRE Attorney for Plaintiff P01h 2070253 U3632644 Unifund Corporation WILLIAM J RIORDAN 5491139051095124 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. - (Y,,- k CHRIS BRYAN Dated: October 7, 2009 EXHIBIT "A" 7 1933 WILLIAM J RIORDAN 5491139051095124 2070253 U3632644 Unifund Corporation AFFTnANITT I, Chris Bryan, 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. I have personal knowledge of the facts and circumstances in connection with this case; 3. Plaintiff's files are maintained in the usual and ordinary course of business; 4. This action is based on a claim for breach of contract and that damages are sought as a direct result of said breach; 5. There is now due and owing from defendant to plaintiff, the amount of $8,916.30 plus interest of $4,237.32 at the rate of 27.34% less credits in the amount of $.00 totaling $13,153.62 as of October 7, 2009. 6. 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. Chris Bryan, AFFIA Sworn to and Subscribed before me this 7th day of October, 2009 Notary Public ?O' ( ,* NOf81Y PIIb?IC ? ;?,, o a My ummi m BOU 05142011 FILL* tt f 2G 9t Y;p - t: $18.50 PD ATrq LK,t? Qlolo48 a?* a?aa?a R Thomas Kline Sheriff SHERIFF'S OFFICE OF CUMBERLAND COUNTY FIB ~-, :=,~„- „- - Ronny R Anderson Chief Deputy Jody S Smith Civi! Process Sergeant Edward L Schorpp Solicitor Unifund Corporation vs. William J. Riordan c;, ,.,;. ~,,. -. _ v; - :.. ! r Case Number 2009-7794 SHERIFF'S RETURN OF SERVICE 11!30/2009 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: William J. Riordan, but was unable to locate him in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant William J. Riordan. Greg Riordan advised Deputies William J. Riordan passed away in 1988. ~ / ~ SHERIFF COST: $60.00 SO AN _ ~ , _ November 30, 2009 ~~ ' - T,. OMAS KLINE, SHERIFF ,' i` David (D. Bueff Prothonotary xirkS. Sohonage, E,SQ, Solicitor Rsnee X Simpson 15` (Deputy Prothonotary Irene E. Morrow 2nd Deputy Prothonotary Office of the Trothonotary Cumberland County, (Pennsylvania • CIVIL TERM 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) 240-6195 • Fax (717) 240-6573