The URL can be used to link to this page

Home My WebLink About10-18542080039 THIS IS AN ARBITRATION MATTER. ASSESSMENT OF 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 " =. = rn 5 1 ASSET ACCEPTANCE LLC ASSIGNEE COURT OF COMMON Z- PLEAS OF GEMB/Auto Pride IWDI 28405 VAN DYKE AVE Warren MI 48093 Vs. MICHAEL SPADAFORE 115 MOUNTAIN VIEW DR ENOLA PA 17025 CUMBERLAND COUNTY DOCKET NO. : to ^ 15!5q 0'w II -1 em CCWI AINT IN ASSMeSIT 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 Qi) *ga.oo Qa Al'/ Cepia &- a 38931 r 1. Plaintiff is a debt buyer and successor in interest to the original creditor as set forth in the caption of this Complaint. 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 $1,487.41 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 March 8, 2010 in the amount of $1,487.41. 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 4/3/06. WHEREFORE, plaintiff claims of the defendant(s) the sum of $1,487.41 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDERIC . WEI ERG, ESQUIRE JOEL M. FL , ESQUIRE Attorney for Plaintiff P01C.DB «RIFICATION I hereby state that I am the agent for the plaintiffhereuh, and that the facts set forth in the at-tache.d Affidavit which is incorporated by reference in the foregoing Complaint vh Civil Action are true and con-ect to the best of my knowledge, i?hfonnation and belief and is based upon fl fonl,ation wl>ich 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. Tliis verification is made subject to 18 Pa.C.S. §4904 which provides for certain penalties for making false statements. 1 Naine`) J JUdy Heusi EXHIBIT "An STATE OF MICHIGAN ) ss COUNTY OF MACOMB ) ASSET ACCEPTANCE, LLC Plaintiff, vs MICHAEL SPADAFORE Defendant, AFFIDAVIT 1, Judy Melasi being first duly sworn deposes and states: That I am a representative 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 $1476.06 representing the charged off amount and interest. That the said account originally with /GEMB / Auto Pride IWDI, account number 6019180032027605, 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. Public for the State of Michigan, the 08th of February, 2010 as 1,,... MACOMB 36843829 1064 GORDON & WEINBERG 1111111 1 0 0 3 6 8 4 3 8 2 9 Dated this 08th day of February, 2010. oilob ;?sset Ac p ce Representative A-P ACEiclunt• , ASSET ACCEPTANCE LLC P.O. Box 2036 Warren, MI 48090 MICHAEL SPADAFORE 115 MOUNTAIN VIEW DR ENOLAXA 17025 ACCOUNT NUMBER 6019180032027605 ACCOUNT NUMBER 6019180032027605 STATEMENT DATE FEB 08 2010 CURRENT BALANCE $1476.06 DUE DATE DUE DATE OF LAST PAYMENT 04/03/06 DATE REFERENCE NO ACCOUNT INFORMATION FEB 08 2010 36843829 BALANCE DUE BALANCE DUE ASSET ACCEPTANCE LLC, A LIMITED $1476.06 LIABILITY COMPANY ORGANIZED AND EXISTING UNDER THE LAWS OF THE STATE OF DELAWARE, ASSIGNEE OF AALLC/GE MONEY BAN P.O. Box 2036, Warren, MI 48090 DATE OF DELINQUENCY PURCHASED ON CHARGE OFF AMOUNT* 05/04/06 INTEREST RATE 03/31 /08 $1274.15 5.00% SERVICE ADDRESS (IF APPLICABLE) INTEREST DUE AS OF FEB 08 2010 $201.91 *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 36843829 1064 GORDON & WEINBERG SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ~et'~Q-C~r~~ Jody S Smith ~°' ~''~~ ""'~~~ Chief Deputy ~~~~~~~ ~~ ~~~ ~, ~t~ Edward L Schorpp Solicitor ~E . i - - G - ~ ~ F<.~,: Asset Acceptance LLC vs. Case Number Michael Spadafore 2010-1854 SHERIFF'S RETURN OF SERVICE 03/16/2010 07:27 PM -Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on March 16, 2010 at 1927 hours, she served a true copy of the within Complaint in Assumpsit, upon the within named defendant, to wit: Michael Spadafore, by making known unto Tracy Spadafore, Wife of defendant at 115 Mountain View Drive, Enola, Cumberland County, Pennsylvania 17025 its contents and at the same time handing to her personally the said true and correct copy of the same. AM NDA COBAUGH, DEPU SHERIFF COST: $41.50 March 18, 2010 SO ANSWERS, ~"~`~-. RON R ANDERSON, SHERIFF (ci Coun-~,Suit yh~-'ti. TEel~osoft. In;~.