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Home My WebLink About11-5734Blatt, Hasenmiller, Leibsker & Moore, LLC Daniel Santucci Attorney I.D. #92800 Gregory R. Dye Attorney I.D #205316 1835 Market Street, Suite 501 Philadelphia, PA 19103 800-850-1079 Attorney for Plaintiff, PORTFOLIO RECOVERY ASSOCIATES LLC PORTFOLIO RECOVERY ASSOCIATES LLC c/o Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 Plaintiff, VS. WILLIAM FORD 418 4TH ST NEW CLIMBERLND PA 17070-1801 Defendant. IN THE COURT OF COMMON PLEA a ? CUMBERLAND COUNTY, PA zw c rn r -- - x;0 r om CIVIL ACTION,. Co I =a) a -? C) No. =K acs -? w C:)m NOTICE TO DEFEND 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 judgment 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. LAWYER REFERRAL SERVICE 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 o? Pd ? of h 5-// ? ? 19'53 2638291 PPTCPADI AVISO Le han demandado a usted en la corte. Si usted quiere defen derse de estas demandas expuestas en las paginas siguientes, usted tiene veinte dias de plazo al partir de la fecha de la demanda y la notificacion. Hase falta ascentar una comparencia escrita o en persona o con un aboga do y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisa do que si usted no se de fiende la corte tomara medidas y puede continuar la demanda en contra suva sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero o sus propieda des u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 267-2032 Blatt, Hasenmiller, Leibsker & Moore, LLC Daniel Santucci Attorney I.D. #92800 Gregory R. Dye Attorney I.D. #205316 1835 Market Street, Suite 501 Philadelphia, PA 19103 800-850-1079 Attorney for Plaintiff, PORTFOLIO RECOVERY ASSOCIATES LLC c/o Blatt, Hasenmiller, Leibsker & Moore, LLC Plaintiff, WILLIAM FORD vs. 418 4TH ST NEW CUMBERLND PA 17070-1801 Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. / 5`7 3 7 C y / -. e"& COMPLAINT Plaintiff PORTFOLIO RECOVERY ASSOCIATES LLC, claims as follows: 1. The Defendant(s), WILLIAM FORD, is a resident of Cumberland County, Pennsylvania. 2. The Defendant(s) obtained extensions of credit with HSBC BANK NEVADA, N.A, (Original Credit Grantor) agreeing to make monthly payments as required by the terms of the account, for purchases charged to the account. 3. The Defendant(s) did make purchases and charged same to the account but failed to make the monthly payments called for on the account. There is a balance due and owing of $13578.13. 4. Plaintiff is the successor in interest of said account having purchased the account in the regular course of business in good faith and value. 5. Plaintiff declared Defendant(s) to be in default and demands payment of the balance. 2638291 PPTCDBCI WHEREFORE, the Plaintiff, PORTFOLIO RECOVERY ASSOCIATES LLC, prays for judgment in its favor and against Defendant(s), WILLIAM FORD in the amount of $13578.13, plus costs. Respectfully submi , PORTFOLIO RE Y ASSCATES LLC one orrts Azzorneys Daniel Santucci, Attorney No. 92800 Gregory R. Dye Attorney No. #205316 Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 (800) 850-1079 Dated: July 5, 2011 Blatt, Hasenmiller, Leibsker & Moore, LLC Daniel Santucci, Attorney I.D. #92800 Gregory R. Dye, Attorney I.D. #205316 1835 Market Street, Suite 501 Philadelphia, PA 19103 800-850-1079 Attorney for Plaintiff, PORTFOLIO RECOVERY ASSOCIATES LLC PORTFOLIO RECOVERY ASSOCIATES LLC c/o Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 Plaintiff, vs. WILLIAM FORD 418 4TH ST NEW CUMBERLND PA 17070-1801 Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: County of Chester: I, Daniel Santucci/Gregory R. Dye, being duly sworn according to law, depose and say I am the attorney for Plaintiff and I am authorzied to make this affidavit on Plaintiff's behalf. I hereby certify that the Defendant is at least 18 years of age and not in the Military Service of the United States, nor any State or Territory thereof or its allies as defined in the Servicemembers' Civil Relief Act of 2004 and any amendments thereto. I also herby certify that the statements made in the foregoing Affidavit of Non-Military Service are true and correct to the best of my information, knowledge, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities. BLATT, Hi & MOORE Dated: July 5, 2011 By: Gregory SKER 2638291 PPTJCAM I 1111111111111111111111111111111111111111111111111111111 VERIFICATION the undersigned attorney for the Plaintiff, hereby verify that the statements made in the foregoing Complaint are true and correct to the best of my knowledge, information, and belief, based upon information provided by the Plaintiff, that the Plaintiff is presently located outside of this jurisdiction, and that in order to file the within document in an expedient and timely manner I am authorized to sign this verification on behalf of the Plaintiff. I understand that false statements herein are made subject to the peWies of 18 Pa.C.S. Section 4904 relating to unsworn falsifications to authorities. PPTXVERI Exhibit "All PPTXEXAI AFFIDAVIT State of Virginia City of Norfolk ss. 2O?Opl I, the undersigned Cristina Patterson Custodian of Records, for Portfolio Recovery Associates, LLC , hereby depose, affirm and state as follows: 1. I am competent to testify to the matters contained herein. 2. I am an authorized employee of Portfolio Recovery Associates, LLC, ("Account Assignee) which is doing business at Riverside Commerce Center, 140 Corporate Boulevard, Norfolk, Virginia, and I am authorized to make the statements, representations and averments herein, and do so based upon a review of the business records of the Account Assignee and those records transferred to Account Assignee from HSBC BANK NEVADA, MA./UNION PRIVILEGE ("Account Seller"), which have become a part of and have integrated into Account Assignee's business records, in the ordinary course of business. 3. According to the business records, which are maintained in the ordinary course of business, the account, and all proceeds of the account are now owned by the Account Assignee, all of the Account Seller's interest in such account having been sold, assigned and transferred by the Account Seller on 5/25/2010. Further, the Account Assignee has been assigned all of the Account Seller's power and authority to do and perform all acts necessary for the settlement, satisfaction, compromise, collection or adjustment of said account, and the Account Seller has retained no further interest in said account or the proceeds thereof, for any purpose whatsoever. 4. According to the records transferred to the Account Assignee from Account Seller, and maintained in the ordinary course of business by the Account Assignee, there was due and payable from WILLIAM FORD ("Debtor and Co- Debtor") to the Account Seller the sum of $13,578.13 with the respect to account number ending in 0598) as of the date of 11/30/2009 with there being no known un-credited payments, counterclaims or offsets against the said debt as of the date of the sale. Plaintiff believes that the defendant is not a minor or an incompetent individual, and declares that the Defendant is not on active military service of the United States. 5. According to the records of said Account Assignee, after all known payments, counterclaims, and/or setoffs occurring subsequent to the date of sale, there was due and owing at the time this lawsuit was filed a sum of $13,578.13. LLC P lio R v egAsswia?e t r" Cristina Patterson , Custodian of Records By: Subscribed and sworn to befpre me on JUN 0 M11 /1 r - Jamie DeAnn Lemaster Public Commonwealth of Virginia CommissW No. 7204490 4--'lean; Notary Public My Commisslon lixpl= 0113112012 This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. Blatt, Hasenmiller, Leibsker & Moore, LLC Daniel Santucci Attorney I.D. # 92800 Gregory R. Dye Attorney LD #205316 1835 Market Street, Suite 501 Philadelphia, PA 19103 610-902-0644 Attorney for Plaintiff, PORTFOLIO RECOVERY ASSOCIATES LLC PORTFOLIO RECOVERY ASSOCIATES LLC c/o Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 Plaintiff, vs. WILLIAM FORD 418 4TH ST NEW CUMBERLND PA 17070-1801 Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA ° ?s CIVIL ACTION r-nm c.. -? No. 3`1 c ( 14 C-) C ?c CD w PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY: Kindly ENTER my appearance in the above-captioned matter on behalf of PLAINTIFF PORTFOLIO RECOVERY ASSOCIATES LLC. Papers may be served at the address set forth below: Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 Telephone Number: 1-610-902-0644 BLATT, HA & MOORE, Dated: July 5, 2011 By: 2638291 PPTXPEAI I I I IN IN III III IN 11111111111111111111111111 IN Gregory R. Dye SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson : , ,,. r Sheriff f !LL - t ` { Jody S Smith Chief Deputy U! ! AUG -S Fit 2 ( N Richard W Stewart E. U, i Solicitor ' ENN S Y LVA H I A Portfolio Recovery Associates, LLC vs. Case Number William R. Ford 2011-5734 SHERIFF'S RETURN OF SERVICE 07/28/2011 04:21 PM - Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on July 28, 2011 at 1621 hours, she served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: William R. Ford, by making known unto himself personally, at 418 4th Street, New Cumberland, Cumberland County, Pennsylvania 17070 its contents and at the same time handing to him personally the said true and correct copy of the same. AMANDA COBAUGH, DEPU SHERIFF COST: $45.00 August 02, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF S . Blatt, Hasenmiller, Leibsker & Moore, LLC Attorney for Plaintiff, Daniel Santucci PORTFOLIO RECOVERY ASSOCIATES LLC Attorney I.D. #92800 1835 Market Street, Suite 501 Philadelphia, PA 19103 800-850-1079 PORTFOLIO RECOVERY ASSOCIATES LLC c/o Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 Plaintiff, vs. WILLIAM FORD 418 4TH ST NEW CUMBERLND PA 17070-1801 Defendant(s). IN THE COURT OF COMMON PLEAS cn PA C CUMBERLAND COUNTY N o ?t -rl , rn 00 CIVIL ACTION z? c .?0 ? No. 11-5734-CIVIL Ic ? a C-; ? C? -n C C- PRAECIPE FOR ENTRY OF JUDGMENT BY DEFAULT FOR FAILURE TO PLEAD TO THE PROTHONOTARY: Kindly ENTER a JUDGMENT BY DEFAULT FOR FAILURE TO PLEAD against the DEFENDANT WILLIAM FORD in this matter in the amount of $13,578.13 plus court costs. I also hereby certify that a true and correct copy of the Notice required by Pa.R.C.P. 237.1(a)(2) was mailed separately to each defendant on 8-26-11 by regular mail. A true and correct copy of each Notice is attached hereto. Dated: September 7, 2011 Respectfully submitte BLATT, HASE I LER, LE KER & MOORE, L By: -91q.66 2638291 PPTJPFJI 1111111111111111111111111111111111111111111111111111111111111 IN W rss y? fti - p??yJ??w Blatt, Hasenmiller, Leibsker & Moore, LLC Attorney for Plaintiff, Daniel Santucci, Attorney I.D. #92800 PORTFOLIO RECOVERY ASSOCIATES LLC Gregory R. Dye, Attorney I.D. #205316 1835 Market Street, Suite 501 Philadelphia, PA 19103 800-850-1079 PORTFOLIO RECOVERY ASSOCIATES LLC c/o Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 Plaintiff, vs. WILLIAM FORD 418 4TH ST NEW CUMBERLND PA 17070-1801 Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. 11-5734-CIVIL AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: County of Chester: I, Daniel Santucci/Gregory R. Dye, being duly sworn according to law, depose and say I am the attorney for Plaintiff and I am authorzied to make this affidavit on Plaintiff's behalf. I hereby certify that the Defendant is at least 18 years of age and not in the Military Service of the United States, nor any State or Territory thereof or its allies as defined in the Servicemembers' Civil Relief Act of 2004 and any amendments thereto. I also herby certify that the statements made in the foregoing Affidavit of Non-Military Service are true and correct to the best of my information, knowledge, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities. Dated: September 7, 2011 2638291 PPTJCAMI 11111111111111111111111111111111111111111111111111111111111111 IN BLATT, HASE & MOORE, LX By: Danibf'Santucci Gregory R. Dye L PORTFOLIO RECOVERY ASSOCIATES LLC Plaintiff, vs. WILLIAM FORD 418 4TH ST NEW CUMBERLND PA 17070-1801 Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. 11-5734-CIVIL TO: WILLIAM FORD Date of Notice: August 26, 2011 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY 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. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 267-2032 BLATT, HASENMILLER, LEIBSKER & MOORE, L C By: Daniel Santucci 1835 Market Street, Suite 501 Philadelphia, PA 19103 800-850-1079 This is a communication from a debt collector. This is an attempt to collect a debt and any information obtained will be used for that purpose. 2638291 PPTNLRSI ?Ililil 1111111 111111 If?l IIIII IIIII IIIII 11111 IIIII I?illl II IIII PORTFOLIO RECOVERY ASSOCIATES LLC Plaintiff, WILLIAM FORD vs. 418 4TH ST NEW CLIMBERLND PA 17070-1801 Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. No. 11-5734-CIVIL TO: WILLIAM FORD NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Default Judgment has been entered against you in the above proceeding. Dated: Q PROTHONOTARY By: IF YOU HAVE ANY QUESTIONS CONCERNING THE ABOVE, PLEASE CONTACT: Attorney of Record for Plaintiff: Blatt, Hasenmiller, Leibsker & Moore, LLC Daniel Santucci Attorney I.D. #92800 1835 Market Street, Suite 501 Philadelphia, PA 19103 800-850-1079 2638291 PPTNDJNI 1111111111111111111111111111111111111111111111111111111111111 IN