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Home My WebLink About10-0960v 2069930 THIS IS AN ARBITRATION MATTER. DAMAGES HEARING REQUIRED. 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 ASSESSMENT OF L 4 L 1 5 1 - na ASSET ACCEPTANCE LLC ASSIGNEE OF VALUE CITY FURNITURE/Wor 28405 Van Dyke Ave Warren MI 48093 VS. JULIET M FULLER 457 HEISEY RD MECHANICSBURG PA 17055 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 10 - qU0 atVi (,P, 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 O $Cd. 00 PO ATrV et:* (0S'776 e ' ; 3r a&q 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)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 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 November 23, 2009 in the amount of $3,446.93. 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 2/4/07. WHEREFORE, plaintiff claims of the defendant(s) the sum of $3,446.93 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDERIC I. WE BERG, ESQUIRE JOEL M. FL , ESQUIRE Attorney for Plaintiff P01A.DB VERIFICATION I hereby state that I ain the agent for the plaintiff herein, and that the facts set forth in the attached Affidavit which is incorporated by reference in the foregoing Complamt 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. Judy Melasi EXHIBIT "A" c2o4 L l 36 STATE OF MICHIGAN COUNTY OF MACOMB ASSET ACCEPTANCE, LLC ss Plaintiff, vs ) JULIET M FULLER ) AFFIDAVIT Defendant, ) I, ludo Wiwi 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 $3385.86 representing the charged off amount and interest. That the said account originally with /VALUE CITY FURNITURE/ World Financial Network N, account number 005856371008963430, 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. Dated this 14th day of September, 2009. S rvisor Subscribed and sworn to before me, a Notary Public for the State of Michigan, the 14th of September, 2009 as certified by my hand as set forth immediately below. Notary Public e. 39203660 1064 GORDON & WEINBERG 0 0 3 9 2 0 3 6 6 0 rVseACC ?O10 nca ASSET ACCEPTANCE LLC P.O. Box 2036 Warren, MI 48090 JULIET M FULLER 457 HEISEY RD MECHANICSBURG,PA 17055 ACCOUNT NUMBER CURRENT BALANCE 005856371008963430 $3385.86 STATEMENT DATE DUE DATE SEP 14 2009 DUE ACCOUNT NUMBER 005856371008963430 DATE OF LAST PAYMENT 02/04/07 DATE REFERENCE NO ACCOUNT INFORMATION BALANCE DUE SEP 14 2009 39203660 BALANCE DUE $3385.86 ASSET ACCEPTANCE LLC, A LIMITED LIABILITY COMPANY ORGANIZED AND EXISTING UNDER THE LAWS OF THE STATE OF DELAWARE, ASSIGNEE OF 005856371008963430 P.O. Box 2036, Warren, MI 48090 DATE OF DELINQUENCY PURCHASED ON CHARGE OFF AMOUNT* INTEREST RATE 03/08/07 04/01/09 $2821.56 10.00% SERVICE ADDRESS (IF APPLICABLE) INTEREST DUE AS OF SEP 14 2009 $564.30 *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 39203660 1064 GORDON & WEINBERG SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff 'uY Jody S Smith 2010FEB 22 Chief Deputy ` ° ?? Edward L Schorpp Cu+4 r Solicitor Asset Acceptance LLC vs. Juliet M. Fuller Case Number 2010-960 SHERIFF'S RETURN OF SERVICE 02/18/2010 02:25 PM - Michelle Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on February 18, 2010 at 1425 hours, she served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Juliet M. Fuller by making known unto herself personally, at 457 Heisey Road, Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $37.00 February 19, 2010 SO ANSWERS, 1 Y R ANDERSON, SHERIFF 1 By Deputy Sheriff . bungSuite She-ff. Teiioso`t. Inc, 2069930 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 VALUE CITY FURNITURE/Wor VS. JULIET M FULLER COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 10-960 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 Agreement $3,712.00 Money Judgment $ f? Judgment on Award of Arbitrators$ u 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 PR ONOTARY i G RDON & WEINBERG, P.C. B : FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 41200 1001 E. Hector Street, Ste 220 C nshohocken, PA 19428 434/351-0500 2069930 PLED-OFF-CE r T - ,; Y 2010 APP -6 AM 10: 41 csrn rk `" ?,,?" ? ASSET ACCEPTANCE LLC ASSIGNEE OF VALUE CITY FURNITURE VS. LIET M FULLER COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 10-960 JUDCIUNT BY AGREENZNT VNd AND NOW, thisZtiday of MajrGj 2010, it is hereby stipulated a?d agreed to by and between, JULIET M FULLER, her successors and assigns and Frederic I. Weinberg, Esquire, counsel for ASSET ACCEPTANCE LLC ASSIGNEE OF VALUE CITY FURNITURE/WORLD FINANCE that the Court enter a determination in the above-captioned case as follows: 1. Judgment shall be entered in the amount of Three Thousand even Hundred Twelve Dollars ($3,712.00) in favor of ASSET ACCEPTANCE C ASSIGNEE OF VALUE CITY FURNITURE/WORLD FINANCE and against, JULIET FULLER, her successors and assigns; 2. Plaintiff, ASSET ACCEPTANCE LLC ASSIGNEE OF VALUE CITY RNITURE/WORLD FINANCE, will agree to accept the sum of $25.00per nth from, JULIET M FULLER, her successors and assigns. The first ayment of $25.00 per month shall become due and payable on March 15, 010 and then on the 15th of every month thereafter until the tipulated Judgment is paid in full; 3. In the event that JULIET M FULLER, her successors and assigns wY.06 ?C(_Jgl'f e K-0 /Iy44. L( a.3 49S',? P na Y ? i J not make payments as prescribed in paragraph 2, they will be sidered in default and the Plaintiff, ASSET ACCEPTANCE LLC ASSIGNEE F VALUE CITY FURNITURE/WORLD FINANCE shall be allowed to exercise any d all remedies available at law. 4. The Parties to this action have authorized their respective nsel and agent to enter into this agreement on their behalf and by ing so this agreement will be binding on both that JULIET M FULLER s/her successors and assigns and, ASSET ACCEPTANCE LLC ASSIGNEE OF ALUE CITY FURNITURE/WORLD FINANCE its successors and assigns. ate: LIET M FULLER fendant ate: FREDE I. WEINBERG, Esquire JOEL / FLINK, ESQUIRE Atto ney for Plaintiff I.D. #41360 I.D. #41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500