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Home My WebLink About10-0195Goldman & Warshaw, P.C. BY: Barry A. Rosen, Esquire PA Identification No: 42951 GOLDMAN & WARSHAW, P.C. 312 W. Broad Street Quakertown, PA 18951 267-373-9730 Counsel for Plaintiff H0076089 THIS IS AN ARBITRATION MATTER. ASSESSMENT OF DAMAGES HEARING WORLDWIDE ASSET PURCHASING II, LLC as successor in interest to DIRECT MERCHANTS BANK, NA 101 CONVENTION CNTR, #850 LAS VEGAS, NV 89101 Vs. GEORGE MIHALOPOULOS 119 CAROL LANE Enola PA 17025 REQU I RFUI . S-- q s L7Q ° ?- dT..;+ ?' t17 cra ?? , ? C rn iv c.? ? COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 10 - lq5 0'1"'WTarm 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 *q&'00 PO ATE P-0 1100'7 V* -?sS840 COMPLAINT IN CIVIL-ACTION 1. Plaintiff, WORLDWIDE ASSET PURCHASING II, LLC as successor in interest to Direct Merchants Creidt Card Bank, N.A., is a limited liability company or other business entity or bank with an address as stated in the caption above. 2. Defendant GEORGE MIHALOPOULOS is an adult individual residing at the above captioned address. 3. At all times relevant hereto, the defendant was the holder of a credit card, which at the request of the defendant was issued to the defendant by the plaintiff's predecessor under the terms of which the plaintiff agreed to extend to defendant the use of plaintiff's predecessor's credit facilities. 4. Defendant accepted and used the aforesaid credit card so issued and by so doing agreed to perform the terms and conditions prescribed by the plaintiff for the use of said credit card. 5. The defendant received and accepted goods and merchandise and/or accepted services and/or cash advances through the use of the credit card issued by the Plaintiff's predecessor. A true and correct copy of Plaintiff's Affidavit and Account Statement is attached hereto as Exhibit "A". 6. After allowing for all offsets and credits, a balance as of December 24, 2009 remains on the subject account having account number 5458001807753607 in the amount of $2,231.09 plus interest accruing at the rate of 23.9% from August 6, 2007 in the amount of • $1,801.76 for a total current amount due of $4,032.85; as of ` December 24, 2009 there remains a balance due in the amount of $4,032.85. 7. Plaintiff has made demand upon the defendant for payment of the balance due of $4,032.85 but the defendant has failed and refused and still refuses to pay the same or any part thereof. 8. Defendant's last payment on account was made on January 22, 2006. WHEREFORE, plaintiff claims of the defendant the sum of $4,032.85 plus applicable court costs and interest. Goldman & Warshaw, P.C. BY: Barry A. Ros AE uire Attorney for Plaintiff THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE THIS COMMUNICATION IS FROM A DEBT COLLECTOR PACARD VERIFICATION BARRY A. ROSEN, ESQUIRE, hereby states that he is attorney for Plaintiff, that he is authorized to execute this verification, that he has reviewed documents of plaintiff in preparation of the foregoing Civil Action Complaint, and verifies that the statements made and information contained in the foregoing Civil Action Complaint are true and correct to the best of his knowledge, information and belief. He understands that any false statements made herein are subject to the penalties contained in 18 Pa. C.S. Section 4904, related to unsworn falsifications to authorities. Date: ?' ?? BARRY 4REKN- Wo-6og-<1 Worldwide Asset Purchasing il, LLC PO BOX 50401 Henderson, NV 89016 Acct No: Unpaid Balance: Amount Enclosed: ••• Please Remit this Portion with Your Payment Direct Merchants Credit Card Bank, NA Account Statement Oriel 11 '.,Sul Statement Date: Unpaid Balance: Payment Due Date: APR: GEORGE MIHALOPOULOS 10 HERITAGE DR GREEN BROOK NJ 08812 Account# 5458001807753607 5458001807750607 $2,231.09 Merchants Credit Card Bank, NA 09/21/2006 $2,231.09 Account In Default 23.90% This statement was prepared by Worldwide Asset Purchasing II, L?C based on the furnished business records of Direct Merchants Credit Card Bank, NA. GEORGE MIHALOPOULOS 5458001807753607 ?007608i9 WW) ASST ,IPU*CHASYNG H LLC as e t DI*ECT IMyCRC"M i NA L DanIdk Moore being duly ?eived sworn according to law, depose and say that: I . I am the agent for the Plaintiff herein an I have c ,account, custody and control of the files relating to this 2. I have pe"Onal knowle;dge.of the &M d,rircumstancee.in ?nnection with this case; f 3. Plaintift'a files are maintained in tine 1 Oind ordinary aouase of business; 4. This action is based on a claim for brae df contract and that dathages are sought as a direct result of said breach; 5. After allowing for all offsets and credits a palance remains on the subject account having account number 5458001807753607 in the t1of 52,574.40;'and 6. If called upon, affant can beatify at trial to the facts pertaining to this matter The above facts are true and correct to of aty ell ?Ine of Affa ) and belief. Sworn to and Subscribed before me this Jday of 20 Notary Public SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff VAO of `uutbrT? ry? OFFICE GP "•? S•-ERIFF Jody S Smith Chief Deputy Edward L Schorpp Solicitor ZG?D ?E1 ry? r - t, Worldwide Asset Purchasing II LLC Case Number vs. George Mihalopoulos 2010-195 SHERIFF'S RETURN OF SERVICE 01/26/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: George Mihalopoulos, but was unable to locate him in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant George Mihalopoulos. Luis Castapalas resident of 119 Carol Lane, Enola, PA 17025 stated that George Mihalopoulos is believed to be residing in New Jersey. A neighbor advised Deputies George Mihalopoulos works at the Summerdale Diner located at 505 N. Enola Drive, Enola, PA 17025. However, the manager at The Summerdale Diner confirmed the defendant has not worked at this location in five years. The Enola Postmaster does not have a forwarding address on file for George Mihalopoulos. SHERIFF COST: $60.00 January 26, 2010 (C COUntySute Sher.ff. Teleosoft, Inc. SO ANSWERS, R ANDERSON, SHERIFF H0076089 Goldman & Warshaw, P.C. Barry A. Rosen, Esquire PA Identification No: 42951 GOLDMAN & WARSHAW, P.C. 312 W. Broad Street Quakertown, PA 18951 267-373-9730 Counsel for Plaintiff "'LE'-OFFICE or THE PROTHf;NOTAR ' 2010 NOV 30 AM 9: 29 CUMBERLAND COUN'Ty PENNSYLVANIA WORLDWIDE ASSET PURCHASING II, LLC as successor in interest to DIRECT MERCHANTS BANK, NA VS. GEORGE MIHALOPOULOS COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 10-195 PRAECIPE TO WITHDRAW COMPLAINT TO THE PROTHONOTARY: Kindly withdraw the above-captioned action, without prejudice. Goldman & Warshaw, P.C. /f BY. 1 Barry A. R en, ESQUIRE Attorney for Plaintiff P006 CERTIFICATION OF SERVICE I, Barry A. Rosen, ESQUIRE, hereby certify that I, on the date below, served a copy of Plaintiff's Praecipe to Withdraw Complaint Pursuant to Pa.R.C.P. 1028(c)(1), via First Class Mail, postage pre- paid, to all other parties or their counsel of record. Barry A. osen, ESQUIRE Dated: y