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COURT OF COMMON PLEAS NOTICE OF APPEAL
Judicial District, County Of CUMBERLAND FROM
MAGISTERIAL DISTRICT JUDGE JUDGMENT
COMMON PLEAS No. 1/-17-39 f?iI 7n#
NOTICE OF APPEAL
Notice is given that the appellant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the Magisterial District
Judge on the date and in the case referenced below.
NAME OF APPELLANT MAG. DIST NO. NAME OF MDJ
EQUABLE ASCENT FINANCIAL LLC 09-1-01 CHARLES A. CLEMENT JR
ADDRESS OF APPEILAN I CI rY STATE LIP CODL
1120 WEST LAKE COOK ROAD BUFFALO IL 60089
UAl E OF JUDGMENT IN THE CASE OF (Plaintiff) (Defendant)
01/18/11 EQUABLE ASCENT FINANCIAL LLC ?n JOYCE NORRIS
DOCKET No SIGNATUR F APPELLANT ATTORNEYOR AGEChr
CV-610-10 1 i/ 1A/!
This block will be signed ONLY when this notation is required under Pa. If appellant was Clal ant (see Pa. R.C.P. .J. No. 1001(6) in action
R.C.P.D.J. No. 10088.
This Notice of Appeal, when received by the Magisterial District Judge, will before a Magisterial District Judge, A C PLAINT MUST BE FILED
operate as a SUPERSEDEAS to the judgment for possession in this case. within twenty
(20) days after filing the NOTICE of APPPJEAL.
Signature of Prothonotary or Deputy
(This section of form to be used ONLY when appellant was DEFENDANT (see Pa.R.C.P.D.J. No. 1001(7) in action before Magisterial District
Judge. IF NOT USED, detach from copy of notice of appeal to be served upon appellee.
PRAECIPE: To Prothonotary
Enter rule upon appellee(s), to file a complaint in this appeal
Name of appellee(s)
(Common Pleas No. ) within twenty (20) days after service of rule or suffer entry of judgment of non pros.
Signature of appellant or attorney or agent
RULE: To
appellee(s)
Name of appellee(s)
(1) You are notified that a rule is hereby entered upon you to file a complaint in this appeal within twenty (20) days after the date of service
of this rule upon you by personal service or by certified or registered mail.
(2) If you do not file a complaint within this time, a JUDGMENT OF NON PROS MAY BE ENTERED AGAINST YOU.
(3) The date of service of this rule if service was by mail is the date of the mailing.
Date: .20
_
Signature of Prothonotary or Deputy
YOU MUST INCLUDE A COPY OF THE NOTICE OF JUDGMENTITRANSCRIPT FORM WITH THIS NOTICE OF APPEAL.
PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO TILE
AOPC 312-05
Fit EU-OFFIU
THE PROTNONOTAR
2011 FEB 15 AM 9' "
CU LVANIATY
PENNSY
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CI.L* 11111
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COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
Mag. Dist. No: MDJ-09-1-01
MDJ Name: Honorable Charles A. Clement Jr.
Address: Olde Towne Commons
400 Bridge Street, Suite 3
New Cumberland, PA 17070
Telephone: 717-774-5989
Michael Ratchford, Esq.
120 N Keyser Ave
Scranton, PA 18504
Disposition Summary
Docket No Plaintiff Defendant
MJ-091 01 -CV-0000610-201 0 Equable Ascent Financial Joyce Norris
Notice of Judgment/Transcript Civil
Case
Equable Ascent Financial
V.
Joyce Norris
d10 Sr4te
(UW 6wuberlancl, PA 17676
Docket No: MJ-09101-CV-0000610-2010
Case Filed: 11/3/2010
Disposition Disposition Date
Judgment for Defendant 01/18/2011
ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH
THE PROTHONOTARY/CLERK OF COURT OF COMMON PLEAS, CIVIL DIVISION. YOU MUST INCLUDE A COPY OF THIS NOTICE OF
JUDGMENT/TRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL.
EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR MAGISTERIAL DISTRICT JUDGES, IF THE JUDGMENT
HOLDER ELECTS TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUST COME FROM THE
COURT OF COMMON PLEAS AND NO FURTHER PROCESS MAY BE ISSUED BY THE MAGISTERIAL DISTRICT JUDGE.
UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS, ANYONE INTERESTED IN THE JUDGMENT MAY FILE A
REQUEST FOR ENTRY OF SATISFACTION WITH THE MAGISTERIAL DISTRICT JUDGE IF THE JUDGMENT DEBTOR PAYS IN FULL, SETTLES,
OR OTHERWISE COMPLIES WITH THE JUDGMENT.
Date Magisterial District Judge Charles A. Clement Jr.
I certify that this is a true and correct copy of the record of the proceedings containing the judgment.
Date Magisterial District Judge Charles A. Clement Jr.
MDJS 315
Page 1 of 1
Printed: 01/18/2011 3:05:36PM
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
EQUABLE ASCENT
FINANCIAL LLC
1120 W LAKE COOK ROAD
CIVIL ACTION
BUFFALO GROVE, 60089
Plaintiff
vs.
JOYCE NORRIS
210 BRIDGE STREET
New Cumberland PA 17070-2126
Defendant
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NOTICE TO DEFEND
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 to Defend are served, by entering a written appearance personally or by an 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 judgment 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.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE
ABLE TO PROVIDE YOU WITH INFORMATION ON AGENCIES THAT MAY
OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT REDUCED FEE OR NO
FEE.
MIDPENN LEGAL SERVICES
401 EAST LOUTHER STREET
CARLISLE, PA 17013
717-243-9400
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
EQUABLE ASCENT
FINANCIAL LLC CIVIL ACTION
1120 W LAKE COOK ROAD
BUFFALO GROVE, 60089
Plaintiff
NO:
vs.
JOYCE NORRIS
210 BRIDGE STREET
New Cumberland PA 17070-2126
Defendant
COMPLAINT
Plaintiff, EQUABLE ASCENT FINANCIAL LLC, by and through its attorneys,
Edwin A. Abrahamsen & Associates, P.C., complains of the Defendant as follows:
Plaintiff, EQUABLE ASCENT FINANCIAL LLC, (hereinafter "Plaintiff")
is a corporation with a principal place of business located at 1 120 W LAKE COOK
ROAD BUFFALO GROVE, 60089.
2. The Defendant JOYCE NORRIS (hereinafter "Defendant") is an adult
individual residing at 210 BRIDGE STREET New Cumberland PA 17070-2126.
3. At all relevant times herein, Plaintiff was engaged in the business of debt
purchase and collection.
4. Defendant applied for and received a credit card issued by GE CAPITAL
CORP with the account number 6030090205697453.
5. The within account was sold by GE CAPITAL CORP to EQUABLE
ASCENT FINANCIAL LLC for valuable consideration and all rights under said accounts
were assigned to EQUABLE ASCENT FINANCIAL LLC.
6. Use of the GE CAPITAL CORP credit card was subject to the terms of the
Cardmember Agreement, a copy of which was sent to the Defendant along with the credit
card. (See, Credit Card Agreement attached hereto as Exhibit "A")
7. Defendant used the GE CAPITAL CORP credit card account number
6030090205697453, for purchases, cash advances and/or balance transfers.
8. The Defendant was mailed account statements relative to the Defendant's
use of the subject credit card.
9. The Defendant defaulted under the terms of the Agreement by failing and
refusing to make monthly payments on the account as they became due.
10. The Defendant last made a payment on June 20, 2009.
11. The total amount due and owing the Plaintiff including interest, is
$5,409.07.
WHEREFORE, Plaintiff requests judgment in its favor and against
Defendant in the amount of $5,409.07 plus costs of suit and any other relief as the Court
deems just and appropriate.
Edwin A. Ab/hd Assoc.
Michael F. Rsquire
Heather K. Wsquire
Attorney I.D5/207805
120 North KScranton, PA mratchford@
hwoodruff(a?
VERIFICATION
I, Michael F. Ratchford, attorney for Plaintiff, EQUABLE ASCENT FINANCIAL
LLC, am fully familiar with the facts set forth in the within Complaint and am authorized
to make this Verification on behalf of Plaintiff. I Verify that the facts set forth in the
within allegations are true and correct to the best of my knowledge, knowing that any
false statements are punishable by law pursuant to 18 C.S.A. 4904.
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