HomeMy WebLinkAbout11-43452094805 `? -
THIS IS AN ARBITRATION MATTER. ASSESSMgy Olt-
HEARING REQUIRED.
DAMAGES
GORDON & WEINBERG P.C. is
BY: FREDERIC I. WEINBERG, ESQUIRE
Identification No.: 41360 ?-
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JOEL M. FLINK, ESQUIRE CD
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Identification No.: 41200
1001 E. Hector Street, Ste 220 C:
Conshohocken, PA 19428
484/351-0500
Cavalry Portfolio Services, LLC
as assignee of Cavalry SPV I,
LLC as assignee of Bank of
America/FIA Card Services, N.A.
7 Skyline Drive
Hawthorne, NY 10532
VS.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
DOCKET NO.
11-4 '.>1 J C?n?
ASHRAF A MUSLEH
3502 BEECH RUN LN
MECHANICSBURG PA 17050-2206
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
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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 April 4, 2011 in
the amount of $1,279.16.
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.
1
7. Defendant's last payment on account was made on 4/16/09.
WHEREFORE, plaintiff claims of the defendant(s) the sum of
$1,279.16 plus applicable costs, interest and attorney's fees.
GORDON & WEINBERG, P.C.
BY:
FREDERIC I. W BERG, ESQUIRE
JOEL M. FLINK, ESQUIRE
Attorney for Plaintiff
P01A.DB
VERIFICATION
The undersigned does hereby verify subject to the penalties of
18 Pa.C.S. Section 4904 relating to unsworn falsification to
authorities, that she is an authorized agent of Cavalry Portfolio
Services, LLC as assignee of Cavalry SPV I, LLC as assignee of Bank
of America/FIA Card Services, N.A. , plaintiff herein and that she
is duly authorized to make this Verification, and that the facts
set forth in the Complaint in thi evil ction are true and
correct to the best of her kno e ihformat'o and belied.
STEPHAN
()WH
Date:
EXHIBIT "A"
2094805
13657505
Cavalry Portfolio Services, LLC as
assignee of Cavalry SPV I, LLC as
assignee of Bank of America/FIA Card
Services, N.A.
Sworn to and Subscr3}jed
e ??
ASHRAF A MUSLEH
4888936077301871
AFFIDAVIT
1. I, STEPHANIE CAPPELLI, being duly served sworn according to
law, depose and say that:
1. I am the agent for the Plaintiff herein and I am the custodian
of the records relating to this account;
2. I have personal knowledge of the facts and circumstances in
connection with this case based on my review of the file;
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. After allowing for all offsets and credits, a balance remains
on the subject account having account number 4888936077301871in the
amount of $1,279.16; and
6. If called upon, affiant c tify at trial as to the facts
stated herein.
The above facts are true an orr J?tkthe pest of my knowledge,
information and belief. `
STEPHANIE CAPPELLI, LEGAL ADMINISTRATOR
befor m t 's / day
of 2 11
LUM UARUIUNAL
No?atyPub0Ro?ddand Nt"
N tar ublic in r
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
F a-ED-Omegqu
Tt? PROTHONOTARY
2011 ja - 8 Pm 2, 16
c,uCBE RLY Q AN UNTY
Cavalry Portfolio Services, COURT OF COMMON PLEAS
LLC as assignee of Cavalry SPV CUMBERLAND COUNTY
I, LLC as assignee of Bank of
America/FIA Card Services,
N.A.
VS.
ASHRAF A MUSLEH
DOCKET NO. : 11-4345 CIVIL
PRAECIPE FOR ENTRY OF JUDGMENT FOR PANT OF AN ANSWZR 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 $1,279.16
Less: Payments on Account ( $.00)
Total: $1,279.16
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: Cavalry
Portfolio Services,LLC as assignee of Cavalry SPV I, LLC as assignee
of Bank of America/FIA CardServices, N.A. and that the last known
address of defendant, ASHRAF A MUSLEH, 3502 BEECH RUN LN,
MECHANICSBURG PA 17050-2206.
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. a??%1q.ooFd 41?
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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. I
AND NOW, this - day of _ v Ul 2011 Judgment
is entered in favor of the plaintiff(s) and a ainst defend nt(s) by
default for want of an answer and ages ass d at th um of ,
$1,279.16 as per the above certific ion. 1 JJJ
Prothono
GORDON & WEINBERG, P.C.
BY:
FREDERIC I. EIN RG, ESQUIRE
JOEL M. FLIN , SQUIRE
Attorney for Plaintiff
2094805
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
Cavalry Portfolio Services,
LLC as assignee of Cavalry SPV
I, LLC as assignee of Bank of
America/FIA Card Services,
N.A.
VS.
ASHRAF A MUSLEH
3502 BEECH RUN LN
MECHANICSBURG PA 17050-2206
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
DOCKET NO. : 11-4345 CIVIL
NOTICE
Pursuant to Pa.R.Civ.P.
you are hereby notified
you in the above procee,
L-Z
236 of the Supreme Court of Pennsylvania,
that a judgment has been entered against
ling as indicated below.
Judgment by Default $1,279.16
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 AT THIS
TELEPHONE NUMBER: 484/351-0500 ,.?
PROTHONOTARY
r.. 0 00?
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
2094805
Cavalry Portfolio Services, LLC as
assignee of Cavalry SPV I, LLC as
assignee of Bank of America/FIA Card
Services, N.A.
vs.
ASHRAF A MUSLEH
TO/PARA
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
DOCKET NO. : 11-4345 CIVIL
NOTICE OF INTENTION TO TAKE DEFAULT
ASHRAF A MUSLEH
3502 BEECH RUN LN
MECHANICSBURG PA 17050-2206
DATE OF NOTICE/FECHA DEL AVISO: June 8, 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.
l+
BY
FREDERIC I?INBERG, ESQUIRE
P10D-2 JOEL M.rF K, ESQUIRE