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Home My WebLink About10-0305S FLED-f„ r cc Or' THE F") 2010 JAN I I Fri 3: 44 LAW OFFICES OF SCOTT L. FELDMAN BY: Scott L. Feldman, Esquire I.D. No. 68805 P.O. Box 1231 Doylestown, PA 18901 (215) 230-8800 Attornet ? -r--,?uP-1kirit--)w y p-P lj"'S't&ANA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LONESTAR FINANCIAL SOLUTIONS CIVIL ACTION NO. 3830 Old Garner Road Weatherford, TX 76088 Plaintiff V. GREGORY S. DUNKLE 32 W. Beale Street Enola, PA 17025-2805 Defendant ATTORNEY I.D. # 68805 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 judgment may be entered against you by the court without further notice for any money claims 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 South Bedford Street Carlisle, PA 17013 Telephone: (717) 249-3166, (800) 990-9108 #(?2 .o0 L 12aft ` tK- o23b.117 LAW OFFICES OF SCOTT L. FELDMAN BY: Scott L. Feldman, Esquire I.D. No. 68805 P.O. Box 1231 Doylestown, PA 18901 (215) 230-8800 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LONESTAR FINANCIAL SOLUTIONS CIVIL ACTION NO. 3? 3830 Old Garner Road V J Weatherford, TX 76088 Plaintiff ATTORNEY I.D. # 68805 V. GREGORY S. DUNKLE 32 W. Beale Street Enola, PA 17025-2805 Defendant . COMPLAINT 1. Plaintiff, Lonestar Financial Solutions, is a debt buyer and successor in interest to the original creditor, US Bank. 2. Defendant, Gregory S. Dunkle, is an adult individual residing at 32 W. Beale Street, Enola, Cumberland County, Pennsylvania. 3. At all times relevant hereto, the defendant was the holder of a Visa Platinum account credit card #4623028902023878, which at the request of the defendant _was issued to the defendant by the original creditor under the terms by which the original creditor agreed to extend to defendant the use of original creditor'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 original creditor for the use of said credit card. 5. The defendant 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 is attached hereto as Exhibit "A". 6. All the credits to which the defendant is entitled have been applied and there remains a balance due as of December 18, 2009, in the amount of $8,430.97. 7. Plaintiff has made demand upon the defendant for payment of the balance due 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 October 6, 2008. WHEREFORE, plaintiff claims of the defendant (s) the sum of $8,430.97, plus applicable costs, interest and attorney's fees. Respectfully Submitted, Scott L. eldman, Esquire i LAW OFFICES OF SCOTT L. FELDMAN BY: Scdtt L. Feldman, Esquire I.I. No. 68805 P.O. Box 1231 Doylestown,'!PA 18901 (215) 230-8000 I Attorney for Plaintiff IN THE?COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LONESTA? FINANCIAL SOLUTIONS 3830 Old Garner Road Weatherford, TX 76088 Plaintiff V. GREGORY S. DUNKLE 32 W. Belale.Street Enola, Ph 17025-2805 i Defendant CIVIL ACTION NO. ATTORNEY I.D. # 68805 VERIFICATION VERIFICATION I, ?he undersigned, hereby state that I am authorized to take this Verification on behalf of Plaintiff and that the statements contained in the foregoing Complaint are true and correct to the best of my personal knowledge, information and belief. z understand that the statements herein are made subject to the penalties of 18 Pa. C.S. § 4909 relating to unsworn falsification to authorities. I I' 1 I. i ?°,t 14 t + v N d 71 N 3 y o rr ? O O1 N N n d v { Gf f o / V A V O d tJ1 O C S S .; ? s g ti 0 'O E a tn m ? 7 N N 3 d 8 ? ? n C O S ? V W ? A N P V o ? o o v + w y o r V 8 v S V p O r O < 3 s m s d ., r`rn v i O M I ? N (p 0? S d 0 2 ? s s s? 3 3 ? g c v? a v o N o ?r e N V J J J J n n r 2 i 3 S7 I I I I l c D n v 0 Q ? 0 T Q. w V) c 0 Z) un T rn 0 0 19 Q V1. tD D l!1 I SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Edward L Schorpp Solicitor 7t P ry ! n , r 201 J3 ;t? ?-9 ,[:t; Lonestar Financial Solutions vs. Gregory S. Dunkle Case Number 2010-305 SHERIFF'S RETURN OF SERVICE 01/22/2010 08:19 PM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on January 22, 2010 at 2019 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Gregory S. Dunkle, by making known unto himself personally, at 32 W. Beale Street, Enola, Cumberland County, Pennsylvania 17025 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $41.50 January 25, 2010 SO AN WERS, NY R ANDERSON, SHERIFF By - V? ty Sheriff I CountySuite Sheriff. Teleosoft, Inc. LAW OFFICES OF SCOTT L. FELDMAN BY: Scott L. Feldman, Esquire Attorney for Plaintiff I.D. No. 68805 P.O. Box 1231 Doylestown, PA 18901 (215) 230-8800 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW LONESTAR FINANCIAL SOLUTIONS CIVIL ACTION N0.2010-305 Plaintiff . v. . GREGORY S. DUNKLE NOTICE OF FILING JUDGMENT Defendant . ( X ) Notice is given that a Judgment in the above captioned matter has been entered against you in the amount of $8,578.47 on April 20, 2010, plus court costs. ( X ) A copy of all documents filed with the Prothonotary in support of the within judgment is/are enclosed. ~_~ David D.'Buell Prothonotary ~~aa~~~o If you have any questions regarding this Notice, please contact the filing party listed above. (This Notice is given in accordance with Pa.R.C.P. No. 236.) ~-} i 2~;~~~~~~ ~,~~~l~~o LAW OFFICES OF SCOTT L. FELDMAN BY: Scott L. Feldman, Esquire Attor~~~~_•fa~`<~l~ri'~~ff I . D. No. 68805 `~',_ ._'.~ ~' '~'` P.O. Box 1231 Doylestown, PA 18901 (215) 230-8800 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LONESTAR FINANCIAL SOLUTIONS Plaintiff v. . GREGORY S. DUNKLE . Defendant CIVIL ACTION NO. 2010-305 ATTORNEY I.D. # 68805 PRAECIPE TO ENTER DEFAULT JUDGMENT TO THE PROTHONOTARY: Please enter default judgment on behalf of Plaintiff, Lonestar Financial Solutions, and against Defendant, Gregory S. Dunkle, in the above-captioned matter. This action was instituted on January 11, 20:10, by Plaintiff filing its Complaint. On January 22, 2010, personal service upon Defendant was effected by the Cumberland County Sheriff. True and correct copies of the first page of the Complaint and of the Sheriff's Return of Service are attached hereto and. marked as Exhibits "A" and "B" respectively. On February 12, 2010, Plaintiff's counsel sent notice to Defendant pursuant to Pa. R.C.P. § 237.1 of Plaint=iff's intention to take default judgment. True and correct copies of said Notice along with a Certificate of Service are attached hereto and marked as Exhibits "C" and "D" respectively. Accordingly, effective service of the Complaint has been acknowledged and subsequent Notice served upon Defendant. Defendant, Gregory S. Dunkle, to date has failed to file an Answer to Plaintiff's Complaint. WHEREFORE, Plaintiff respectfully request~~ that default judgment be entered in its favor and against Defendant in the ~I~. oo P A A7't^/ C~~ (503 2.# ay~ooa I~o~hc~. O~~LCU1~~P ~~ P~ ~a~l' a~ amount of 58.430.97, plus costs Dated : ~ ^„0`~ ~ __ ~~ '~ ~` - - SCOTT L. FELDMAN, ESQ. Attorney for F~laintiff -,,~- ~`~~,.J,`1LCIVt_ AAn t l~ T Ir ~~~f~ j''- 'nr, i~Tt'Jl~ LAW OFFICES OF SCOTT L. FELDMP,N BY: Scott L. Feldman, Esquire I.D. No. 68805 P.O. Box 1231 Doylestown, PA 18901 (215) 230-8800 2QIOJr'd 4 1 Pry 3~ ~~ Attorney forr,B;laintff ,~~;~~~-,~ ~tdlrW:,:: a~ ~ :~ ,.~ r~:_~ ~., ~`~!t "'mot ~~ ~u ~ v~ CQ PY IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LONESTAR FINANCIAL SOLUTIONS CIVIL ACTION NO. 3830 Old Garner Road ~d _ 3C~• ~tU~J~ Weatherford, TX 76088 l~: ((,„,~~ Plaintiff ATTORNEY I.D.. ## 68805 v. GREGORY S. DUNKLE 32 W. Beale Street . Enola, PA 17.025-2805 Defendant . NOTICE You have been sued in court . If you wish to defend against the claims set forth in the following pages., you rnust take action within twent~~T (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 judgment may be entered against you by the court without further notice for any money claims 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 OFD CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET F!JRTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 Telephone: (717) 249-3166, (800) 990--9108 SHERIFF'S OFFICE OF CUMBERLAND C-OUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Edward L Schorpp Solicitor Lonestar Financial Solutions vs. Gregory S. Dunkle t". COPY Case Number 2010-305 SHERIFF'S RETURN OF SERVICE 01/22!2010 08:19 PM -William Cline, Deputy Sheriff, who being duly sworn according to law, states tha± on January 22, 2010 at 2019 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Gregory S. Dunkle, by making known unto himself personally, at 32 W. Beale Street, Enola, Cumberland County, Pennsylvania 17025 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $41.50 January 25, 2010 SO AN WERS, O NY R ANDERSON, SHERIFF BY ~~ ty Sheriff ;c Coun`ySuite Sheriff. Te!ecsofl. lnc. C i LAW OFFICES OF SCOTT L. FELDMAN BY: Scott L. Feldman, Esquire I.D. No. 68805 P.O. Box 1231 Doylestown, PA 18-901 (215) 230-8800 Attorney for Plaintiff ~ co~v IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LONESTAR FINANCIAL SOLUTIONS Plaintiff , v. GREGORY S. DUNKLE , CIVIL ACTION NO. 2010-305 ATTORNEY I.D.. # 68805 Defendant . To: Gregory S. Dunkle Date of Notice: February 12, 2010 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILEL) TO TAKE ACTION REQUIRED OF YOU IN THIS CASE. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY O:R OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 Telephone: (717) 249-3166, (800) 990--9108 C,~~ ~ B Y : ~ ~Q , Scott L. Feldman, Esq. Attorney for Plaintiff LAW OFFICES OF SCOTT L. FELDMAN BY: Scott L. Feldman, Esquire Attorney for Plaintiff I.D.'No. 68805 P.O. Box 1231 Doylestown, PA 18901 (215) 230-8800 ~ O ^` IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LONESTAR FINANCIAL SOLUTIONS Plaintiff . v. , GREGORY S. DUNKLE Defendant . CIVIL ACTION NO. 2010-305 ATTORNEY I.D. # 68805 CERTIFICATE OF SERVICE I hereby certify that on Friday, February 12, 2010, I caused a true and correct copy of the foregoing document (237.1 10 Day Notice) to be served on Defendant by first class mail, postage prepaid, addressed as follows: Gregory S. Dunkle 32 W. Beale Street Enola, PA 17025-2805 BY : Nc( , Scot L. ]~eldman, Esquire Attorney :Eor Plaintiff