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Home My WebLink About11-48252107890 THIS IS AN ARBITRATION MATTER. DAMAGES HEARING REQUIRED. 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 ASSESSMENT OF ? cn .'s ?-1 CC:) -Gp m Cn HARVEST CREDIT MANAGEMENT VII, LLC ASSIGNEE OF HOUSEHOLD ORCHARD 1580 Lincoln Street STE 600 Denver CO 80203 vs. CONNIE WILSON 316 E NORTH ST CARLISLE PA 17013 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : I,- 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 G 147zl* m// a?ID 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 May 3, 2011 in the amount of $12,895.79. 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 11/17/2008. WHEREFORE, plaintiff claims of the defendant(s) the sum of $12,895.79 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDERIC 't -/WEINBERG, ESQUIRE JOEL M. FLINK, ESQUIRE Attorney for Plaintiff P01A.DB 2107890 EH133456 HARVEST CREDIT MANAGEMENT VII, LLC ASSIGNEE OF HOUSEHOLD ORCHARD CONNIE WILSON 5491098401821946 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. NAME EXHIBIT "A" r 1982 2107890 EH133456 HARVEST CREDIT MANAGEMENT VII, LLC ASSIGNEE OF HOUSEHOLD ORCHARD CONNIE WILSON 5491098401821946 David Ravin I, law, depose and say that: AFFIDAVIT , being duly served sworn according to 1. I am the agent 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; 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 $9,269.67 plus interest of $3,528.60 at the rate of 8% less credits in the amount of $.00 totaling $12,798.27 as of March 16, 2011. 6. 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. AFF ANT Sworn to and Subscribed before me this day oAPR 12 2011 2011 cka)?u?m o'10tary Public tl? Yr. L µ ;aJ p'i ls? e APR 3 20?,? SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor OFFICE -F ..r..;:.€ F {} ?.? tJ1 l r «_ E 14 AM 10: ? PEN Harvest Credit Management VII vs. Connie Wilson Case Number 2011-4825 SHERIFF'S RETURN OF SERVICE 06/09/2011 03:05 PM - Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on June 9, 2011 at 1505 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Connie Wilson, by making known unto Betsy Moose, adult in charge at 316 E. North Street, 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 June 10, 2011 MI HAE??LBA R ,, DEPUTY SO ANSWERS, RON R ANDERSON, SHERIFF -es`Y i 1, *t Ire;. t GORDON & WEINBERG, P.C. BY: FREDERIC I. WE=:NBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 81894 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 2107890 ?3 ... --i co rnM = m = ,J) r-- r -a m U N N C-> , CD -q F73 M , HARVEST CREDIT MANAGEMENT VII, LLC ASSIGNEE OF HOUSEHOLD ORCHARD VS. CONNIE WILSON COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 11-4825-CIVIL PRAECIPE FOR ENTRY OF JUDGMENT FOR PANT OF AN ANSWER 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 $12,895.79 Less: Payments on Account ( $150.00) Total: $12,745.79 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: HARVEST CREDIT MANAGEMENT VII,LLC ASSIGNEE OF HOUSEHOLD ORCHARD and that the last known address of defendant, CONNIE WILSON, 316 E NORTH ST, CARLISLE PA 17013. 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 tr.e date of filing of this praecipe. 4I4•oc P4-AriW 3. The said defendant (s) is (are) not in the military OL52916 service of the United States or otherwise within the coverage of ea(oao?i8 the Soldiers and Sailors Civil Relief Act and is (are) over 18 years of age. ?? I AND NOW, this _ end 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 , $12,745.79 as per the above certifica n. Prothonotary ?.?q GORDON & WEINBERG, P.C. BY: FREDERIC I( WE BERG, ESQUIRE JOEL M. FL N , ESQUIRE Attorney for Plaintiff ?" ?. ?' ??-. t 2107890 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 HARVEST CREDIT MANAGEMENT VII, LLC ASSIGNEE OF HOUSEHOLD ORCHARD VS. CONNIE WILSON 316 E NORTH ST CARLISLE PA 17013 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO NOTICE 11-4825-CIVIL 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. Judgment by Default $12,745.79 L-L Money Judgment $ Judgment on Award of Arbitrators$ L_L Judgment on Verdict$ IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL ATTORNEYS: FREDERIC I. WEINBERG OR JOEL M. FLINK, ESQUIRES AT HIS TELEPHONE NUMBER: 484/351-0500 PROTHO GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 41200 1001 E. Hector Street, St;e 220 Conshohocken, PA 19428 484/351-0500 2107890 HARVEST CREDIT MANAGEMENT VII, LLC ASSIGNEE OF HOUSEHOLD ORCHARD vs. CONNIE WILSON COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 11-4825-CIVIL NOTICE OF INTENTION TO TAKE DEFAULT TO/PARA CONNIE WILSON 316 E NORTH ST CARLISLE PA 17013 DATE OF NOTICE/FECHA DEL AVISO: June 30, 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 WEINBERG, ESQUIRE JOEL M. FINK, ESQUIRE P10D-2