The URL can be used to link to this page

Home My WebLink About11-2506 2088244 `z? -- ~--? THIS IS AN ARBITRATION MATTER. ASSES' N 'I? Ff" DAMAGES HEARING REQUIRED. `r? N GORDON & WEINBERG, P.C. -' co 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 Atlantic Credit & Finance Assignee from HSBC 2727 Franklin Road Roanoke, VA 24014 Vs. COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : !'-- ;Sft N, I JOAN CORSON 125 AIRPORT RD SHIPPENSBURG PA 17257 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 r'p# a 5-slq 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 February 7, 2011 in the amount of $1,511.61. 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 1/12/2009. WHEREFORE, plaintiff claims of the defendant(s) the sum of $1,511.61 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDERIC I. W NBERG, ESQUIRE JOEL M. FL , 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 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. IN CLEM- EXHIBIT "A" ATLANTIC CREDIT & FINANCE, INC. C1 V. JOAN CORSON AFFIDAVIT OF DEBT AND VERIFIED BILL OF PARTICULARS The undersigned being first duly sworn according to law, deposes and says that with the policies and practices, as well as the books and records of the PIaintiff'w' stated herein, and based on information and belief states as follows. • they are familiar zth respect to the matters I. Plaintiff's principal business consists of purchasing charged off receivables. 2- The Defendant defaulted on HS.g?, Account No. 552 atTon 6/30/2009 and subsetluently sold to Atlantic Creditl& Finan 1'1 c 406.awi h`aalult was charged $1,51.1.61. balance of 3. Plaintiff purchasexl or was otherwise assigned this charged off account along wi th other debt a result of the foregoing sale and assignment, the Plaintiff succeeded to all fight, title, in the charged off account and it now owns the account. s. nd interestAs 4. Plaintiff conducted a due diligence investigation to determine, anion other g things, the accuracy of the account information provided to ascertain whether the statute of'limitations was a bar to demand or institution of suit. F•'urtlicr, Plaintiff and/or ' its pre entered the predecessor made representations and warranties that } tdhad cleat right, mtitleto a and contract where interest in the account, 2) the account was free and clear of all liens and encumbrances; and 3 ' power, authority, and full right to sell and convey its interest in the account. It had the 5. According to Plaintilf's records, the last payment to the Original Creditor was on 1/12/2009 amount of $ 65.00. After application of all payments, credits, adjustments, and lawful tys t the any, there is still a balance due and owing o1i this indebtedness of $1,511.61 offsets, if 6. The internal Account Statement of Plaintiff is attached hereto as Exhibit account information that was provided to plaintiff at the time of purchase and and displays ;splays the The foregoing is true bent' g and correct to the best of my knowledge and belief. By. Authorized Represe t i n at ve Subscribed and swoz71 bef ore me, M 10 40ta1Y ubl ic: Retie a R dy;k??kitll l(rr/. f, 1 .; • : . ?? ; . .'NnrF?RY'. THIS COMMUNICATION I _ S FROM A DEBT CU • -f7 r? a ,72 fs^c LLE C.TOR Gordon & weinber g, P.C.: CGA FF- 3772928 . , ' `' . -0001744 = E'?YiiiES lll 0 Atlantic Credit & Finance Inc. statement Date _ Atlantic Account Statement 05/19/2010 C:'1d= !T- FVAN(-'.4coRPofdAiff; ACF Account ID: 3712928 Original Creditor Account Number: 5522340005636406 Purchase Balance: Original Creditor Amount Paid: Original Creditor: original Creditor Last Pay Date: Original Creditor Last Pay Amount. Original Creditor Charge Off Date: Current Balance: $1,511.61 $0.00 HSBC 1/12/2009 $65.00 06/30/2009 $1,511.61 Name: CORSON, JOAN SSN - Last 4 Digits: 2031 Streetl: 94 RUSTIC DR Street2: City, State, Zip: SHIYPBNSBURG PA 17257-8750 Date Amount Page 1 of 1 ACF - 9122 Confidential Psaperty of Atlantic Credit i Finance Inc. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor iy! X" Atlantic Credit & Finance Inc. Assignee from HSBC Case Number vs. Joan Corson 2011-2506 SHERIFF'S RETURN OF SERVICE 03/10/2011 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Joan Corson, but was unable to locate her in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant Joan Corson. Deputies were advised by the landlord of 125 Airport Road, Shippensburg, Pennsylvania 17257 Joan Corson does not reside at this address. SHERIFF COST: $73.00 March 10, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF i,c' countysulte S^enff. ieleo, ofi.. I+':... 0avid aD, Buell Prothonotary i� Office of the (Prothonotary Cum6er[and County, <Pennsyfvania 7CyrkS. Sohonage, ESQ Solicitor /I —t250i6 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 0 Suite100 0 Carlisle, TA 0 (Phone 717 240-6195 0 F'ax 71 7 240-6573