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Home My WebLink About11-4261 2107520 THIS IS AN ARBITRATION MATTER. ASSESSMENT OF DAMAGES HEARING REQU RED- ? -e GORDON & WEINBERG, P.C. ? ?,, ??- O BY: FREDERIC I. WEINBERG, ESQUIRE -n r Identification No.: 41360 JOEL M. FLINK, ESQUIRE .a Identification No.: 41200 vr, OZ r7nF D 1001 E. Hector Street, Ste 220 y w = Conshohocken, PA 19428 '- 484/351-0500 NCEP, LLC COURT OF COMMON PLEAS P.O. Box 1589, Suwanee,GA 30024 CUMBERLAND COUNTY VS. DOCKET NO. FELICIA SOULEY 607 A GENEVA DR APT 21 Mechanicsburg PA 17055 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, 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 4aoo?,? Ad -'4 V-77 141e.S-??pe- ? as 90?? COMPLAINT IN CIVIL-ACTION 1. Plaintiff, NCEP, LLC a debt buyer and successor in interest to the original creditor, HSBC Bank Nevada Na Issuer of Union Privilege MasterCard. 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 March 22, 2011 in the amount of $1,096.63. 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 6/24/09. WHEREFORE, plaintiff claims of the defendant(s) the sum of $1,096.63 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDERIC . W NBERG, ESQUIRE JOEL M. FL -1-51K, ESQUIRE Attorney for Plaintiff POIP.DB 2107520 11492788 NCEP, LLC FELICIA SOULEY 5480420032006809 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. EXHIBIT "A" 2107520 NCEP, LLC FELICIA SOULEY 5480420032006809 AFFIDAVIT I, sgatresbn being duly served sworn according to law, depose and"say that: 1. I am an affiant for the Plaintiff herein and I have custody and control of the files relating to this account; 2. I have personal knowledge of the facts and circumstances in connection with this case and base this affidavit on Plaintiff's records, as well as the account information provided to Plaintiff NCEP, LLC upon the purchase of debtor's account, which was issued by HSBC Bank Nevada Na Issuer of Union Privilege MasterCard. 3. Plaintiff's files are maintained in the usual and ordinary course of business; 4. This action is based on a claim for breach of contract and that damages are sought as a direct result of said breach; 5. There is now due and owing from defendant to plaintiff, the amount of $1,026.45 plus interest of $66.97 at the rate of 6% less credits in the amount of $.00 totaling $1,093.42 as of March 3, 2011. 6. If called upon, affiant can testify at trial as to the facts pertaining to this matter. The above facts are ftrue\and correct to information and belief, ; l' Sworn to and Subscribed before me this day of 20' Notary Public best of my knowledge, 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 NCEP, LLC VS. FELICIA SOULEY """P-1110-OFFICE .E -PROTHONOTARY 2011 JUN 20 PM 1: 15 CUMBERLAND COUNTY PENNSYLVANIA COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 11-4261 CIVIL PRAECIPE FOR ENTRY OF JUDGMMT FOR NANT OF AN ANSWM ASSESSMENT OF DAMAGES, 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 $1,096.63 Less: Payments on Account ( $.00) Total: $1,096.63 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: NCEP, LLC and that the last known address of defendant, FELICIA SOULEY, 607 A GENEVA DR APT 21, Mechanicsburg PA 17055. 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. 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. Cam- CL it oo ?d a x:5/5 ea )6a-? s.7 Nohc? A41- ea AND NOW, this day of 2011 Judgment is entered in favor of the plaintiff(s) and against defendant(s) by default for want of an answer and damages assessed at the sum of , $1,096.63 as per the above certif ati Prothonotar ft%.?) 0 GORDON & WEINBERG, P.C. BY: BERG, ESQUIRE FREDERIC IUNKESQUIRE JOEL M. FL Attorney for Plaintiff ,e?'*s++a yr? ». A. ?. ?? ..Y?'. .? ? , 2107520 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 NCEP, LLC COURT OF COMMON PLEAS CUMBERLAND COUNTY VS. DOCKET NO. : 11-4261 CIVIL FELICIA SOULEY 607 A GENEVA DR APT 21 Mechanicsburg PA 17055 NOTICE Pursuant to Pa.R.Civ.P. you are hereby notified you in the above procee, 236 of the Supreme Court of Pennsylvania, that a judgment has been entered against ding as indicated below. Judgment by Default $1,096.63 Money Judgment $ Judgment on Award of Arbitrators$ Judgment on Verdict$ IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL ATTORNEYS: FREDERIC I. WEINBERG OR JOEL M. FLINK, ESQUIRES A THIS TELEPHONE NUMBER: 484/351-0500 PROTH Y L•,4 s : a:.:!.Ik;,t+t ''.?_ ? ". _?`? r . 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 2107520 NCEP, LLC COURT OF COMMON PLEAS CUMBERLAND COUNTY FELICIA SOULEY TO/PARA Vs. DOCKET NO. : 11-4261 CIVIL NOTICE OF INTENTION TO TAKE DEFAULT FELICIA SOULEY 607 A GENEVA DR APT 21 Mechanicsburg PA 17055 DATE OF NOTICE/FECHA DEL AVISO: June 2, 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. BY /' FREDERIC I. W1 INIBE'RG, ESQUIRE JOEL M. FLINK;;ESQUIRE P10D-2 v 2107520 GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE = Identification No.: 81894 Mw cn ' 1001 E. Hector Street, Ste 220 z? -0 -Vm Conshohocken, PA 19428 -<D CD 484/351-0500 r- s - ?Z NCEP, LLC COURT OF COMMON PLEAS CUMBERLAND COUNTY VS. DOCKET NO. : 11-4261 CIVIL FELICIA SOULEY SUGGESTION OF BANKRUPTCY OF DEFENDANT TO THE PROTHONOTARY:. AND NOW, this 21Sepll, it is suggested of record that Defendant, FELICIA SOULEY, filed a petition in bankruptcy under Chapter 7 of the Bankruptcy Code on or about September 13, 2011, in the United States Bankruptcy Court for the Middle District of Pennsylvania, docket number 06292-MDF. Therefore, this matter should be stayed until further notice. GORDON & WEINBERG, P.C. BY: FREDERIC EINBERG, ESQUIRE JOEL M. F , ESQUIRE Attorney for Plaintiff