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Home My WebLink About10-0413 2064523 THIS IS AN ARBITRATION MATTER. ASSESSMENT OF DAMAGES HEARING 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 REQUIRED. C. 1 r` -r to -c COURT OF COMMON PLEAS CUMBERLAND COUNTY RJM ACQUISITIONS, LLC 600 BROADHOLLOW ROAD, MELVILLE, NY 11747 DOCKET NO. : (p - 4 13 ? vi )erm Vs. SETH MUNSON 320 RAVEN CT MECHANICSBURG PA 17050-2084 COMPLAINT IN ASSUNPSIT 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 00 PD A7-ty ao 106088 1. Plaintiff, RJM ACQUISITIONS, LLC a debt buyer and successor in interest to the original creditor, WACHOVIA BANK, N.A.. 2. The defendant, for valuable consideration received, executed and delivered to plaintiff a promissory note under the terms of which the defendant promised to pay to the plaintiff consecutive monthly payments under the terms and conditions set forth in the promissory note. A true and correct copy of the aforesaid promissory note or Affidavit of Account, if available, is attached hereto, made a part of this complaint and marked Exhibit "A". 3. Contrary to the terms of the aforesaid promissory note, the defendant failed to make the required payments when due as a result of which the unpaid balance of $2,762.33 became due and payable. 4. All the credits to which the defendant(s)is entitled have been applied and there remains a balance due as of December 2, 2009 in the amount of $2,762.33. 5. 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. 6. Defendant's last payment on account was made on 7/15/2008. 46 WHEREFORE, plaintiff claims of the defendant(s) the sum of $2,762.33 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: RG, ESQUIRE FREDERIC I. W OUIRE JOEL M. FLINK Attorney for tiff P01C.DB 2064523 1021746790 RJM ACQUISITIONS, LLC SZTN NW8ON 081010194032122*01 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. Pau! Chen NAME EXHIBIT "A" SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff a 4117 ot Climb QF€ICE FTrES.YRIFF F?± "r1"1M ;iY Jody S Smith Chief Deputy Edward L Schorpp Solicitor RJM Acquisitions, LLC vs. Seth Munson 2010 Xii112- 6 A1i 11: G7 C 1- Case Number 2010-413 SHERIFF'S RETURN OF SERVICE 01/21/2010 11:52 AM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on January 21, 2010 at 1152 hours, he served a true copy of the within Complaint in Assumpsit, upon the within named defendant, to wit: Seth Munson, by making known unto Richard Munson, Father of defendant at 320 Raven Court, Mechancisburg, Cumberland County, Pennsylvania 17050 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $37.00 January 22, 2010 SO ANSWERS, N R ANDERSON, SHERIFF By_ Deputy Sheriff {c; CountySuite Sheriff, Telecsoff, Inc, 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 2064523 RJM ACQUISITIONS, LLC COURT OF COMMON PLEAS CUMBERLAND COUNTY N O VS. SETH MUNSON 320 RAVEN CT MECHANICSBURG PA 17050-2084 DOCKET NO. 10-413 -r7 ? r c.7 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. /X/ Judgment by Default $2,762.33 Money Judgment $ f1 Judgment on Award of Arbitrators$ 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 V PROT RY 2064523 GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 81894 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 RJM ACQUISITIONS, LLC VS. SETH MUNSON "TJ ?7 COURT OF COMMON PLEAS:'; CUMBERLAND COUNTY,. DOCKET NO. 10-413, N 0 0 y. "CJ X - W PRRECIPE FOR ENTRY OF JUDGNZNT FOR MANT OF AN ANSWER, ASSESSMNT OF DAMAGES VERIFICATION OF ADDRESS AND NON-MILITARY SERVICE TO THE PROTHONOTARY: Enter judgment for want of an answer for plaintiff and against defendant(s) above named only and assess damages certified to be calculable as a sum certain from the complaint, as follows: Principal $2,762.33 Less: Payments on Account ( $.00) Total: $2,762.33 Understanding the false statements made herein are subject to penalty under 18 Pa.C.S.A. §4904, Unsworn Falsification to Authorities, I verify that: 1. The last known addresses of the parties are: RJM ACQUISITIONS, LLC and that the last known address of defendant, SETH MUNSON, 320 RAVEN CT, MECHANICSBURG PA 17050-2084. --i (rl rn MC) L C) ? l i M 2. The annexed notice(s) of intention to file this praecipe was (were) mailed to all parties, defendant and to their record attorneys, if any, after default occurred, and at least ten days prior to the date of filing of this praecipe. 3. The said defendant(s) is (are) not in the military service of the United States or otherwise within the coverage of the Soldiers and Sailors Civil Relief Act and is (are) over 18 414-oopPATfy years of age. 011(811 Pa*a3s') q8 w AND NOW, this 107fk day of jA6UAh , 2010 Judgment is entered in favor of the plaintiff(s) and against defendant(s) by default for want of an answer and damages asat the su m of $2,762.33 as per the above c 2??;)-*?w cationProthonotary GORDON & WEINBE P.C. BY: FREDERIC I WEI BERG, ESQUIRE JOEL M. FL N ESQUIRE Attorney for Plaintiff 2064523 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 RJM ACQUISITIONS, LLC COURT OF COMMON PLEAS CUMBERLAND COUNTY Vs. DOCKET NO. : 10-413 SETH MUNSON TO/PARA NOTICE OF INTENTION TO TAKE DEFAULT SETH MUNSON 320 RAVEN CT MECHANICSBURG PA 17050-2084 DATE OF NOTICE/FECHA DEL AVISO: February 11, 2010 IMMRTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY AN ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. 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 OR OTHER IMPORTANT RIGHTS. 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 GORDON & WEINBERG, P.C. BY: 17-<? FREDERIC I. G, ESQUIRE JOEL M. FLIN EINSQUIRE P10D-2