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Home My WebLink About10-22122073208 THIS IS AN ARBITRATION MATTER. ASSESSMENT OF DAMAGES HEARING REQUIRED. GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE n r-o Identification No.: 41360 C= -JOEL M. FLINK, ESQUIRE ?: Mi1 ? Identification No.: 41200 r-- 1001 E. Hector Street, Ste 220 ;.` - Conshohocken, PA 19428 _5. 484/351-0500 c."s r N) CACH, LLC COURT OF COMMON PLEAS 4340 SOUTH MONACO STREET, CUMBERLAND COUNTY DENVER,CO 80237 VS. DOCKET NO. : !D - Gala 0.1 v t FFej-#l CARRIE ARNOLD 6995 WERTZVILLE RD MECHANICSBURG PA 17050-1541 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 $4a. Do PQ Arn/ e-"# xAO(ol r~ 1597y(o COMPLAINT IN CIVIL-ACTION 1. Plaintiff, CACH, 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 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 2/12/10 in the amount of $3,035.61. 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 8/20/09. WHEREFORE, plaintiff claims of the defendant(s) the sum of $3,035.61 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDERIC I. EI ERG, ESQUIRE JOEL M. FLIN , ESQUIRE Attorney for Plaintiff PO1P. DB 2073208 14137144 CACH,LLC CARRIE ARNOLD 6019181825440336 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. KARA EGIZI NAME EXHIBIT "A" 2073208 AFFIDAVIT OF CLAIM STATE OF COLORADO ) ss. COUNTY OF D F= N1 V FR- ) I, KARA EG IZI , being first duly sworn on oath or upon affirmation, depose and state that I am the authorized agent and a custodian of record of CACH, LLC, the plaintiff in the case captioned CACH, LLC vs. CARRIE ARNOLD, that I am of legal age with full authority to make the statements contained herein, that I declare under penalty of perjury under the laws of the State of Pennsylvania that the following is true and correct, and if called as a witness I could competently testify to the matters stated herein as follows: 1. I have reviewed the books and records of Plaintiff and am familiar with the account of CARRIE ARNOLD (the "Defendant"). Plaintiff's books and records contain account records and information of the account referenced below provided to Plaintiff by the Original Creditor referenced below or its assignee. The records are kept in the ordinary course of a regularly conducted business activity and are made either by a person having personal knowledge of the information contained therein, and I know from my experience in reviewing such records and from common knowledge of how credit cards work that those records are made and maintained by individuals who have a business duty to make entries in the records accurately at or near the time of the event that they record. 2. The records consist of both hard copy information and electronic information that is generated, stored and maintained in accordance with generally accepted standards in the retail and financial industries by individuals that possess the knowledge and training necessary to ensure the accuracy and reliability of the records. 3. The business records furnished to Plaintiff show that Defendant opened a credit card account with GE MONEY BANK ("Original Creditor") bearing account number 6019181825440336 (the "Account'). The Defendant defaulted in his/her payments to the Original Creditor. 5. For good and valuable consideration, Plaintiff purchased the Account from the Original Creditor or its assignee and Plaintiff is the current creditor of the Account. 6. All credits and payments have been properly applied, Defendant is not entitled to any additional credits or offsets on the account of any kind, and the balance as set forth herein is currently due and owing. 7. There is now due and payable from the Defendant the sum of $2,458.00 plus interest of $450.37 at the rate of 29.99% less credits in the amount of $.00 totaling $2,908.37 as of December 11, 2009. 8. To the best of Affiant's knowledge and based upon information provided by the Original Creditor and a search of the data banks of the Department of Defense Manpower Data Center said Defendant is not in the active military service of the United States. Further Affrant sayeth not. DEC 1 6 7009 Dated this day of , 2009 CACH, LLC By: Print Name: 14 Title: Authorihd'A Cus o ran of Records C? ? ? 6 ?.??ij9 Subscribed and sworn to before me on this day of , 2009 H Notary Public My Commission Expires: yNP ?,4qs QQ•,?"?pTAI?Y ??2- v v My Commission Expires 03/02/2011 Y• :D • O ?OF C0?-O? Department of Defense Manpower Data Center Dec-14-2009 13:57:06 File 0: 601918182544033611 Military Status Report Pursuant to the Service Members Civil Relief Act d Last FirstiMiddle Begin Date Active Duty Status Active Duty End Date Service Name Agency ARNOLD CARRIE Based on the information you have furnished, the DMDC does not possess any information indicating the individual ;status. Upon searching the information data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the current status of the individual as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Service Members Civil Relief Act (50 USC App. §§ 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged' to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL http:/Awow.defenselink.mil/faqlpis/PCOgSLDR.html. If you have evidence the person is on active duty and you fail to obtain this additional Service verification, punitive provisions of the SCRA maybe invoked against you. See 50 USC App. §521(c). If you obtain additional information about the person (e.g.. an SSN, improved accuracy of DOB, a middle name), you can submit your request again at this Web site and we will provide a new certificate for that query. This response reflects active duty status including date the individual was last on active duty, if it was within the preceding 367 days. For historical information, please contact the Service SCRA points-of-contact. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d)(1) for a period of more than 30 consecutive days. In the case of a member of the National Guard, includes service undera call to active service authorized by the President or the Secretary of Defense for a period of more than 30 consecutive days' under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy7ARs, Marine Corps ARs and Coast Guard RPAs. Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps) for a period 'of'more than 30 consecutive days. Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protectionsare based have not been amended to'extend ,the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually 'begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of SCRA extend beyond the last dates of active duty. Those who would rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected. WARNING: This certificate was provided based on a name and SSN provided by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID:U50B6G1MJL SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson , Sheriff ~'[<F~ ~~,~t~,il" of Lauf7~,rrJr?~ ; r ` ~~~i~5t Jody S Smith Chief Deputy _ t~fQ f;~ ~ f ~ ~j~ ~~ ~7 Edward L Schorpp Solicitor ~~Fl~ ,,,~-~, __ ~~`,; Cach, LLC vs. Case Number Carrie Arnold 2010-2212 SHERIFF'S RETURN OF SERVICE 04/08/2010 06:11 PM -Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on Aprii 8, 2010 at 1811 hours, he served a true copy of the within Complaint and Notice upon the within named defendant to wit: Carrie Arnold, by making known unto Tim Arnold, Husband of defendant at 6995 Wertzville Road, Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time handing to him personally the said true and correct copy of the same. ~~ NOAH CLINE, DEPUTY SHERIFF COST: $37.00 April 09, 2010 SO ANSWERS, ( ~~ RON R ANDERSON, SHERIFF 1C1 i,rt1;'."~,a',Ji(n. 'jk1P.t `,(. (~E;1EC:' ;'t. YI?;. `• ~ . 2073208 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 CACH, LLC COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. DOCKET N0. 10-2212 CARRIE ARNOLD 6995 WERTZVILLE RD MECHANICSBURG PA 17050-1541 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. LL Judgment by Default $3,035.61 ~ Money Judgment $ f~ Judgment on Aovard 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 PROTHO Y ~i~~/~ !, CORDON & 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 CACH, LLC vs. CARRIE ARNOLD 2073208 n c~ ~-,'-`~' {~ ,- ,_-_. -r COURT OF COMMON PLEAS~~ ~~ CUMBERLAND COUNTY -~ DOCKET N0. 10-2212 N -., , a ~' ..~~ ~~ ,~~Y ~,? ~, cN..~ - ~' PRAECIPE FOR ENTRY OF JUDGMENT 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 $3,035.61 Less: Payments on Account ( $.00) Total: $3,035.61 Understanding the false statements made herein are subject to ~I~.pp ~~ ~~ penalty under 18 Pa.C.S.A. X4904, Unsworn Falsification to ~fo'1.0o'13a Authorities, I verify that: ~#a4 x581 1. The last known addresses of the parties are: CACH, LLC and that the last known address of defendant, CARRIE ARNOLD, 6995 ~lohCn ~~ WERTZVILLE RD, MECHANICSBURG PA 17050-1541. 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 years of age. 1 AND NOW, this o~~"M day of 2010 Judgment is entered in favor of the plaintiff(s) and against defendant(s) by default for want of an answer and damages assessed at the sum of , $3,035.61 as per the above certi i tion. Prothonotary GORDON & WEINBERG, P~.C. BY: i~\ FREDERIC I. EIN RG, ESQUIRE JOEL M. FL NK SQUIRE Attorney for Plaintiff CORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FUNK, ESQUIRE Identification No.: 91200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 984/351-0500 2073208 CACH, LLC COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. DOCKET NO. 10-2212 CARRIE ARNOLD NOTICE OF INTENTION TO TAKE DEFAULT TO/PARA CARRIE ARNOLD 6995 WERTZVILLE RD MECHANICSBURG PA 17050-1541 DATE OF NOTICE/FECHA DEL AVISO: April 29, 2010 II~ORTANT 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 CORDON & WEINBERG, P.C. B Y : % ~-/ " FREDERId I~ WEINBERG, ESQUIRE JOEL M,: 'FfLINK, ESQUIRE PLOD-2 i i SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor 2911 SEP 30 PM 2: ^ a CUMBERLAND PENI4S 4'LWN t,1! f}, Cach, LLC vs. Case Number Carrie Arnold 2010-2212 SHERIFF'S RETURN OF SERVICE 09/29/2011 01:39 PM - William Cline, Deputy, who being duly sworn according to law, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands, possession, or control of the within named garnishee, Americhoice FCU at 20 Sporting Green Drive, Silver Spring Township, Mechanicsburg, PA 17050, Cumberland County, by handing to CHRISTINE CRUMLIC, TELLER, personally three true and attested copies of the Writ of Execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on September 20, 2011 to Carrie Arnold at 6995 Wertzville Road, Mechancisburg, PA 17050. SHERIFF COST: $117.63 September 30, 2011 SO ANSWERS, /?7 xlllalrz--? RON iam N, SHERIFF Deputy .C, -ownty? SHERIFF'S OFFICE OF CUMBERLAND COUNTY .y R Anderson ,riff ??? „• nt ? tt ai?Gr?,?tjj? ,FT» ?i 6r }LED-OF , 1(, E RR0TH0O l".: Tj°' 2012 PEA Y -3 Ply 2. 14 CUMBERLAND COUNT'( PENNSYLVANIA Body S Smith Chief Deputy Richard W Stewart Solicitor Cach, LLC vs. Carrie Arnold Case Number 2010-2212 SHERIFF'S RETURN OF SERVICE 09/29/2011 01:39 PM - William Cline, Deputy, who being duly sworn according to law, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands, possession, or control of the within named garnishee, Americhoice FCU at 20 Sporting Green Drive, Silver Spring Township, Mechanicsburg, PA 17050, Cumberland County, by handing to CHRISTINE CRUMLIC, TELLER, personally three true and attested copies of the Writ of Execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on September 20, 2011 to Carrie Arnold at 6995 Wertzville Road, Mechancisburg, PA 17050. 05/02/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is returned as ABANDONED. No action on writ in over 6 months. SHERIFF COST: $92.21 SO ANSWERS, May 02, 2012 RbNWY- R ANDERSON, SHERIFF ,5D Z-Z, doe,(" ?Z16 36 c; Cow,* &Ate Shenft Ieleosott Inc