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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 BANK OF AMERICA
28405 Van Dyke Ave
Warren MI 48093
VS.
JUDY A RINHART
110 LORI LN
BOILING SPRINGS PA 17007
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
DOCKET NO. : dq
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
merchandise 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 or Affidavit 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 November
23, 2009 in the amount of $12,193.17.
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.
46
7. Defendant's last payment on account was made on
1/25/06.
WHEREFORE, plaintiff claims of the defendant(s) the sum of
$12,193.17 plus applicable costs, interest and attorney's fees.
GORDON & WEINBERG, P.C.
BY:
FREDERIC WEI BERG, ESQUIRE
JOEL M. F IN ESQUIRE
Attorney for Plaintiff
P01A.DB
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, ilifonnation and belief and is based upon
infonnatian w1LCh 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 cowisel in making this verification. Till's verification is made subject to
18 Pa.C.S. §4904 which provides for certain penalties for making false statements.
Name) udy Melasi
EXHIBIT "A"
9GO???
STATE OF MICHIGAN
COUNTY OF MACOMB
ss
ASSET ACCEPTANCE, LLC )
Plaintiff, )
vs )
AFFIDAVIT
JUDY A RINHART )
Defendant, )
I, ]udy Melasi 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 $10719.24 representing the charged off
amount and interest.
That the said account originally with BANK OF AMERICA/, account number 4888920016059717, 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 17th day of September, 2009.
pervisc(
Subscribed and sworn to before me, a Not Public for the State of Michigan, the 17th of September, 2009 as
certified by(my haptra) set forth im?iec * to y? to
Notary
14&COMB
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ASSET ACCEPTANCE LLC
P.O. Box 2036
Warren, MI 48090
JUDY A RINHART
110 LORI LN
BOILING SPRINGS,PA 17007
ACCOUNT NUMBER CURRENT BALANCE
4888920016059717 $10719.24
STATEMENT DATE DUE DATE
SEP 17 2009 DUE
ACCOUNT NUMBER DATE OF LAST PAYMENT
4888920016059717 01/25/06
DATE REFERENCE NO ACCOUNT INFORMATION BALANCE DUE
SEP 17 2009 37449214 BALANCE DUE $10719.24
ASSET ACCEPTANCE LLC, A LIMITED
LIABILITY COMPANY ORGANIZED AND
EXISTING UNDER THE LAWS OF THE
STATE OF DELAWARE, ASSIGNEE OF
4888920016059717
P.O. Box 2036, Warren, MI 48090
DATE OF DELINQUENCY PURCHASED ON CHARGE OFF AMOUNT* INTEREST RATE
09/10/05 06/02/08 $8317.65 12.00%
SERVICE ADDRESS (IF APPLICABLE) INTEREST DUE AS OF SEP 17 2009
$2401.59
*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
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