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Home My WebLink About10-0310THIS 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 S' 'UM rn +. r N C7 0 L x N 3s w RAZOR CAPITAL, LLC 8003 Norman Center Drive, Bloomington, MN 55440 VS. KEVIN R ZYGMUNT 16 BELLMORE RD CAMP HILL PA 17011-7901 NOTICE 2069161 ARBITRATION MATTER. OF DAMAGES HEARING REQUIRED. COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 10,-- 31C) t3 ? -c 0,161 Terri 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 -fga.00 Pb ATTy PT* a? 130 COMPLAINT IN CIVIL-ACTION 1. Plaintiff, RAZOR CAPITAL, LLC a debt buyer and successor in interest to the original creditor, Wells Fargo. 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 January 4, 2010 in the amount of $10,071.20. 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 2/28/2008. WHEREFORE, plaintiff claims of the defendant(s) the sum of $10,071.20 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDERIC I. W (!IN RG, ESQUIRE JOEL M. FLINK, Q UIRE Attorney for Plaintiff POIP.DB 2069161 12P798 RAZOR CAPITAL, LLC KEVIN R ZYGMUNT 4465920171820392 VERIFICATION I hereby state that I am tt-se agent for the plair,titf herein, anj that the facts set forth in the a`tached Affidavit whif_Jh is incorporated by reference in the forcgoing Complaint in Civil Action are true and coxrect to the best of my knowledge, information and belief and is based upon information which plaintiff has furnished ?o counsel. The lanquagc in Lhe Comrlaint is that of counsel and riot o* plaintiff. To the extent that the cont.ertts of the Complaint are that of counsel, plaintiff has relied upon counsel in mak_riq this. verification. This verification is made subject to ib Pa,C,S. §4904 which provides for cert.aitt pena.l ties for.-mak' f C( false statements. j / . i i r? TODD AND^ .,o K, IRECTOR OF OPEP ITA prig EXHIBIT "A" KEVIN R 'l,YVMUNT 4466420171820392 St:aL.e of Minnesota County of. Hennepin § 2069161 RAZOR CAPTTAL, LLC AFFIDAVIT I, TODD ANDERSON being duly served sworn accor.•ciing to law, depose and say that: 1. I am employed as the legal outsourcing clerk for the Piaintirr herein and T have custody and control of the files relating to L.his account.; 2. S have personal knowledge of the facts and circumstances in connection with this c=ase and base this affidavit. on Plaintiff's records, as well as the acr_nunt information provided to Plaintiff by llol?s r''argo when W l'S Fargo sold the account to Razor Capital, LLC. 3. Plaintiff's riles are maic7Lained in the usual and ordinary course of business; 4. This action is based on a claim for breach of contract and 1-hat damages are sought as a direct result of said breaci;; Thsre i s r_^w due alld nw°•..nc from. defer--ant to Plaintiff, f ?•fr,'.1n9. 3ti I l,f :.ile an?;,unt ?_, .is in?• t,Jrest o f j fJ at Lhe rate of 19. 99S'' less r-nnl.l_,t r, ,, . iCd]t in the f . GG tr,taling y, as of 1.1ugus` 24, 2000. 5. Tr called upon, affiant can testify at_ trial as to the acts pett.aining to this matter. The above facts are true and correct to thy?,he."t of n,v knowledge, :i reformation and belief. ?i TODD 'VDF:R5ON; DIRF:C1'()R OF OPFR.ATION$ Sworn to and Subscribed i before me this day 0f f11 is t?o9 ET-0- ary Public ' Sta e O :,acv t f M l?? :"'oar, y. Ronny R Anderson Sheriff Jody S Smith Chief Deputy Edward L Schorpp SOtlC/tOr SHERIFF'S OFFICE OF CUMBERLAND COUNTY t=1LEL~3-{~a=i=iC~ ,,~ ThM P~~~~~-'~'~`~~~jAAY ~+~~tX4~ u~ '~ iUliutr,I~ t v +~ _ ZOlOFEf-3-9 ~~~If~O~ - .-~ t:..' .~ ! ~.JvN SY ff ~- ~,v~ ~ L~,Ft: Razor Capital, LLC vs. Kevin R. Zygmunt Case Number 2010-310 SHERIFF'S RETURN OF SERVICE 01/28/2010 08:35 PM -Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on January 28, 2010 at 2035 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Kevin R. Zygmunt, by making known unto Christin Zygmunt, Wife of defendant at 16 Bellmore Road, Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $41.94 February 04, 2010 SO ANSWERS, R N R,A~NDER Of ,SHERIFF ~ s, ~ ~ gY is (..ounty ~a:,:n S..tsr!.fi. T`r.~^soft. ~:;. F ILED-o;.F ICS: GORDON & WEINBERG, P.C. F HE iPROT(10NOTAR1111 BY: FREDERIC I . WEINBERG, ESQUIRE 2013 MAY ` 3: Identification No. : 41360 JOEL M. FLINK, ESQUIRE CUMBERLAND COUNTY Identification No. : 41200 PENNSYLVANIA 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 RAZOR CAPITAL, LLC COURT OF COMMON PLEAS CUMBERLAND COUNTY VS . DOCKET NO. 10-310 KEVIN R ZYGMUNT PRAECIPE TO VACATE JUDGMENT TO THE PROTHONOTARY: Please vacate the Judgment entered in the above matter. GORDON & WEINBERG, P _ BY: FREDERIC 1 . W BERG, ESQUIRE JOEL M. FLINK, ESQUIRE Attorney for Plaintiff PO10 L' ok 1 lok- a��3� c. 4 CERTIFICATION OF SERVICE I, FREDERIC I . WEINBERG, ESQUIRE, hereby certify that I, on the date below, served a copy of the Praecipe to Vacate Judgment 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. FREDERIC I WEINB RG, ESQUIRE 1� Dated