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Home My WebLink About10-4987r, 2085379 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 h.? C`3 c? Cr Ile C-,) CD ADVANTAGE ASSETS II, INC. 7322 Southwest Freeway Houston, TX 77074 VS. CHARLES V GETHOUAS 421 4TH ST NEW CUMBERLAND PA 17070-1802 ?7 d C., COURT OF COMMON PLEAS CUMBERLAND COUNTY -C DOCKET NO. ?? - 44481 (2;tV11 1iGIrM 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 4?J 0A.00 Pa Ayr-y C* 11.15 R? a?Ilob70 I 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 May 26, 2010 in the amount of $3,770.37. 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 2/3/2009. WHEREFORE, plaintiff claims of the defendant(s) the sum of $3,770.37 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDERIC I. EIN RG, ESQUIRE JOEL M. FLIN SQUIRE Attorney for Plaintiff P01P. DB 2085379 *262025008 ADVANTAGE ASSETS II, INC. AS ASSIGNEE OF Citibank (South Dakota) N.A. CHARLES V GETHOUAS 6035320262025008 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, CEO ADVANTAGE ASSETS II, (South Dakota) N.A. CHARLES V GETHOUAS 6035320262025008 State of Texas County of Harris § AFFIDAVIT 2085379 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 $3,770.37 plus interest of $.00 at the rate of 0* less credits in the amount of $.00 totaling $3,770.37 as of April 14, 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. LEONARD 2PRUZANSCEO Sworn to and Subscribed before me this day ?PURY ??? ? =?o;• ?,= ESTREIIASAHAGUN of , . Notary Public, State of Texas 2010 My Commission Expires December 17, 2013 Els)-6- Notary Public SHERIFF'S OFFICE OF CUMBERLAND COUNTY Sheriff R Anderson ~~ ,~ Q~ ~~~ptr of ~~+~bc~~~ ~ ~, , W Chaef Depruty '`~;`y ~ E ~ ~~. ~ ~ 1 AM 8' ~ ~ ~~ ; F'.- . } ~ ~ ,._<,~ { ~t Richard W Stewart °`°' Solicitor f gee F -~~ ~.,~R~F~ ~~p~YIVA~ Advantage Assets II, Inc. Case Number vs. 2010-4987 Charles V. Gethouas SHERIFF'S RETURN OF SERVICE 08/18/2010 04:15 PM -William Cline, Corporal, who being duly sworn according to law, states that on August 18, 2010 at 1615 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Charles V. Gethouas, by making known unto Nicholas Gethouas, Son of defendant at 421 Fourth Street, New Cumberland, Cumberland County, Pennsylvania 17070 ~ contents and at the same time handing to him personally the said true and correct copy of the sa ILLIAM CLINE, DEPUTY SHERIFF COST: $43.30 August 26, 2010 SO ANSWERS, ~~ RON R ANDERSON, SHERIFF (ej CountySuite Sheriff. Telsosoft, 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 !J l" ~i~0r :?1\V t ~EO~YO INI~~Y~ 2oi~ Oc~ ~ z P ~: ~~ ~'U~~C~RL~~~O COUNTY ~~f~edSYL~'~,~~i,^, ADVANTAGE ASSETS II, INC. vs. CHARLES V GETHOUAS COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. 10-4987 PRAECIPE FOR ENTRY OF JUDG~NT FOR ~PAN'1' OF AN AN39~ER. A33E33NENT OF DA~1GE3. 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 $3,770.37 Less: Payments on Account ( $.00) Total: $3,770.37 Understanding the false statements made herein are subject to penalty under 18 Pa.C.S.A. §4904, Unsworn Falsification to Authorities, I verify that: 1. The last known addresses of the parties are: ADVANTAGE ASSETS II, INC. and that the last known address of defendant, CHARLES V GETHOUAS, 421 4TH ST, NEW CUMBERLAND PA 17070-1802. 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 the military 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. r AND NOW, this ~ Z= `~ ay of ~r'~ ~ 2010 Judgment is entered in favor of the plaintiff(s) and against defendant(s) by default for want of an answer and damages assessed at the sum of , $3,770.37 as per the above certifi t' n. Prothonota GORDON & WEIN RG, P.C. BY: FREDERIC I WE BERG, ESQUIRE JOEL M. F INK ESQUIRE Attorney Plaintiff «~~ ~~ cad 37~y ~adE a4~4so~ , ~cc,~ rn~.~ ~~ 2085379 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 ADVANTAGE ASSETS II, INC. COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. DOCKET NO. 10-4987 CHARLES V GETHOUAS 421 4TH ST NEW CUMBERLAND PA 17070-1802 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. f R~ Judgment by Default $3, 770.37 ~ Money Judgment $ ~ Judgment on ANard 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 /1 PROT~~fiARY lO~~~ IV 2085379 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 4841351-0500 ADVANTAGE ASSETS II, INC. vs. CHARLES V GETHOUAS TO/PARA COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET N0. 10-4987 NOTICE OF INTENTION TO TAKE DEFAULT CHARLES V GETHOUAS 421 4TH ST NEW CUMBERLAND PA 17070-1802 DATE OF NOTICE/FECHA DEL AVISO: September 8, 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 WEINBERG, ESQUIRE JOEL M. F NK, ESQUIRE P10D-2