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Home My WebLink About11-4540Q THIS IS AN ASSESSMENT 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 2106233 ARBITRATION MATTER. OF DAMAGES HEARING REQUIRED. ADVANTAGE ASSETS II, INC. 7322 Southwest Freeway, Houston, TX 77074 Vs. LAURA VAZQUEZ 1402 LONGS GAP RD CARLISLE PA 17013-8618 NOTICE COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. 4D C= --4 ,urn s W d 't.? CDrn d kq:s?t b 'I 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 C_;?) I C k-tf /oS16 *aY16 3/ 4 COMPLAINT IN CIVIL-ACTION 1. Plaintiff, ADVANTAGE ASSETS II, INC. a debt buyer and successor in interest to the original creditor, Citibank (South Dakota), N.A.. 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 merchandise 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 25, 2011 in the amount of $5,278.03. 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. t 7. Defendant's last payment on account was made on 5/15/2008. WHEREFORE, plaintiff claims of the defendant(s) the sum of $5,278.03 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDERIC I. W INBERG, ESQUIRE JOEL M. F , ESQUIRE Attorney for Plaintiff POIP.DB 2106233 6035320237 ADVANTAGE ASSETS II, INC. AS ASSIGNEE OF Citibank (South Dakota), N.A. LAURA VAZQUEZ 6035320237073828 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. LEONARD PRUZANSRY, CEO EXHIBIT "A" ADVANTAGE ASSETS II, (South Dakota), N.A. LAURA VAZQUEZ 6035320237073828 State of Texas County of Harris AFFIDAVIT 2106233 INC. AS ASSIGNEE OF Citibank I, LEONARD PRUZANSRY, CEO, being duly served sworn according to law, depose and say that: 1. I am the agent for the Plaintiff herein and I have custody and control of the files relating to this account; 2. Plaintiff's files are maintained in the usual and ordinary course of business; 3. This action is based on a claim for breach of contract and that damages are sought as a direct result of said breach; 4. There is now due and owing from defendant to plaintiff, the amount of $5,278.03 plus interest of $.00 at the rate of 0% less credits in the amount of $.00 totaling $5,278.03 as of February 23, 2011. 5. If called upon, affiant can testify at trial as to the facts pertaining to this matter. The above facts are true and correct to the best of my knowledge, information and belief. NAME: LEONARD PRUZANSR , CEO Sworn to and Subscribed before me this day of Q, 201¢ is ?M r - !i. ,, HILDA SAHAGUN Notary Public, State of Texas ?} ti0 My Commission Expires '';„, May 20, 2014 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor L4xOty of climbpt4Fr4 FILED-0r 'lug: THE PROT"ON.OTARY 2011 JUN -7 AM 10= 28 113UMBERLANC "GUN l' PENNSYLVANIA Advantage Assets II, Inc. vs. Case Number Laura E. Vazquez 2011-4540 SHERIFF'S RETURN OF SERVICE 05/27/2011 06:41 PM - Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on May 27, 2011 at 1841 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Laura E. Vazquez, by making known unto herself personally, at 1402 Longs Gap Road, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $34.00 May 31, 2011 ROB RT BITNER, DEPUTY SO ANSWERS, RON R ANDERSON, SHERIFF !" C'u!1 ySuite SSerdT '(FIRt7=o1T. Inr,. 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 '4962 ICE OF HE PROTHONOTARY 2,211 JUL 1 1 PM 2:40 CUMBERLAND COUNTY PEtZNSYLVANIA ADVANTAGE ASSETS II, INC. VS. LAURA VAZQUEZ COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 11-4540 CIVIL PPAECIPE FOR ENTRY OF JVDGNMT FOR PANT OF AN ANSWER ASSESSM NT 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 $5,278.03 Less: Payments on Account ( $.00) Total: $5,278.03 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: ADVANTAGE ASSETS II, INC. and that the last known address of defendant, LAURA VAZQUEZ, 1402 LONGS GAP RD, CARLISLE PA 17013-8618. 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. Om + S IL A-00 Vd 0 CSC ak I a3co I 1 AND NOW, this is entered in favor default for want of $5,278.03 as per th, day of , 2011 Judgment of the plaintiff ) a ag t defend (s) by an answer and dam es a ess at the of , B above certifica n. 'e, at4c Prothonotary GORDON & WEINBERG, P.C. BY: FREDERIC EINBERG, ESQUIRE JOEL M. F NK, ESQUIRE Attorney for Plaintiff I, 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 2106233 ADVANTAGE ASSETS II, INC. VS. LAURA VAZQUEZ 1402 LONGS GAP RD CARLISLE PA 17013-8618 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 11-4540 CIVIL 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. /R1 Judgment by Default $5,278.03 Money Judgment $ Judgment on Award of Arbitrators$ L_Z 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 7/11/11 PROTH Y 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 2106233 ADVANTAGE ASSETS II, INC. COURT OF COMMON PLEAS CUMBERLAND COUNTY LAURA VAZQUEZ TO/PARA Vs. DOCKET NO. : 11-4540 CIVIL NOTICE OF INTENTION TO TAKE DEFAULT LAURA VAZQUEZ 1402 LONGS GAP RD CARLISLE PA 17013-8618 DATE OF NOTICE/FECHA DEL AVISO: June 17, 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;'j BERG, ESQUIRE JOEL M. ,F I`?K, ESQUIRE PLOD-2 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 w 017=![: j ?t? r fi?}1'NORQ(. 2106233 2012 MAR 23 PM 1: 5P CUMBERLAND COUNTY PENNSYLVANIA ADVANTAGE ASSETS II, INC. VS. LAURA VAZQUEZ COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 11-4540 CIVIL SUGGESTION OF BANKRUPTCY OF DEFENDANT TO THE PROTHONOTARY: AND NOW, this 15Marl2, it is suggested of record that Defendant., LAURA VAZQUEZ, filed a petition in bankruptcy under Chapter 1.3 of the Bankruptcy Code on or about March 14, 2012, in the United States Bankruptcy Court for the Middle District of Pennsylvania, docket number 12-01268. Therefore, this matter should be stayed until further notice. GORDON & WEINBERG, P.C. BY: FREDERIC I. W NBERG, ESQUIRE JOEL M. FLIO , ESQUIRE Attorney for Plaintiff