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HomeMy WebLinkAbout10-0415 2069736 THIS IS AN ARBITRATION MATTER. ASSESSMENT OF DAMAGES HEARING REQUIRED. GORDON & WEINBERG, P.C. n C- N 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 PALISADES COLLECTION, LLC COURT OF COMMON PLEAS 210 Sylvan Ave, Englewood Cliffs CUMBERLAND COUNTY NJ 07632 VS. DOCKET NO. ID-415 Cl vi iert% LEWIS LABORI 3434 GREEN ST CAMP HILL PA 17011-4419 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, 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 $ga.oo PO A'rN er.? 9gq?(v COMPLAINT IN CIVIL-ACTION 1. Plaintiff, PALISADES COLLECTION, LLC a debt buyer and successor in interest to the original creditor, GE Money Bank. 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 November 30, 2009 in the amount of $1,260.36. 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 12/8/08. WHEREFORE, plaintiff claims of the defendant(s) the sum of $1,260.36 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: 17?- FREDERIC I. WE RG, ESQUIRE JOEL M. FLINK, ESQUIRE Attorney for Plaintiff P01P.DB 2069736 19447779 PALISADES COLLECTION, LLC LEWIS LASORI 6034621701469041 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. A E EXHIBIT "A" 2069736 PALISADES COLLECTION, LLC LEWIS LABORI 6034621701469041 State of New Jersey County of Bergen § § AFFIDAVIT Ana Hernandez I, and say that: , being duly served sworn according to law, depose 1. I am employed as the legal outsourcing clerk for the Plaintiff herein and I have custody and control of the files relating to this account; 2. I have personal knowledge of the facts and circumstances in connection with this case and base this affidavit on Plaintiff's records, as well as the account information provided to Plaintiff by GE Money Bank when GE Money Bank sold the account to PALISADES COLLECTION, LLC. 1 a. 3. Plaintiff's files are maintained in the usual and ordinary course of business; 4. This action is based on a claim for breach of contract and that damages are sought as a direct result of said breach; 5. There is now due and owing from defendant to plaintiff, the amount of $1,260.36 plus interest of $.00 at the rate of 0% less credits in the amount of $.00 totaling $1,260.36 as of November 18, 2009. 6. If called upon, affiant can testify at trial as to the facts pertaining to this matter. The above facts are true and correct to the best of my knowledge, information and belief. A FI Sworn to and Subscribed before me this day of 2009 L-t SsrQ otary Public *,PH JUDITH JOSEPH STONE NOTARY PUBIC STATE OF NEW JERSEY ??•''?? Y'•.y? MY COMMISSION EXPIRES: JAN 19, 2012 D: ,?• C *''• pUB??; yeti SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Edward L Schorpp Solicitor ~~~ ~.«, qt 4tiir~tirr/,r.~ t ~'+F~'r '. .~~.;,c; ,~ -~-, ~. (-~LF~ ; ~ F.~E_ ~'~ r~r L n'T ur > ~'~RY ~~I~ FES ! 9 ~~ ~~ ~-, ,f , Lt. i _ , '~~ ~"1~r~ . v': ~J r Palisades Collection, LLC Case Number vs. Lewis Labori 2010-415 SHERIFF'S RETURN OF SERVICE 02/12/2010 08:30 PM -Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on February 12, 2010 at 2030 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Lewis Labori, by making known unto himself personally, at 3434 Green Street, Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $95.50 February 16, 2010 SO A ERS, O NY R ANDERSON, SHERIFF ~ '~. `~-~ Deputy Sheriff tci GcunySuite Shen+t. 'fei2osoft. Ir:;.