The URL can be used to link to this page

Home My WebLink About10-35942081419 THIS IS AN ARBITRATION MATTER. ASSESSMENT OF DAMAGES HEARTNt"-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 FLED4YF GE OF VE PR7HOWT'ARY 2010 JUN -I PM 3: 12 CUMBERLAND COLM PEiOSYt.VANA ADVANTAGE ASSETS II, INC. 7322 Southwest Freeway, Houston, TX 77074 Vs. JENENE P MARTELL 9 COLUMBIA DR CAMP HILL PA 17011-7634 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. ?II 3 s?y C f erica 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 cy.L'o0 Pd. "?y J-y? 9W COMPLAINT IN CIVIL-ACTION 1. Plaintiff, ADVANTAGE ASSETS II, INC. a debt buyer and successor in interest to the original creditor, Citibank (South Dakota) N.A.. 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 3/18/10 in the amount of $2,533.19. 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 7/2/08. WHEREFORE, plaintiff claims of the defendant(s) the sum of $2,533.19 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDERIC I. EIN G, ESQUIRE JOEL M. FLI SQUIRE Attorney for Plaintiff POIP.DB 2081419 *487658484 ADVANTAGE ASSETS II, INC. AS ASSIGNEE OF Citibank (South Dakota) N.A. JENENE P MARTELL 6035320487658484 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. LEONARD PRUZANSKY, O ADVANTAGE ASSETS II, (South Dakota) N.A. JENENE P MARTELL 6035320487658484 State of Texas County of Harris AFFIDAVIT 2081419 INC. AS ASSIGNEE OF Citibank I, Leonard Pruzansky, being duly served sworn according to law, depose 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. Plaintiff's files are maintained in the usual and ordinary course of business; 3. This action is based on a claim for breach of contract and that damages are sought as a direct result of said breach; 4. There is now due and owing from defendant to plaintiff, the amount of $2,533.19 plus interest of $.00 at the rate of 0% less credits in the amount of $.00 totaling $2,533.19 as of March 2, 2010. 5. If called upon, affiant can testify at trial as to the facts pertaining to this matter. The above facts are true and correct to the best of my knowledge, information and belief. Sworn to and Subscribed before me this day of 2010 LEONARD PRUZANSKY, CEO ESTRELLA SAHAGUN Notary Public, State of Texas My Commission Expires December 17, 2013 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ~atiti~~tr of ~lunbrrf~~$ ~~ }} ,, ~~.j 5L-Y~ ti V~#~t t7FFiCE ~:" 4NE: SrERlFF FILES ~U'i-,1;,~ Jody S Smith Chief Deputy Advantage Assetts II, Inc. vs. Jenene P. Martell 2Dl0 Ji~~~ -9 ~~ 8~ ~~ S~ ~ ; a!i ({~~ ~4JIYtlti'~ r,~'.~I,d t p~ `t. VtY 1 t'L I ~3tiil`€~V~~' Vk~ Case Number 2010-3594 SHERIFF'S RETURN OF SERVICE 06/04/2010 07:43 PM -Stephen Bender, Deputy Sheriff, who being duly sworn according to law, states that on June 4 2010 at 1935 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Jenene P. Martell, by making known unto Gary Martell, Husband of defendant at 9 Columbia Drive, Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $41.50 June 07, 2010 ~~,~~y,,`""_ STEPHEN BENDER, DEPUTY SO ANSWERS, RON R ANDERSON, SHERIFF (c) CountySuite Sheriff. Teleosoft. Inc. CORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FUNK, ESQUIRE Identification No.: 81894 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 2081419 ADVANTAGE ASSETS II, INC. vs. JENENE P MARTELL COURT OF COMMON PLEAS CUP•1BERLAND COUNTY DOCKET N0. 10-3594 CI~~ILr~-a r _.~ ~~ ^e' ~~: i°r7 ~= ~:~~ + ~'~ :~7 _._1 t=~ ~'Tl X7-3 ~~ri ~~ :~ ~.~ ., =''~ -„ ~s tfi ., ~. ,~, cry ~ ra ,.' _.~,. ~_ v i ~ ~ ^~ SUGGESTION OF BANKRUPTCY OF DEFENDANT ~'~ =A TO THE PROTHONOTARY: :lam ~ o ...~ ._-~ AND NOW, this September 14, 2010, it is suggested of record that Defendant, JENENE P MARTELL, filed a petition in bankruptcy under Chapter 13 of the Bankruptcy Code on or about August 16, 2010, in the United States Bankruptcy Court for the Middle District of Pennsylvania, docket number 10-06672. Therefore, this matter should be stayed until further notice. CORDON & WEINBERG, P.C. BY: FREDERIC WE BERG, ESQUIRE JOEL M. LI ESQUIRE Attorney `tor Plaintiff David D. BueC (Prothonotary Office of the Prothonotary Cum6er[anddCounty, annsyfvania 7(irkS. Sohonage, ESQ Solicitor -3591/ CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 28TH DAY OF OCTOBER, 2014, 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 0 Suite100 0 CarCisCe, TA 0 Phone 717 240-6195 0 Ea. -k; 717 240-6573