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Home My WebLink About10-5066h 2069876 THIS IS AN ARBITRATION MATTER. ASSESSMENT OF DAMAGES HEARING REQUIRED. GORDON & WEINBERG, P.C. c? BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE C ? Identification No.: 41200 w c' 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 ?-? 484/351-0500 ASSET ACCEPTANCE LLC ASSIGNEE World Financial Network National Bank Warren MI 48093 Vs. KELLY A MANSBARGER 428 PROWELL DR CAMP HILL PA 17011 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. ?? - ?(p CIVI lam 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 O s 0-A . OO p o r'-mq - 1 1507 e aglao 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 July 2, 2010 in the amount of $839.72. 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 10/2/2006. WHEREFORE, plaintiff claims of the defendant(s) the sum of $839.72 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDERIC I. W INBE ESQUIRE JOEL M. FLIN E IRE Attorney for P aintiff 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. Name` Judy Melesi STATE OF MICHIGAN ) ss COUNTY OF MACOMB ) ASSET ACCEPTANCE, LLC Plaintiff, vs KELLY A MANSBARGER Defendant, I Judy Melasi } AFFIDAVIT } } being first duly sworn deposes and states: That I am the Supervisor of ASSET ACCEPTANCE, LLC a Limited Liability company or anized 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 $787.27 representing the charged off amount and interest. That the said account originally with /VICTORIAS SECRET / World Financial Network Nati, account number 000000000888036134, 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 14th day of September, 2009. % Su Sol' Subscribed anti sworn to before me, a Notary Public for the State of Michigan, the 14th of September, 2009 as certified by my hand as set forth immediately below. Notary Public r???.t3lktd ctt,??•? Notrr?? t'uts?;C - ";:?c^hl?an 4A? Crmm:ss!a?« :r.j;its` MACdM6 2013 Acting In Me C:aunt'r cf 384969tK 1%4 (10RDON & WEINBERG 0 0 3 8 4 9 6 9 1 8 ASSET ACCEPTANCE LLC P.O. Box 2036 Warren, MI 48090 KELLY A MANSBARGER 428 PROWELL DR CAMP HILLYA 17011 ACCOUN'T' NUMBER CURRENT BALANCE r 000000000888036134 $787.27 51'ATEMENT DATE DUE DATE SEP 14 20(9 DUE ACCOUNT NUMBER DATE OF LAST PAYMENT 000000000888036134 10/02/06 DATE REFERENCE NO ACCOUNT INFORMATION BALANCE DUE SEP 14 2009 38496918 BALANCE DUE $787.27 ASSET ACCEPTANCE LLC, A LIMITED LIABILITY COMPANY ORGANIZED AM EXISTING UNDER THE LAWS OF THE STATE OF DELAWARE, ASSIGNEE OF 000000000888036134 P.O. Box 2036, Warren, M148090 DATE OF DELINQUENCY PURCHASED ON CHARGE OFF AMOUNT* INTEREST RAT 1210.5106 1 10/29/08 $638.21 10.00%x. SERVICE ADDRESS (IF APPLICABLE) INTEREST DUE AS OF SEP 14 2009 _----...?_-_- 149.06__.___... *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 38496418 tUfrl (3()Rt)DN & WRINI3F•,RG SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson ~, ,~ . Sheriff of un~brr r T~ " ~ ~ r};,; ~~atlta :. '~ Jody S Smith Chief Deputy j~ ~ ~ c ~ L ~ r ~ ~ ~ ~ .~ r `l f ~ ~ ; F ~~~ ~ ,~ ~c 1 o AVG t't q~-t Richard W Stewart ~ ~~ '° 11: ~ Solicitor ~rI~E ~ F T~~ S~SRIFF ~~. Asset Acceptance LLC Case Number vs. Kelly A. Mansbarger 2010-5066 SHERIFF'S RETURN OF SERVICE 08/13/2010 07:05 PM -Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on August 13, 2010 at 1905 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Kelly A. Mansbarger, by making known unto Ward Mansbarger, Husband of defendant at 428 Prowell 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. RYAN BURGETT, D SHERIFF COST: $41.50 August 16, 2010 SO ANSWERS, ~~ (~•C~ ~ RON R ANDERSON, SHERIFF (c) CountySuite Sheriff. Teleosoff, Inc. A 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 20~~-r~FF1CF Vii= ~3`r~ ~%C~1~f~II~~~OT~R.`'+` ~tQI~QC~ ~2 t-`~ t~ ~~ C?l3~~~RL~,~D COURT F`L~~~~°SYL4'~fi~El~ ASSET ACCEPTANCE LLC ASSIGNEE OF VICTORIAS SECRET/World vs. KELLY A MANSBARGER COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET N0. 10-5066 PRAECIPE FOR ENTRY OF JUDGMENT FOR CANT OF AN ANSNER, ASSE33NENT OF DA1~1GE3 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 $839.72 Less: Payments on Account ( $.00) Total: $839.72 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 VICTORIAS SECRET/World and that the last known address of defendant, KELLY A MANSBARGER, 428 PROWELL DR, 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. 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. .~ AND NOW, this ~ day of 2010 Judgment is entered in favor of the plaintiff(s) and against defendant(s) by default for want of an answer and damaged assessed at the sum of , $839.'72 as per the above certificate. n Prothonota GORDON & WEIN$ERG, P.C. BY: FREDERIC I. EI BERG, ESQUIRE JOEL M. FLI ESQUIRE Attorney for Plaintiff ~`iy.oa rid. ~ CK~ / 3 3135/' R ~ ~ ~ Qs'aT ~~~~~~~~ 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 2069876 ASSET ACCEPTANCE LLC ASSIGNEE OF VICTORIAS SECRET/World vs. KELLY A MANSBARGER 428 PROWELL DR CAMP HILL PA 17011 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. 10-5066 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. fXl Judgment by Default $839.72 ~ Moaey Judgment $ ~ 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 1 PROT RY lv~~ ~`~a 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 19928 989/351-0500 ASSET ACCEPTANCE LLC ASSIGNEE OF VICTORIAS SECRET/World vs. KELLY A MANSBARGER TO/PARA 2069876 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET N0. 10-5066 NOTICE OF INTENTION TO TAIL DEFAULT KELLY A MANSBARGER 428 PROWELL DR CAMP HILL PA 17011 DATE OF NOTICE/FECHA DEL AVISO: September 7, 2010 I1~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 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: FREDERI.G/I~'T~1;INBERG, ESQUIRE JOEL NJ': /FLINK, ESQUIRE P10D-2