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Home My WebLink About10-58462085121 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 ASSET ACCEPTANCE LLC ASSIGNEE OF CHASE BANK 28405 Van Dyke Ave Warren MI 48093 VS. KENNETH FIGUEROA 36 N 41ST ST CAMP HILL PA 17011 ASSESSMENT OF s M? cn ?t { z v ' ? - C 7 o COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : /O _ etu?C'T T 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 C9) ,Y4-. oo?:L co laet[g 2- a?g/ice 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 May 5, 2010 in the amount of $2,424.15. 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. 7. Defendant's last payment on account was made on 5/6/2007. WHEREFORE, plaintiff claims of the defendant(s) the sum of $2,424.15 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. N BY: FREDERIC I. WEI ERG, ESQUIRE JOEL M. FLI , ESQUIRE 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 atlached Affidavit wlveh is incorporated by reference in the foregoing Complaint in Civil Action ale true and con-e.ct to the. best of my knowledge, information and belief and is based upon infonnaiion v,dvch plaintiff has f unshed to counsel. The langZiage 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 malting false statements. Name Deann6,-Ja EXHIBIT "A" STATE OF MICHIGAN ) ss COUNTY OF MACOMB ) ASSET ACCEPTANCE, LLC Plaintiff, vs KENNETH FIGUEROA AFFIDAVIT Defendant, Deanna Jason ) I, 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 $2397.25 representing the charged off amount and interest. That the said account originally with CHASE BANK/FIRST USA, account number 4266841075719391, 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. s 07th day of April, 2010. by L?fl and sworn to before r s set (forth immAedi. ) "IYI , i/1 Pu r;??yne Co.anYy rr. rs S P 2, 201 Fac'?;;,9 in qhe Ccsnf?? c=t otary Public for the State of Michigan, the 07th of April, 2010 as certified ow. 40121397 moll I IS INI 1064 GORDON & WEINBERG ? III =1 I 0 0 4 0 1 2 1 3 9 7 M1nsak Ax:_ mince ASSET ACCEPTANCE LLC P.O. Box 2036 Warren, MI 48090 KENNETH FIGUEROA 36 N 41ST ST CAMP HILL,PA 17011 ACCOUNT NUMBER CURRENT BALANCE 4266841075719391 $2397.25 STATEMENT DATE DUE DATE APR 07 2010 DUE ACCOUNT NUMBER DATE OF LAST PAYMENT 4266841075719391 05/06/07 DATE REFERENCE NO ACCOUNT INFORMATION BALANCE DUE APR 07 2010 40121397 BALANCE DUE $2397.25 ASSET ACCEPTANCE LLC, A LIMITED LIABILITY COMPANY ORGANIZED AND EXISTING UNDER THE LAWS OF THE STATE OF DELAWARE, ASSIGNEE OF AALLC/CHASE 8/09 P.O. Box 2036, Warren, MI 48090 DATE OF DELINQUENCY PURCHASED ON CHARGE OFF AMOUNT* INTEREST RATE 06/12/07 08/27/09 $1704.57 18.00% SERVICE ADDRESS (IF APPLICABLE) INTEREST DUE AS OF APR 07 2010 $692.68 *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 40121397 1064 GORDON & WEINBERG SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ~~„ ~titr n' ~at,r~4r~»~~~~4 Jody S Smith .~ Chief Deputy s Richard W Stewart Solicitor c~~~~F ~~F T~~ ~ ~~a~~~ Asset Acceptance LLC vs. Case Number Kenneth Figueroa 2010-5846 SHERIFF'S RETURN OF SERVICE 09/24/2010 04:08 PM -Stephen Bender, Deputy Sheriff, who being duly sworn according to law, states that on September 24, 2010 at 1608 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Kenneth Figueroa, by making known unto himself personally, at 36 N. 41st Street, 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 September 28, 2010 4~~ STEPHEN BENDER, DEPUTY SO ANSWERS, RON R ANDERSON, SHERIFF ~-~ .~ ;.~. ~ ~ ' ! 1 ~- ~==' ~ _~z~': cn r` ~ ~.< `~' =C - __~ r.~ ~ -,-, ~ c-~ ~ w.~ o ~ s~ ~ ~ ~ i ~ ~ ~; y. ~ _.~; ~ ici Ceunf,Su~t~ ShPn'f. Telco=oft. ~irc_ 2085121 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 r? A-3 _V- Conshohocken, PA 19428 -'' 4841351-0500 -TI ASSET ACCEPTANCE LLC ASSIGNEE COURT OF COMMON PLEAS OF CHASE BANK CUMBERLAND COUNTY - -"' VS. DOCKET NO. : 10-5846 KENNETH FIGUEROA N8: BRAECIBE F01t ENTRY OF JUDMM FM =NT OF Ali AESM, AS3E881f8NT OF DAMMS, VMIFI TIDE OF ADD 8 MW -MILITIIR 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 $2,424.15 Less: Payments on Account ( $.00) Total: $2,424.15 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: ASSET ACCEPTANCE LLCASSIGNEE OF CHASE BANK and that the last known address of defendant, KENNETH FIGUEROA, 36 N 41ST 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. 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 /S day of 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 , $2,424.15 as per the :xboe cert'fic a ion. t' %An A A (1, A01A P othonotary GORDON & EINBE , P.C. BY: FREDE IC I WEINBERG, ESQUIRE JOEL INK, ESQUIRE Attorney for Plaintiff 2085121 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 CHASE BANK VS. KENNETH FIGUEROA 36 N 41ST ST CAMP HILL PA 17011 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 10-5846 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. /at Judgment by Default $2,424.15 S//Q 11 Money Judgment $ 1,1, Judgment on Award 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 2085121 GORDON & WEINBERG, P.C. BY: FREDERIG 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 CHASE BANK VS. KENNETH FIGUEROA TO/PARA COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 10-5846 NOTICE OF INTENTION TO TAKE DEFAULT KENNETH FIGUEROA 36 N 41ST ST CAMP HILL PA 17011 DATE OF NOTICE/FECHA DEL AVISO: October 15, 2010 I24PORTANT 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 I/.; E NBERG, ESQUIRE JOEL M. FLZNK, ESQUIRE PLOD-2 pia. #,y.?o lAl 011W -?Uoffl W, "n O'lo micbd