Loading...
HomeMy WebLinkAbout10-7385 2092544 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 CHASE 28405- VAN DYKE AVE Warren MI 48093 vs. DONALD STACHE 501 GLENN ST SHIPPENSBURG PA 17257 COURT OF COMMON PLEAS CUMBERLAND COUNTY ~ o ~ ~ o ~"~ -n r DOCKET NO . : I ~ -~3 p'S u's w C- ..~ ~ ~,- a -Wtcs ~° z = o n ca ~ A o ~~ ~ .s- ~:, :~ ~ ~ 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 P~ ~~q,~ a~ ~# ~`~Iq 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 August 27, 2010 in the amount of $1,381.84. 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 12/17/07. WHEREFORE, plaintiff claims of the defendant(s) the sum of $1,381.84 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDER I. EINBERG, ESQUIRE JOEL M F K, ESQUIRE Attorney for Plaintiff POlA.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 wluch 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. r' Nom' ~Udy Melas~ i ~~~~~ /~ EXHIBIT "A" STATE OF MICHIGAN ) COUNTY OF MACOMB ~ ss ASSET ACCEPTANCE, LLC Plaintiff, vs DONALDSTACHE Defendant, ]UDY MElASI I, ~ 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 $1354.55 representing the charged off amount and interest. That the said account originally with CIRCUIT CITY/CHASE/Circuit City /Chase, account number 1820000016526150, 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 03rd day of August, 2010. Asst cceptanc Representative Subscribed and sworn to before me, a Notary Public for the State of Michigan, the 03rd of August, 2010 as certified by my hand as set forth immediately below. Notary Public MAC1Rirf:N G~IA'~ Ntstdt'/ pubilc - Michigan Macomb bounty N{y Commtsslon Expires Jul 13.2013 Acting in ih~ Cos~niy of 41429732 1064 GORDON & WEINBERG 0 0 4 1 4 2 9 7 3 2 A~{ft Accf OfOnef r.~ ASSET ACCEPTANCE LLC P.O. Box 2036 Warren, MI 48090 DONALDSTACHE 501 GLENN ST SHIPPENSBURG,PA 17257 ACCOUNT NUMBER CURRENT BALANCE 1820000016526150 $1354.55 STATEMENT DATE DUE DATE AUG 03 2010 DUE ACCOUNT NUMBER 1820000016526150 DATE OF LAST PAYMENT 12/17/07 DAT E REFERENCE NO ACCOUNT INFORMATION BALANCE DUE AUG 03 201 0 4 . 1429732 BALANCE DUE ASSET ACCEPTANCE LLC, A LIIvIITED LIABILITY COMPANY ORGANIZED AND $1354.55 EXISTING UNDER THE LAWS OF THE STATE OF DELAWARE, ASSIGNEE OF AALLC/CIRCUIT CITY P.O. Box 2036, Warren, MI 48090 DATE OF DELINQUENCY PURCHASED ON CHARGE OFF AMOUNT* INTEREST RATE 01/21/08 04/19/10 $1006.21 18.00% SERVICE ADDRESS (IF APPLICABLE) INTEREST DUE AS OF AUG 03 2010 $348.34 *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 \~ 41429732 ~J 1064 GORDON & WEINBERG SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson ?? ?.}???-PROTHONOTARY Sheriff Jody S Smith 1?Q DEC _g PM 3: 4 8 Chief Deputy Richard W Stewart CUMBERLAND COUNT Solicitor PENNSYLVANIA Asset Acceptance LLC I Case Number vs. 2010-7385 Donald Stache SHERIFF'S RETURN OF SERVICE 12/02/2010 11:57 AM - William Cline, Corporal, who being duly sworn according to law, states that on December 2, 2010, at 1157 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Donald Stache, by making known unto himself personally, at 501 Glenn Street, Shippensburg, Cumberland County, Pennsylvania 17257 its contents and at the s e time handing to him personally the said true and correct copy of the same. L IAM CLINE, DEPUTY SHERIFF COST: $46.00 December 03, 2010 SO ANSWERS, RON W R ANDERSON, SHERIFF { Davi4 . Buell Prothonotary Office of the Prothonotary Cum 6erlTancf County, Tennsyfvania 7(yrkS. Solionage, ESQ, Solicitor /0 - 73 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 • Suite100 • Carlisle, PA • Phone 717 240-6195 • Ta.x.717 240-6573