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Home My WebLink About10-2214.l 2080252 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 ASSET ACCEPTANCE LLC OF BANK OF AMERICA 28405 Van Dyke Ave Warren MI 48093 VS. RAHN B RUDY 1042 HEMLOCK LN ENOLA PA 17025 n a ?-' ASSIGNEE COURT OF COMMON PLEAS CUMBERLAND COUNTY n7? M ti rri DOCKET NO. IC - o lq C,, Term 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 `s 49.1.00 PQ q-rN 115&75 R,l' a59'7+8 r 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 oriqinal 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 $1,164.05. 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 3/11/2009. WHEREFORE, plaintiff claims of the defendant(s) the sum of $1,164.05 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDERIC IN, ErYRBERG, ESQUIRE JOEL M. FLINK, ESQUIRE Attorney for Plaintiff POIA.DB 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 malting this verification. This verification is made subject to 18 Pa.C.S. §4904 which provides for certain penalties for making false statements. Nama_) Judy Melasi EXHIBIT "A" STATE OF MICHIGAN ) COUNTY OF MACOMB ) ASSET ACCEPTANCE, LLC Plaintiff, vs RAHN B RUDY Defendant, 1, 7udy Melasi ss 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 $1122.08 representing the charged off amount and interest. That the said account originally with BANK OF AMERICA/BANK OF AMERICA, account number 4888936164410189, 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 08th day of February, 2010. As Acc t ce epresentative Subscribed and sworn to before me, a Notary Public for the State of Michigan, the 08th of February, 2010 as below. certifieo by moand as set forth immediately MACOMB 39865739 1064 GORDON & WEINBERG 0 0 3 9 8 6 5 7 3 9 ASSET ACCEPTANCE LLC P.O. Box 2036 Warren, MI 48090 RAHN B RUDY 1042 HEMLOCK LN ENOLA,PA 17025 ACCOUNT NUMBER CURRENT BALANCE 4888936164410189 $1122.08 STATEMENT DATE DUE DATE FEB 08 2010 DUE ACCOUNT NUMBER 4888936164410189 DATE OF LAST PAYMENT 03/11/09 DATE REFERENCE NO ACCOUNT INFORMATION BALANCE DUE FEB 08 2010 39865739 BALANCE DUE $1122.08 ASSET ACCEPTANCE LLC, A LIMITED LIABILITY COMPANY ORGANIZED AND EXISTING UNDER THE LAWS OF THE STATE OF DELAWARE, ASSIGNEE OF AALLC/BANK OF AMER P.O. Box 2036, Warren, MI 48090 DATE OF DELINQUENCY PURCHASED ON CHARGE OFF AMOUNT* INTEREST RATE 11/01/08 06/30/09 $981.96 24.00% SERVICE ADDRESS (IF APPLICABLE) INTEREST DUE AS OF FEB 08 2010 $140.12 *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 f 39865739 1064 GORDON & WEINBERG 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 2080252 n C ~t , ~'t? r. N O Li c ~r~ c... -4-+ r_ ~ .~_ ~-'~ ~ ~ •~~- ~ ~::a __~.'-. ~D ~ -- ~'r .. ~._, C: : j -.i -< ASSET ACCEPTANCE LLC ASSIGNEE OF BANK OF AMERICA vs. RAHN B RUDY COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET N0. 10-2214 PRAECIPE FOR ENTRY OF J[JDCML~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 $1,164.05 Less: Payments on Account ( $365.00) Total: $799.05 Understanding the false statements made herein are subject to penalty under 18 Pa.C.S.A. X4904, Unsworn Falsification to Authorities, I verify that: 1. The last known addresses of the parties are: ASSET ACCEPTANCE LLCASSIGNEE OF BANK OF AMERICA and that the last known address of defendant, RAHN B RUDY, 1042 HEMLOCK LN, ENOLA PA 17025. 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 service of the United States or otherwise within the Soldiers and Sailors Civil Relief Act and is years of age. the military the coverage of (are) over 18 ~ ~H ¢iy- ~ v ~ ~ l i-l LYS z+~,r.`l3 y3 7 /yoftc ,~.4;<<d ~j ~(.- AND NOW, this / day of ~~ 2010 Judgment is entered in favor of the plaintiff(s) d against defendant(s) by default for want of an answer and damages assessed at the sum of , 5799.05 as per the above cer ification. Prothonotary GORDON & WEIN ERG P.C. BY: ~ / ) FREDERIC ~~EINBERG, ESQUIRE JOEL M. FLINK, ESQUIRE Attorney for Plaintiff 2080252 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 BANK OF AMERICA COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. RAHN B RUDY 1042 HEMLOCK LN ENOLA PA 17025 DOCKET N0. 10-2214 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. ~ Judgment by Default $799.05 ~L Money Judgment $ t,~ Judgment on Allard of Arbitratora$ ,~ 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 PRO HONOTARY 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 BANK OF AMERICA vs. RAHN B RUDY 2080252 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET N0. 10-2219 NOTICE OF INTENTION TO TAIO; DEFAULT TO/PARA . RAHN B RUDY 1042 HEMLOCK LN ENOLA PA 17025 DATE OF NOTICE/FECHA DEL AVISO: May 13, 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 NIAY 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: FREDERI ~."WEINBERG, ESQUIRE JOEL SLINK, ESQUIRE P10D-2 2080252 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 BANK OF AMERICA COURT OF COMMON PLEAS CUMBERLAND COUNTY VS. RAHN B RUDY DOCKET NO. : 10-2214 Cam. '?{ ORD=R TO Sl?TI8lS JO3Ni8?'t' ?' ? ? j 7 ?,t TO THE PROTHONOTARY: ?. Kindly mark the judgment entered June 9, 2010 in th6Zabr?" captioned matter satisfied upon payment of your costs only. GORDON & WEINBERG, P.C. BY: FREDERIC W )tINBERG, ESQUIRE JOEL M. LI ESQUIRE Attorney or Plaintiff P005 48.00 Pa A?r1