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Home My WebLink About10-1111t 2054421 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 Collins Financial Services, Inc. as assignee of World's Foremost Bank 2101 West Ben White Blvd Austin, TX 78704 vs. Jeffrey Brandt 1000 MOUNTAIN RD NEWVILLE PA 17241-8504 ASSESSMENT OF c_n w ti.J _r s? Q COURT OF COMMON PLEAS. CUMBERLAND COUNTY DOCKET NO. : 1C)-1111 NOTICE O-tv I l lerm 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 *ga.ao PA FATty C?.? 108 ?-I 5 /9818 % 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 def=endant(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 October 29, 2009 in the amount of $3,471.26. 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 account was opened on 4/22/2006. WHEREFORE, plaintiff claims of the defendant(s) the sum of $3,471.26 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDERIC I. IN RG, ESQUIRE JOEL M. FLIN , SQUIRE Attorney for Plaintiff P01A.DB VEAL FT_ CATION I hereby state that I am the agent for the plaintiff herein, and that the fac't's set forth in the attached Affidavit which is incorporated by reference in the forego7.ng Complaint in Civil Action are true and correct to the best of my knowledge, information and belief and is ba.s,c_d 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 -th.:i s verification. This verification is made subject to 18 Pa..C. S. §4904 which provides for certain penalties for making false stai-I-ements. l i " ..) /I y"t '/I Name Card Nolvr%k EXHIBIT "A" It 1854 Collins Financial Services, Inc. PLAINTIFF VS. Jeffrey Brandt State of Texas County of Travis DEFENDANT 2054421 § AFFIDAVIT The undersigned, being duly sworn, states the following: 1. I am a custodian of the records for the plaintiff and in that capacity I make this affidavit. 2. 1 am familiar with the books and records of the plaintiff, and the books and records pertaining to the account which is subject matter of this action are maintained under my supervision and control, are kept in the ordinary course of business, and the entries made in those records are made at or near the time that the transactions reflected in those records occur. 3. Plaintiff purchased/was assigned this account from World's Foremost Bank/ CARD and/or its assigns, in the name of Jeffrey Brandt with account number 4300230051817999. 4. At the time of purchase/assignment of the subject account, the data from the records of the original creditor were loaded into the plaintiffs computer system. Following the initial entry of data, all subsequent entries into the the plaintiffs system were made at or near the time of the events that they describe. 5. The books and records of the plaintiff indicate that there is justly due and owing by the Jeffrey Brandt as of April 17, 2009, the sum of $3,471.26 plus interest at the rate of 0%for a total balance due in the amount of $3,471.26. 6. To the best of my information and belief, Jeffrey Brandt is a resident of NEWVILLE PA 17241,8504 and is neither an infant nor incompetent. The foregoing matters are, to the best of my information and belief, true and correct. AFFIANT 4wF- V&(4t«uWCt Sworn to and subscribed before me this 11 Day of NM 2009. b • p pf V Y?t LENORA KATHLEEN STELTER NOTARY PUBLIC STATE OF TEXAS COMMISSION EXPIRES: 03-29-20 1 Notary Public, State of Texas x" My Commission Expires: (?} 1 Ref. No. 7287159 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ~~yytt,Y~ o[lrit~nGfr[,y~~0 ~~ .~~~ >.r t;7F! i,~ C,~F 'r£ 9~r6F31F~ FlLED~.t~i !CE r~F ~c P~'~T!.'n~QT>~Y Jody S Smith Chief Deputy Edward L Schorpp Solicitor 2010 MAC -5 P~ 2~ 36 CLji~.~'i .^ it ~ _rl.1i~3 F t Collins Financial Services, Inc. vs. Jeffrey A. Brandt Case Number 2010-1111 SHERIFF'S RETURN OF SERVICE 03/01/2010 07:20 PM -Stephen Bender, Deputy Sheriff, who being duly sworn according to law, states that on March 1, 2010 at 1920 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Jeffrey A. Brandt, by making known unto Ronny Brandt, Brother of defendant at 850 Mountain Road, Newville, Cumberland County, Pennsylvania 17241 its contents and at the same time handing to him personally the said true and correct copy of the same. Deputies were advised Jeffrey A. Brandt lives in a.cabin and uses 850 Mountain Road, Newville, PA 17241 as his mailing address. STEPHEN BENDER, DEPUTY SHERIFF COST: $49.60 March 02, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF .r! GourTVSUttf:'. S'~P!!`f. TE:I P. 45;x1. In:; 2054421 GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FUNK, ESQUIRE Identification No.: 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 Collins Financial Services, Inc. as assignee of World's Foremost Bank vs. Jeffrey Brandt 1000 MOUNTAIN RD NEWVILLE PA 17241-8504 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET N0. 10-1111 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. ~L Judgment by Default $3,471.26 ~ Money Judgment $ ~ Judgment on Av~ard of Arbitrators$ LL Judgment on Verdict$ IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL ATTORNEYS: FREDERIC I. WEINBERG OR JOEL M. FU NK, ESQUIRES AT THIS TELEPHONE NUMBER: 484/351-050 r 1 PR OTARY ~l/i4/io 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 20544~2~~~,4 '-r J~ ~r ZQ 10 A~'R E 9 F~°~ ~~ ~ 8 Collins Financial Inc. as assignee Foremost Bank vs. Jeffrey Brandt DOCKET N0. 10-1111 PRAECIPE FOR ENTRY OF JUDC~NT FOR WANT OF AN ANSWER ASSESSMENT 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 $3,471.26 Less: Payments on Account ( $.00) Total: $3,471.26 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: Collins FinancialServices, Inc. as assignee of World's Foremost Bank and that the last known address of defendant, Jeffrey Brandt, 1000 MOUNTAIN RD, NEWVILLE PA 17241-8504. 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 . ~I~.00 •PQ 1it7•Y ~ Ir1o73 3. The said defendant (s) is (are) not in the military P'~a~0'lµ~ service of the United States or otherwise within the coverage of the Soldiers and Sailors Civil Relief Act and is (are) over 18 ~~~~~ years of age. Services, COURT OF COMMON PLEAS of World's CUMBERLAND COUNTY AND NOW, this ~q~' day of ADr~I , 2010 Judgment is entered in favor of the plaintiff(s) nd against defendant(s) by default for want of an answer and damages assessed at the sum of , $3,471.26 as per the above tification. ~c Prot ary GORDON & WEINBERG, P. BY: FREDERIC WE'~NBERG, ESQUIRE JOEL M. F INK, ESQUIRE Attornev~for Plaintiff GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 91360 JOEL M. FLINK, ESQUIRE Identification No.: 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19928 484/351-0500 Collins Financial Services, Inc. as assignee of World's Foremost Bank vs. Jeffrey Brandt TO/PARA 2054421 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET N0. 10-1111 NOTICE OF INTENTION TO TAKE DEFAULT Jeffrey Brandt 1000 MOUNTAIN RD NEWVILLE PA 17241-8504 DATE OF NOTICE/FECHA DEL AVISO: March 23, 2010 IMPORTANT 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: ' FREDER jI. WEINBERG, ESQUIRE JOEL FLINK, ESQUIRE P10D-2