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Home My WebLink About10-7465 2095545 THIS IS AN ARBITRATION ASSESSMENT OF DAMAGES 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 MATTER. HEARING REQUIRED. C*) C 3 -to rnrt v cn ? D CD x c' -- n' ADVANTAGE ASSETS II, INC. 7322 Southwest Freeway, Houston, TX 77074 VS. DEJAN JAGESIC 1820 CHATHAM DR CAMP HILL PA 17011-5914 COURT OF COMMON PLEAS -' CUMBERLAND COUNTY DOCKET NO. NOTICE Ib-7) ?Ds NO, 0 c7 C-) 1 C4 I w --t rn r- -0m --a° = ? o-? ? LD m 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, 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 oay 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 merchandise 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 October 28, 2010 in the amount of $2,335.07. 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 10/19/2008. WHEREFORE, plaintiff claims of the defendant(s) the sum of $2,335.07 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDERIC I. JOEL M. FLIN Attorney for BEFG, ESQUIRE UIRE intiff P01P.DB 2095545 *281517746 ADVANTAGE ASSETS II, INC. AS ASSIGNEE OF Citibank (South Dakota) N.A. DEJAN JAGESIC 6035320281517746 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 =ISIT "A" ADVANTAGE ASSETS II, (South Dakota) N.A. DEJAN JAGESIC 6035320281517746 State of Texas County of Harris AFFIDAVIT 2095545 INC. AS ASSIGNEE OF Citibank I, LEONARD PRUZANSRY, CEO, 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 $2,335.07 plus interest of $.00 at the rate of 0% less credits in the amount of $.00 totaling $2,335.07 as of October 8, 2010. 5. If called upon, affiant can testify at trial as to the facts pertaining to this matter. The above facts are true and correct to the best of my knowledge, information and belief. NAME : LEONARD PRUZANSRY, CEO Sworn to and Subscribed before me this day of a4del-, 2010 Notary HILDA SAWAGUN Notary Public, State of Texas My Commission Expires May 20, 2014 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff FILQ- fC OF THE PROIHOJ4 n Jody S Smith +? RL Chief Deputy 19010 DEC 20 P11 2:57 Richard W Stewart U$ERLApI Cojpq-rv Solicitor PENNS YLV is Advantage Assets II, Inc. vs. Dejan Jagesic Case Number 2010-7465 SHERIFF'S RETURN OF SERVICE 12/09/2010 06:57 PM - Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on December 9 2010 at 1857 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Dejan Jagesic, by making known unto Hata Jagesic, Mother of defendant at 1820 Chatham Drive, Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $41.50 December 13, 2010 .lam DENNI FRY, 4DK0JT)r SO ANSWERS, RON R ANDERSON, SHERIFF David D. Buell Prothonotary Office of the Prothonotary Cum6errand County, annsyfvania 7rkS. Sofionage, EN, Solicitor• — 71145 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 I Carlisle, TA • (Phone 717 240-6195 0 Ea.K 717 240-6573