HomeMy WebLinkAbout11-54462101826
THIS IS AN ARBITRATION MATTER.
DAMAGES HEARING REQUIRED.
GORDON & WEINBERG, P.C.
BY: FREDERIC I. WEINBERG, ESQUIRE
Identification No.: 41360
JOE M. FLINK, ESQUIRE
Identification No.: 41200
1001 E. Hector Street, Ste 220
Conshohocken, PA 19428
484/351-0500
ASSESSMENT OF
Cavalry Portfolio Services, LLC COURT OF COMMON PLEAS
as assignee of Cavalry SPV I, CUMBERLAND COUNTY
LLC as assignee of Wells Fargo
Bank, N.A.
500 Summit Lake Dr., Ste.
Valhalla, NY 10595--134
VS.
SUSAN K 130WER
1007 SHEFFIELD
MECHANICSBURG
AVE
PA 17055-5748
DOCKET NO. : I I- sc/q(
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Civ?l
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 May 5, 2011 in
the amount of $7,264.00.
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.
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7. Defendant's last payment on account was made on
10/16/2009.
WHEREFORE, plaintiff claims of the defendant(s) the sum of
$7,264.00 plus applicable costs, interest and attorney's fees.
GORDON & WEINBERG, P.C.
BY:
FREDERIC I. W INB G, ESQUIRE
JOEL M. FLIN QUIRE
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
Wells Fargo Bank, N.A. , plaintiff herein and that she is duly
authorized to make this Verification, and that the facts set forth
in the Complaint in this civil action are true and correct to the
best of her knowledge,
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Date: ' Z--?
EXHIBIT "A"
1
2101826
13944655
Cavalry Portfolio Services, LLC as
assignee of Cavalry SPV I, LLC as
assignee of Wells Fargo Bank, N.A.
SUSAN K BOWER
4071100007682713
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 4071100007682713in the
amount of $7,264.00; and
6. If called upon, affiant can testify at trial as to the facts
stated herein.
The above facts are t,? and c
information and belief.
st of my knowledge,
STEPHANIE
LLI, LEGAL ADMINISTRATOR
Sworn to and Subsced
before this day
of 2200
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N; ar lic
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SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
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PENNSYLVANIA
Cavalry Portfolio Services, LLC Case Number
vs.
Susan K. Bower 2011-5446
SHERIFF'S RETURN OF SERVICE
08/03/2011 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search
and inquiry for the within named defendant to wit: Susan K. Bower, but was unable to locate her in his
bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant Susan K.
Bower. Request for service at 1007 Sheffield Avenue, Mechanicsburg, Pennsylvania 17055 the
Defendant was not found. The Mechancisburg Postmaster has confirmed, Susan K. Bower has moved
and left no forwarding address.
SHERIFF COST: $43.00 SO ANSWERS,
August 03, 2011 RbNO"Y R ANDERSON, SHERIFF
Prothonotag
Office ofthe -^«th~nOt-7y
County,��/���_ Pennsylvania
-~rk-.--'-o`-~Q
Solicitor
""13111-fic=o CIVIL TERM
ORDER OF TERMINATION OF COURT CASES
AND NOW THIS 28TN DAY OF OCTOBER, 2014, AFTER MAILING NOTICE OF
INTENTION TO PROCEED AND RECEIVING NO RESPONSE —THE ABOVE
CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH
BY THE COURT,
DAVID D. BUELL