HomeMy WebLinkAbout11-57082083594
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
ASSET ACCEPTANCE, LLC ASSIGNEE COURT OF COMMON PLEAS
OF WORLD FINANCIAL NETWORK CUMBERLAND COUNTY
NATIONAL BANK
28405 Van Dyke Avenue
Warren, MI 48093
VS.
DOCKET NO. :I - 7b o
Cio I
AMANDA J SALTZBURG
19 WHEATFIELD DRIVE
CARLISLE PA 17015
NOTICE
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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 July 14, 2011 in
the amount of $1,142.19.
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
7/19/2007.
WHEREFORE, plaintiff claims of the defendant(s) the sum of
$1,142.19 plus applicable costs, interest and attorney's fees.
GORDON & WEINBERG, P.C.
BY:
FREDERIC I WEINBE ESQUIRE
JOEL M. FL UIRE
Attorney for Plaintiff
P01A.DB
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
ii-Jonnation 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.
A,,?E-
Nam ` judy Melasi
EXHIBIT "A"
?6-k35-9?/
STATE OF MICHIGAN )
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COUNTY OF MACOMB }
ASSET ACCEPTANCE, LLC
Plaintiff,
YS
AMANDA J SALTZBURG
Defendant,
I,
JUDY MELASI
ss
}
AFFIDAVIT
}
M_ being first duly sworn deposes and states:
That I am a representative of ASSET ACCEPTANCE, LLC a Limited Liability company organized and
existing under the laws of the State of Delaware and doing business at P.O. BOX 2041, WARREN, MI 48090.
That there is justly due and owing on the account, the sum of $1029.69 representing the charged off
amount and interest.
That the said account originally with NICTOR1AS SECRET / World Financial Network Nati, account
number 000000000261363910, has been purchased by ASSET ACCEPTANCE, I.LC, who now owns said
account and has all rights connected therewith including the right to institute this action.
Dated this 24th day of March, 2010.
1 r
Asset cceptanc Representative
1)
Subscribed ar,&sworn to before me a Notary Public for the State of Michigan, the 24th of March, 2010 as
certified by y and as set fo ipffgrely below.
NWary,fliblic/ '
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39504582
1 064 GORDON & WEINBERG 1111111111
0 0 3 9 5 0 4 5 8 2
ASSET ACCEPTANCE LLC
P.O. Box 2036
Warren, MI 48090
AMANDA) SALTZBURG
201 VALLEY ST APT 4
MARYSVILLE,PA 170.43
_ ACCOUNT NUMBER CCJRRF.NT BALANCE
000000000261363910 $1029.69
STATEMENT DATE.
MAR 24 2010
ACCOUNT NUMBER
000000000261363910
DUE DATE
DUE,
DATE OF LAST PAYMENT
07/19/07
DATE REFERENCE NO ACCOUNT INFORMATION
T BALANCE DUE
MAR 24 2010 39504582 AALANCE DUE $1029.69
ASSET ACCEPTANCE LLC, A LIMITED
I.IAJ3II.rrY COMPANY ORGANIZED AND
EXISTING UNDER THE LAWS OF THE
STATE OF DELAWARE, ASSIGNEE OF
AA1..I,C/WORLD FIN NA
P.O. Box 2036, Warren, MI 48090
DATE OF DELINQUENCY PTTRCHASED ON CHARGE. OF AMOUNT* JNTF.REST RATE
03/06/07 05112/09 829.50 10.00%
SERVICE ADDRESS (TF APPLICABLE) INTEREST DUE AS OF MAR 24 2010
$200.19
*For purposes of this Statement only, Charge Off Amount reflects credits for payrnunts received by
Asset, if any.
**. Not previously sent to consumer.
THIS COMMUNICATION IS FROM A DEBT COLLECTOR
395,04582
1064 GORDON & WEINBERG
SHERIFF'S OFFICE OF CUMBERLAND. COUNTY
Ronny R Anderson
Sheriff pt CIiiub F ILpEC-OFi IG
Jody S Smith ?4`ttti?t, er(,y?l? I?E P R 0 TIj0"''??.+ twit ?.Ft.
Chief Deputy 2Q11 JUL 2$ AM 8: Qr
Richard W Stewart
Solicitor CUMBERLAND CUU'NI'Y
PENNSYLVANIA
Asset Acceptance LLC
Case Number
vs.
Amanda J. Saltzburg 2011-5708
SHERIFF'S RETURN OF SERVICE
07/19/2011 08:50 PM - Valerie Weary, Deputy Sheriff, who being duly sworn according to law, states that on July 19,
2011 at 2050 hours, she served a true copy of the within Complaint and Notice, upon the within named
defendant, to wit: Amanda J. Saltzburg, by making known unto herself personally, at 19 Wheatfield Dri
Carlisle, Cumberland County, Pennsylvania 17015 its contents and at the same time handing to h
personally the said true and correct copy of the same.
VALERIE WEARY, DEPUTY
SHERIFF COST: $34.00
July 20, 2011
SO ANSWERS,
RON ~ R ANDERSON, SHERIFF
fcj CounrySuitc Shev:tf ie eos>o`(. Inc
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
20§3594
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r'UMBER PE NSYLVANIANTY
ASSET ACCEPTANCE,
OF WORLD FINANCIAL
NATIONAL BANK
VS.
AMANDA J SALTZBURG
DOCKET NO. : 11-5708-CIVIL
PRAECIPE FOR ENTRY OF JUDGKCNT FOR RtANT 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 $1142.19
Less: Payments on Account ( $.00)
LLC ASSIGNEE COURT OF COMMON PLEAS
NETWORK CUMBERLAND COUNTY
Total: $1142.19
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: ASSET
ACCEPTANCE, LLCASSIGNEE OF WORLD FINANCIAL NETWORK NATIONAL BANK and
that the last known address of defendant, AMANDA J SALTZBURG, 19
WHEATFIELD DRIVE, CARLISLE PA 17015.
2. The annexed notice(s) of intention to file this
praecipe was (were) mailed to all parties, defendant and
record attorneys, if any, after default occurred, and at
ten days prior to the date of filing of this praecipe.
to their
least
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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.
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 d@Vage ss d at the m of ,
/I i $1,142.19 as per the above certifica on.a
Prothono WOOF"
GORDON & WEINBERG?P.C.
BY: --t i' \
FREDERIC I WEI ERG, ESQUIRE
JOEL M: FL N ESQUIRE
Attorney for Plaintiff
2083594
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
ASSET ACCEPTANCE, LLC ASSIGNEE COURT OF COMMON PLEAS
OF WORLD FINANCIAL NETWORK CUMBERLAND COUNTY
NATIONAL BANK
VS. DOCKET NO. : 11-5708-CIVIL
AMANDA J SALTZBURG
19 WHEATFIELD DRIVE
CARLISLE PA 17015
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.
rXL Judgment by. Default $829.50
" Money Judgment $
,/L Judgment on Award of Arbitrators$
,/L 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
?I ?? ?' PROTH
., .
2083594
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
ASSET ACCEPTANCE, LLC ASSIGNEE OF
WORLD FINANCIAL NETWORK NATIONAL
BANK
vs.
AMANDA J SALTZBURG
TO/PARA
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
DOCKET NO. : 11-5708-CIVIL
NOTICE OF INTENTION TO TAKE DEFAULT
AMANDA J SALTZBURG
19 WHEATFIELD DRIVE
CARLISLE PA 17015
DATE OF NOTICE/FECHA DEL AVISO: August 9, 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.
n
rBY: i
FREDERIC I.ffWIPINBERG, ESQUIRE
JOEL M. ESQUIRE
P10D-2 i./