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Home My WebLink About10-02022072242 THIS IS AN ARBITRATION MATTER. ASSESSt?§NT4F DAMAGES HEARING REQUIRED. C G Q (7 C- GORDON & WEINBERG, P.C. ? BY: FREDERIC I. WEINBERG, ESQUIRE cr? , Identification No.: 41360 JOEL M. FLINK, ESQUIRE Cr.,> Identification No.: 41200_ ?r 1001 E. Hector Street, Ste 220 -- Conshohocken, PA 19428 w 484/351-0500 ASSET ACCEPTANCE LLC OF HOUSEHOLD BANK 18405 VanDyke Avenue Warren MI 48093 VS. TERRI R BLUMENTHAL 150 S PITT ST CARLISLE PA 17013 ASSIGNEE COURT OF COMMON PLEAS CUMBERLAND COUNTY U? DOCKET NO. : 10 - aka Civa lam 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 oo P ? a-rr/ ce id I q0 21'x' 0135 853 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)tae 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 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 December 16, 2009 in the amount of $1,299.26. 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 2/8/06. WHEREFORE, plaintiff claims of the defendant(s) the sum of $1,299.26 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDERIC I. W INB RG, ESQUIRE JOEL M. FLINK QUIRE 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, 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. Name E)Etf" P Ift!A 'rI KIERSKI EXHIBIT "A" -? 6-) Y 2---, STATE OF MICHIGAN COUNTY OF MACOMB ss ASSET ACCEPTANCE, LLC ) Plaintiff, ) vs ) AFFIDAVIT TERRI R BLUMENTHAL ) Defendant, ) I, nFANNA SKIERSKI 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 $1299.26 representing the charged off amount and interest. That the said account originally with /HOUSEHOLD BANK, account number 5440455014087376, 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. ted this 20th day of Nove er, 2009. Supervisor Subscribed and sworn to before me, a Notary Public for the State of Michigan, the 20th of November, 2009 as certified by my hand as set forth immediately ow. C Notary Public ?' 1 ?: ? i.Cl" IIY1 S3 '1 ?. ?i05 t ? C. : <.. ? %•. th, 40052712 1064 GORDON & WEINBERG 0 0 4 0 0 5 2 7 1 2 ASSET ACCEPTANCE LLC P.O. Box 2036 Warren, MI 48090 ACCOUNT NUMBER CURRENT BALANCE 5440455014087376 $1299.26 STATEMENT DATE DUE DATE NOV 20 2009 DUE TERRI R BLUMENTHAL 150 S PITT ST CARLISLE,PA 17013 ACCOUNT NUMBER DATE OF LAST PAYMENT 5440455014087376 02/08/06 DATE REFERENCE NO ACCOUNT INFORMATION BALANCE DUE NOV 20 2009 40052712 BALANCE DUE $1299.26 ASSET ACCEPTANCE LLC, A LIMITED LIABILITY COMPANY ORGANIZED AND EXISTING UNDER THE LAWS OF THE STATE OF DELAWARE, ASSIGNEE OF AALLC/COLLECT AMER P.O. Box 2036, Warren, MI 48090 DATE OF DELINQUENCY PURCHASED ON CHARGE OFF AMOUNT* INTEREST RATE 03/09/06 08/25/09 $1299.26 0.00% SERVICE ADDRESS (IF APPLICABLE) INTEREST DUE AS OF NOV 20 2009 $0.00 *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 40052712 1064 GORDON & WEINBERG SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny RAnderson r,)r jyF p~~:~`~-!~'?f~~?;T~?Y Sheriff ,~, ui~:~~~}r~~,,, Jody S Smith ~'`~~ ~ ~~'~' ZD ~ Q ~~,~ ~ 3 Hid EQ~ 2 Chief Deputy Edward L Schorpp CL:wi - - ` ii„i~Y `~V, ' ~ t, Solicitor ,~~r rri'°t~ ~ ~ ° ~ ~ ,~ Asset Acceptance LLC vs. Terri R. Blumenthal Case Number 2010-202 SHERIFF'S RETURN OF SERVICE 01/08/2010 02:45 PM -Michael Garrick, Deputy Sheriff, who being duly sworn according to law, states that on January 8, 2010 at 1445 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Terri R. Blumenthal, by making known unto Kevin Kelly, Adult in charge at 150 S. Pitt Street, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $33.40 January 11, 2010 SO ANSWERS, O NY R ANDERSON, SHERIFF BY t~ Sherif 2072242 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 HOUSEHOLD BANK vs. TERRI R BLUMENTHAL COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 10-202 NOTICE Pursuant to Pa.R.Civ.P. 236 of the Supreme Court of Pennsylvania, you are hereby notified that a judgment has been entered against you in the above proceeding as indicated below. /X1 Judgment by Agreement $1,491.26 ~ Money Judgment $ L.L Judgment on A~+ard of Arbitratora$ ,[J[ Judgment on Verdict$ IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL ATTORNEYS: FREDERIC I. WEINBERG OR JOEL M. FLINK, ESQUIRES AT THIS TELEPHONE NUMBER: 484/351-0500 -J PROTHONOTARY a~ie~io GORDON&WEINBERG Fax GORDON & wEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 4.200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 ASSET ACCEPTANCE LLC ASSIGNEE OF HOUSEHOLD BANK 18405 vanDyke Avenue Warren MI 48093 vs. TERRI R BLUMENTHAL 150 s ~zTT sT CARLISLE FA 17013 ~I~.oo PD ATi`1 ~~" I OSadv~ P.~" ~3'? ~5~ IJrr4tc,. ~ JUDC~NT BY ACrREENII:NT o10f0 P.N D N Ow , t }-: i s ~ a~la- d ti :' o f ~~6 .~8~3-, i t i s hereby stipulated and agreed to by and between, TERRI R BLUMENTHAL her successors and assigns and Frederic I. Weinberg, Esquire, counsel for ASSET ACCEPTANCE LLC ASSIGNEE OF HOUSEHOLD BANK that the Court enter a determination in the above-captioned case as follows: 1. Judgment shall be entered in the amount of One Thousand Four Hundred Ninety One Twenty Six (51,491.26) in favor of ASSET ACCEPTANCE LLC ASSIGNEE OF HOUSEHOLD BANK and against, 'TERRI R BLUMENTHAL her successors and assigns; 2. Plaintiff, ASSET ACCEPTANCE LLC ASSIGNEE OF HOUSEHOLD BANK will agree to accept the sum of $50.00 per month from, TERRI R BLUMENTHAL her successors and assigns. The first payment of 550.00 per month shall become due and payable on February 15, 2010 and then on the 15th of every month thereafter until tine Stipulated Judgment is paid in 2072242 Jan 12 2010 02:35pm P003/004 n N c~ -' ~1 p` 'r~ Z:i r~;' Tr ~ :-r; = rT7 i~ W Ci7i-~__ ii? `~ -~ -a r-n ~., _ ~, :.~ l1 7 ~;.Tk y ~ ~U ~C~ C N =; ~'r COURT OF COMMON PLEAS ~ -.- ~ CUMBERLAND COUNTY °1 ~ DOCKET N0. i0-202 GORDON&WEINBERG Fax Jan 12 2010 02:35pm POOd/OOd full; 3. In the event that TERRI R BLUMEN'~HAL her successors and assigns do not make payments as prescribed in paragraph 2, they will. be considered in default and the Plaintiff, ASSET ACCEPTANCE LLC ASSIGNEE OF HOUSEHOLD BANK shall be allowed to exercise any and all remedies available at law. 4. The Parties to this action. have authorized their respective counsel and agent to enter into this agreement on their behalf and by doing so this agreement will be binding on both that TERRI R BLUMENTHAL her successors and assigns and, ASSET ACCEPTANCE LLC ASSIGNEE OF HOUSEHOLD BANK its succe~ors and assigns. a ~. ~ a v~, Date: TER I R BL De:z 17Clc~lnt Date : ~ ~ ~~ l ~~ , FREDERrC I. WE NBF Esquire Attorney for Plainta.ff z.D. #41360 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500