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Home My WebLink About10-3108J 2073781 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 N Cif HARVEST CREDIT MANAGEMENT VII, LLC assignee of BARCLAYS/APPLE CREDIT 1580 Lincoln Street Denver CO 80203 VS. LORRAINE WARFEL 706 Meadow Drive Camp Hill PA 17011-1719 COURT OF COMMON PL CUMBERLAND COUNTY DOCKET NO. : )C> -NOS NOTICE Z Ev Cw?t-rerm 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 qa co pA A-rry co Ily53r] , 2 41939 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 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 March 10, 2010 in the amount of $3,101.51. 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 12/10/2007. WHEREFORE, plaintiff claims of the defendant(s) the sum of $3,101.51 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: RG, ESQUIRE FREDERIC I. VKQUIRE JOEL M. FLI Attorney fo tiff P01A.DB . 2073781 83238046 HARVEST CREDIT VII, LLC assignee of BARCLAYS/APPLE CREDIT LORRAINE 11ARFEL 5140219000772059 VERIFICATION I hereby state that I am the agent for the plaintiff herein, and that the facts not 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. 54904 which provides for certain penalties for making false statements. EXHIBIT "A" . 1982 2073781 RB238046 EARNEST CREDIT VII, LLC assignee of BARCLAYS/APPLE CREDIT LORRAINB MJML 5140219000772059 David Ravin AFFIDAVIT I, , being duly served sworn according to law, dispose and say that: 1. I am the agent for the Plaintiff herein and I have custody and control of the files relating to this account; 2. 1 have personal knowledge of the facts and circumstances in connection with this case; 3. Plaintiff's files are maintained in the usual and ordinary course of business; 4. This action is based on a claim for breach of contract and that damages are sought as a direct result of said breach; 5. There is now due and owing from defendant to plaintiff, the amount of $2,159.41 plus interest of $839.91 at the rate of 26.99% less credits in the amount of $.00 totaling $2,999.32 as of January 5, 2010. 6. If called upon, affiant can testify at trial as to the facts pertaining to this matter. The above facts are true and correct to the best of my knowledge, information and belief. AFFIANT Sworn to and Subscribed before me this 11 day CA R. O ...0 of 2009 ?o EN otary is ?IR?S 1??1b SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson ~i ~~;~,' i ;' ' '~ ^= tic s ~,~ i'~ ~ - r. ~ Sheriff . ~; ~~rti~,t~, of "l`au+~~,~,~~~~~ Jody S Smith 2~ ~ ~ ~!. i ~~ ~~ s' ~~ Chief Deputy t ~ ~ . ,%, Edward L Schorpp ~'~~ Solicitor ~ G ~ -~<< ..~R~FF ~G~J'~ _ ~ ~ . 1 ~~~~' Harvest Credit Management VII vs. Case Number Lorraine Warfel 2010-3108 SHERIFF'S RETURN OF SERVICE 05/18/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Lorraine Warfel, but was unable to locate her in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant Lorraine Warfel. Anita Weikel, defendants daughter and current resident of 706 Meadow Drive, Camp Hill, PA 17011 advised Deputies Lorraine Warfel is residing in Dauphin County, Pennsylvania. SHERIFF COST: $46.50 SO ANSWERS, May 18, 2010 RON R ANDERSON, SHERIFF ~~OUniySuile ShP,nYf. T~lFasuft. 4?~. (0.1 cuM David 1D. Buell e Ienee Simpson r Prothonotary 15` De p ut y Prothonotary o « Z �� d �'"' Morrow �rkS. Sohonage, ESQ. E.�� ' Solicitor 7750 2nd Deputy Prothonotary Office of the Prothonotary Cumberland County, Pennsylvania lD '73/08 CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 29TH DAY OF OCTOBER, 2013,AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE-THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R.C.P.230.2. BY THE COURT, DAVID D. BUELL PROTHONOTARY One Courthouse Square • Suite 100 • Carlisle, P.A. 17013 • (717)240-6195 • 'Fac(717)240-6573