HomeMy WebLinkAbout10-22132080038
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
0
Conshohocken, PA 19428
484/351-0500 --?
Y (- 0
ASSET ACCEPTANCE LLC COURT OF COMMON PLEAS-
o#
ASSIGNEE OF GEMB/Whitehall CUMBERLAND COUNTY
28405 VAN DYKE AVE
Warren MI 48093
Vs.
GWENYTH PIERGOFF
403 N WALNUT ST
MECHANICSBURG PA 17055-3379
and
KEVIN S GOFF
403 N WALNUT ST
MECHANICSBURG PA 17055-3379
DOCKET NO. : 10 - 610113 blvi ( iem
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 49a.00 N) ATl
tic 11-3-756
2 J39 f747
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
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 March 8,
2010 in the amount of $4,315.32.
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
9/30/06.
WHEREFORE, plaintiff claims of the defendant(s) the sum of
$4,315.32 plus applicable costs, interest and attorney's fees.
GORDON & WEINBERG, P.C.
BY:
FREDERIC I. EI ERG, ESQUIRE
JOEL M. FLI , ESQUIRE
Attorney for Plaintiff
P01A.DB
«RIFICATION
I hereby state that I am the agent for the plaintiff herein; a-nd that the facts set forth in the
attached Affidavit wluch is incorporated by reference ul the foregoing Complaint in Civil Action
are true and correct to the best of my kno,,vledge, information and belief and is based upon
information wliic.h 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. Tills verification is made subject to
18 Fa.C.S. §4904 which provides for certain penalties for malcing false statements.
Name`) Judy melas1
STATE OF MICHIGAN )
ss
COUNTY OF MACOMB )
ASSET ACCEPTANCE, LLC
Plaintiff,
vs
GWENYTH PIERGOFF KEVIN S GOFF
Defendant,
1, ludv Wasi
AFFIDAVIT
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 $4281.73 representing the charged off
amount and interest.
That the said account originally with /GEMB / Whitehall, account number 5046620225157833, 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.
MACOMB
Public for the State of Michigan, the 08th of February, 2010 as
36839807 INN low I Kim
1064 GORDON & WEINBERG
0 0 3 6 8 3 9 8 0 7
Dated this 08th day of February, 2010.
WAax'?J
- ?\ ? k C? -? Wet Ace ance Representative
Aatl A'4 CYG CrtCt ..
ASSET ACCEPTANCE LLC
P.O. Box 2036
Warren, MI 48090
GWENYTH PIERGOFF KEVIN S GOFF
403 N WALNUT ST
MECHANICSBURG,PA 17055-3379
ACCOUNT NUMBER CURRENT BALANCE
5046620225157833 $4281.73
STATEMENT DATE DUE DATE
FEB 08 2010 DUE
ACCOUNT NUMBER DATE OF LAST PAYMENT
5046620225157833 09/30/06
DATE REFERENCE NO ACCOUNT INFORMATION BALANCE DUE
FEB 08 2010 36839807 BALANCE DUE $4281.73
ASSET ACCEPTANCE LLC, A LIMITED
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* INTEREST RATE
10/25/06 03/31/08 $3772.60 5.00%
SERVICE ADDRESS (IF APPLICABLE) INTEREST DUE AS OF FEB 08 2010
$509.13
*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
\? 36839807
J 1064 GORDON & WEINBERG