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Home My WebLink About11-25172103921 THIS IS AN ARBITRATION MATTER. ASSESSMENT OF DAMAGES HEARING REQUIRED. GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 c-) o JOEL M. FLINK, ESQUIRE C -- --? TQ Identification No.: 41200 rnrn r --- 1001 E. Hector Street, Ste 220 f Conshohocken, PA 19428 c`np "'' co :10 C") 484/351-0500 i - - - -n vcs 3 te ` Global Acceptance Credit Company LP COURT OF COMMON PLEAS ?°? tv r at?~ assignee of CashCall Inc. CUMBERLAND COUNTY 5850 WEST I-20, SUITE 100 Sri Arlington TX 76017 : 1 I , a51 , ?1/! I l?Y VS. DOCKET NO. JONATHAN L FORBES 309 OAKVILLE ROAD SHIPPENSBURG PA 17257 _ CO®sPLAINT IN A33VOSIT 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 ?d at+ Cktt-1y3A&4 e*a,5583P 1 1. Plaintiff is a debt buyer and successor in interest to the original creditor as set forth in the caption of this Complaint. 2. The defendant, for valuable consideration received, executed and delivered to plaintiff a promissory note under the terms of which the defendant promised to pay to the plaintiff consecutive monthly payments under the terms and conditions set forth in the promissory note. A true and correct copy of the aforesaid promissory note or Affidavit of Account, if available, is attached hereto, made a part of this complaint and marked Exhibit "A". 3. Contrary to the terms of the aforesaid promissory note, the defendant failed to make the required payments when due as a result of which the unpaid balance of $2,600.00 became due and payable. 4. All the credits to which the defendant(s)is entitled have been applied and there remains a balance due as of January 27, 2011 in the amount of $2,600.00. 5. 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. 6. Defendant's last payment on account was made on 3/19/07. WHEREFORE, plaintiff claims of the defendant(s) the sum of $2,600.00 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBER QUIRE JOEL M. LI ESQUIRE Attorney or Plaintiff PO1C. DB Global Acceptance Credit JONATHAN L FORBES DEBTOR NAME 668050 Account # 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. O NE: EXHIBIT "A?? STATE OF TEXAS COUNTY OF TARRANT AFFIDAVIT Shaine Cauthon, being duly sworn, deposes and says: 1. I am the Legal Manager of GLOBAL ACCEPTANCE CREDIT COMPANY, L.P. which is a partnership organized and existing under the laws of the State of Texas. 2. I have knowledge of the facts herein set forth and am duly authorized to make this Affidavit; that the claim against JONATHAN L FORBES is within my knowledge and is just, true and correct and that all just and lawful offsets, payments and credits have been allowed. 3. There is now due plaintiff from said debtor the sum of $2,600.00 plus interest and other fees as allowed by law and/or agreement. 4. To the best of my knowledge the Defendant is not now in the military service, as defined in the Soldier's and Sailor's Civil Relief Act of 1940 with amendments, nor has been in such service within thirty days hereof. 5. Demand for payment was made on the debtor more than thirty days prior to the making of this Affidavit, for the amount due on the Account; such h not been paid by the debtor. AFFIANT Sworn to and subscribed to before me this --„ . Day of Inu2011 Notary Public GACC#668050-1 joLgYr C "r: Vz7 Original ACCOUnt NO: 1358411 " My co"T F GACC Tax Id #56-2559256 STA Rev: 070724 OPW -1 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 Conshohocken, PA 19428 484/351-0500 Global Acceptance Credit Company LP assignee of CashCall Inc. vs. JONATHAN L FORBES 2103921 COURT OF COMMON PLEAS CUMBERLAND COUNTY ? ,,rnai 0 rn- rte- 0 DOCKET NO. 11-2517 -n C . C :, N ` r n OF DAMAGES --- ...'•• ••? •+?• .u.sw?c ASSESSME VERIFICATION OF ADDRESS AND NON-MILITARY SERVICE 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 $2,600.00 Less: Payments on Account ( $.00) Total: $2,600.00 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: Global Acceptance CreditCompany LP assignee of CashCall Inc. and that the last known address of defendant, JONATHAN L FORBES, 309 OAKVILLE ROAD, SHIPPENSBURG PA 17257. 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. QC?' iC/ GG f??? lJ.l,i9?.x? ('?ltt !r? % 4015 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?rf? 2011 Judgment is entered in favor of the plaintiff(s) and against defendant(s) by default for want of an answer and damage s/? sessed at the sum of , $2,600.00 as per the above /??fication./// / P GORDO$ & WEINBERG, pi. . BY: FREDERIC NBERG, ESQUIRE JOEL M. F K, ESQUIRE Attorney for Plaintiff www 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 C Conshohocken, PA 19428 484/351-0500 Global Acceptance Credit Company LP assignee of CashCall Inc. vs. JONATHAN L FORBES 2103921 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 11-2517 TO/PARA NOTICE OF INTENTION TO TAKE DEFAULT , JONATHAN L FORBES 309 OAKVILLE ROAD SHIPPENSBURG PA 17257 DATE OF NOTICE/FECHA DEL AVISO: March 25, 2011 IMPORTANT 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. n BY: FREDERIC I.;,? BERG, ESQUIRE P10D-2 JOEL M. FLIP ESQUIRE 2103921 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 Global Acceptance Credit Company LP assignee of CashCall Inc. vs. JONATHAN L FORBES 309 OAKVILLE ROAD SHIPPENSBURG PA 17257 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 11-2517 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. /X/ Judgment by Default $2,600.00 L1 Money Judgment $ L.1 Judgment on Award of Arbitrators$ L -L Judgment on Verdict$ IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, ATTORNEYS: FREDERIC I. WEINBERG OR JOEL M. FLIN TELEPHONE NUMBER: 484/351-0PLEASE CALI, L//j5"li 1 L,.J of ILL... L';312 APR 16 Ps i 2: U) 2103921 GORDON & WEINBERG, P.C. CUMBERLAND COUNTY BY: FREDERIC I. WEINBERG, FfTIW tYLVANIA Identification No.: 41360 °- JOEL M. FLINK, ESQUIRE Identification No.: 81894 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 Global Acceptance Credit Company LP COURT OF COMMON PLEAS assignee of CashCall Inc. CUMBERLAND COUNTY VS. DOCKET NO. : 11-2517 JONATHAN L FORBES SUGGESTION OF BANKRUPTCY OF DEFENDANT TO THE PROTHONOTARY: AND NOW, this 11Apr12, it is suggested of record that: Defendant, JONATHAN L FORBES, filed a petition in bankruptcy under Chapter 13 of the Bankruptcy Code on or about March 15, 2012, in the United States Bankruptcy Court for the Middle District of Pennsylvania, docket number 1:12-bk-01494-M. Therefore, this matter should be stayed until further notice. GORDON & WEINBERG, P.C. BY: FREDERIC WE BERG, ESQUIRE JOEL M. I , ESQUIRE Attorney for Plaintiff