HomeMy WebLinkAbout10-46122084275
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
Conshohocken, PA 19428
484/351-0500
ASSET ACCEPTANCE LLC ASSIGNEE
OF CITIBANK (SOUTH DAKOTA),
28405 VAN DYKE AVE
Warren MI 48093
VS.
PATRICK BASOM
103 N 21ST ST
CAMP HILL PA 17011
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
DOCKET NO. : /0 _ L /
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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
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 ofd April 29, 2010
in the amount of $9,375.15.
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.
f
7. Defendant's last payment on account was made on 7/20/07.
WHEREFORE, plaintiff claims of the defendant(s) the sum of
$9,375.15 plus applicable costs, interest and attorney's fees.
GORDON & WEINBERG, P.C.
BY:
FREDERIC I. EIN RG, ESQUIRE
JOEL M. FL K, SQUIRE
Attorney for Plaintiff
P01A.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 making this verification. This verification is made subject to
18 Pa.C.S. §4904 which provides for certain penalties for making false statements.
NmJudy Melasi
STATE OF MICHIGAN )
ss
COUNTY OF MACOMB )
ASSET ACCEPTANCE, LLC
Plaintiff,
vs
PATRICK BASOM
r
Defenda1WWJJ
nt,, V [AELASI
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 $9157.58 representing the charged off
amount and interest.
That the said account originally with CITIBANK/, account number 5424180621624136, 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 29th day of March, 2010.
et ccep Kce Representative
Subscribed and sworn to before me, a Notary Public for the State of Michigan, the 29th of March, 2010 as
certified by my hand as set forth immediately below.
Notary Public
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40162807
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ASSET ACCEPTANCE LLC
P.O. Box 2036
Warren, MI 48090
PATRICK BASOM
103 N 21 ST ST
CAMP HILL,PA 17011
ACCOUNT NUMBER CURRENT BALANCE
5424180621624136 $9157.58
STATEMENT DATE DUE DATE
MAR 29 2010 DUE
ACCOUNT NUMBER
5424180621624136
DATE
MAR 29 2010
DATE OF LAST PAYMENT
07/20/07
REFERENCE NO I ACCOUNT INFORMATION
40162807 BALANCE DUE -
ASSET ACCEPTANCE LLC, A LIMITED
LIABILITY COMPANY ORGANIZED AND
EXISTING UNDER THE LAWS OF THE
STATE OF DELAWARE, ASSIGNEE OF
AALLC/CITIBANK 8/0
P.O. Box 2036, Warren, MI 48090
BALANCE DUE
9157.58
DATE OF DELINQUENCY PURCHASED ON CHARGE OFF AMOUNT* INTEREST RATE
08/17/07 09/10/09 $6127.65 24.00%
SERVICE ADDRESS (IF APPLICABLE) INTEREST DUE AS OF
MAR 29 2010
$3029.93
*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
--S?f
40162807
1-) 1064 GORDON & WEINBERG
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
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Jody S Smith Q~,tw o~ +~rrrn~r~.r~
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Chief Deputy O. -~ ~,- ~?'~} (
Richard W Stewart
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Solicitor
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Asset Acceptance LLC
vs. Case Number
Patrick A. Basom 2010-4612
SHERIFF'S RETURN OF SERVICE
07/26/2010 04:32 PM -Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on July
26, 2010 at 1632 hours, she served a true copy of the within Complaint and Notice, upon the within namec
defendant, to wit: Patrick A. Basom, by making known unto himself personally, at McDonald's, 1 Lemoyne
Drive, Lemoyne, Cumberland County, Pennsylvania 17043 its contents and at the same time handing to
him personally the said true and con'ect copy of the same.
AMA DA COBAUGH, DEPUTY
SHERIFF COST: $55.90
July 27, 2010
SO ANSWERS,
RON R ANDERSON, SHERIFF
(cj CountySuite Sheriff, Teleosoft, Inc.
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
2084~r'~`~t_~~: Fl~E
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ASSET ACCEPTANCE LLC ASSIGNEE
OF CITIBANK (SOUTH DAKOTA),
vs.
PATRICK BASOM
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
DOCKET N0. 10-4612
PRAECIPE FOR ENTRY OF JUDC;~NT FOR PANT OF AN ANS9PER A33E33MLNT
OF DAMAGE, VERIFICATION OF ADDRE33 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 $9,375.15
Less: Payments on Account ( $.00)
Total: $9,375.15
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 CITIBANK (SOUTH DAKOTA), and that the last
known address of defendant, PATRICK BASOM, 103 N 21ST ST, CAMP HILL PA
17011.
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. ~~~.,ppppA'IT`~
~~ l3~sa
3. The said defendant (s) is (are) not in the military (Z~~19![P~
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. ~~
AND NOW, this _ ~'~ day of u:~ 2010 Judgment
is entered in favor of the plaintiff(s) and against defendant(s) by
default for ~3ant of an answer and damages assessed at the sum of ,
$9,375.15 as per the above certification. ,..
Prothonotary
GORDON & WEINBERG, P.C.
BY:
FREDERIC I. EIN ERG, ESQUIRE
JOEL M. FLI K, SQUIRE
Attorney fo laintiff
2084275
GORDON & WEINBERG, P.C.
BY: FREDERI~ 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 CITIBANK (SOUTH DAKOTA),
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
vs.
PATRICK BASOM
103 N 21ST ST
CAMP HILL PA 17011
DOCKET N0. 10-4612
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.
fRL Judgment by Default $9,375.15
~ Monsy Judgment $
~ Judgment on Aaard 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
PR THONOTARY
,0,1,0
2084275
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
CITIBANK (SOUTH DAKOTA),
vs.
PATRICK BASOM
TO/PARA
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
DOCKET N0. 10-4612
NOTICE OF INTENTION TO TAIL DEFAULT
PATRICK BASOM
103N21STST
CAMP HILL PA 1701 I
DATE OF NOTICE/FECHA DEL AVISO: August 31, 2010
IMPORTANT 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
GORDON & WEINBERG, P.C.
BY:
FREDERIC WEIN ERG, ESQUIRE
JOEL M. LIN SQUIRE
PLOD-2
2084275
GORDON & WEINBERG, P.C.
BY: FREDERIC I. WEINBERG, ESQUIRE ? ,.;, T
Identification No.: 41360 ?
rn% ? rn
JOEL M. FLINK, ESQUIRE
03
Identification No.: 81894
1001 E. Hector Street, Ste 220
Conshohocken, PA 19428 ?C' n
?
484/351-0500 C- N) °
co
-,
ASSET ACCEPTANCE LLC ASSIGNEE COURT OF COMMON PLEAS
OF CITIBANK (SOUTH DAKOTA), CUMBERLAND COUNTY
VS. DOCKET NO. : 10-4612
PATRICK BASOM
SUGGESTION OF BANKRUPTCY OF DEFENDANT
TO THE PROTHONOTARY:
AND NOW, this February 22, 2012, it is suggested of record
that Defendant, PATRICK BASOM, filed a petition in bankruptcy
under Chapter 7 of the Bankruptcy Code on or about February 17,
2012, in the United States Bankruptcy Court for the Middle
District of Pennsylvania, docket number 12-00922. Therefore,
this matter should be stayed until further notice.
GORDON & WEINBERG, P.C.
BY:
Z--
FREDERII I. INBERG, ESQUIRE
JOEL ESQUIRE
Attorney for Plaintiff