HomeMy WebLinkAbout11-60752108911
THIS IS AN ARBITRATION MATTER.
DAMAGES HEARING REQUIRED.
GORDON & WEI BERG, P.C.
BY: FREDERI I. WEINBERG, ESQUIRE
Identif cation No.: 41360
JOEL M.IFLINK, ESQUIRE
Identification No.: 41200
1001 E. Hector Street, Ste 220
Conshohocken, PA 19428
484/351-0500
ASSESSMENT OF
Asset Acceptance, LLC assignee
of Citibank
28405 Van Dye Avenue
Warren, MI 8093
VS.
DAVID A RIPP L
6319 CHESTER IELDLN
MECHANICSBUR PA 17050
YOU HAVE
FORTH IN THE FO
THIS COMPLAINT
OR BY ATTORNEY
TO THE CLAIMS
THE CASE MAY PI
THE COURT WITH(
ANY OTHER CLAI
PROPERTY OR OTf
rn ?.
cn?
COURT OF COMMON PLEAS > o
CUMBERLAND COUNTY ? c o
--4
DOCKET NO.
Fri
7 -?
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NOTICE
BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIMS SET
GLOWING PAGES, YOU MUST TAKE ACTION WITHIN TWENTY (20) DAYS AFTER
kND NOTICE ARE SERVED, BY ENTERING A WRITTEN APPEARANCE PERSONALLY
AND FILING IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS
;ET FORTH AGAINST YOU. YOU ARE WARNED THAT IF YOU FAIL TO DO SO
:OCEED WITHOUT YOU AND A JUDGEMENT MAY BE ENTERED AGAINST YOU BY
)UT FURTHER NOTICE FOR ANY MONEY CLAIMED IN THE COMPLAINT OR FOR
4 OR RELIEF REQUESTED BY THE PLAINTIFF. YOU MAY LOSE MONEY OR
[ER RIGHTS IMPORTANT TO YOU.
YOU SHOD D 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
004 Jga.OOP4 41?
clc,-Al s3G c%
LW Dud-686
COMPLAINT IN CIVIL-ACTION
1. Plaintiff is a debt buyer and successor in interest to
the origina? creditor as set forth in the caption of this
Complaint.
2. Atl all times relevant hereto, the defendant(s) was the
holder of a ccard, 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 ?nd 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 availably, 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 June 7, 2011 in
the amount ?f $10,242.58.
6. P}aintiff 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.
2108911
40160411
Asset Acceptance, LLC assignee of
Citibank
DAVID A RIP EL
54241804848 7431
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 ids 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 PAMELA MCCULLOUGH
2277 2108911
40160411
Asset Acceptance, LLC assignee of
Citibank
DAVID A RIP EL
54241804848 7431
AFFIDAVIT
I , PAMELA WCULLOUGH being duly served sworn according to
law, depose and say that:
1. am the agent for the Plaintiff herein and I have custody
and control of the files relating to this account;
2. have knowledge of the facts and circumstances in
connection ?ith this case;
3. plaintiff's files are maintained in the usual and ordinary
course of b siness;
4. his action is based on a claim for breach of contract and
that damage are sought as a direct result of said breach;
5. There is now due and owing from defendant to plaintiff, the amount
of $6,284.1 plus interest of $3,665.10 at the rate of 24% less credits in
the amount o $.00 totaling $9,949.21 as of March 28, 2011.
6.f called upon, affiant can testify at trial as to the
facts perta ning to this matter.
The above facts are true and corr to the best of my 1
knowledge, information and belief.
Al,
I
AFFIANT
Sworn to and Subscribed
before me this day
MY 2W 1 2011 r^
Notar Public
AA
lHAWM
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff °ILL 0FFI, 4
of ?a?
?ttitr rtbTy?
Jody S Smith 1fl ? P R, U t , ir?J ?•
'v
Chief Deputy 21 11 AUG 10 PH 2: 11
Richard W Stewart
Solicitor „.: _;UMBERLAND C:UU"1"`.
PE€ NSYLVAt,lIA
Asset Acceptance LLC
vs. Case Number
David A. Rippel 2011-6075
SHERIFF'S RETURN OF SERVICE
08/04/2011 03:17 PM - Michelle Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on
August 4, 2011 at 1517 hours, she served a true copy of the within Complaint and Notice, upon the within
named defendant, to wit: David A. Rippel, by making known unto Pat Rippel, Mother of Defendant at 6319
Chesterfield Lane, Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same
time handing to her personally the said true and correct copy of the same.
MICH PLLEGUTSHALL, DEPUTY
SHERIFF COST: $38.00
August 05, 2011
SO ANSWERS,
RON R ANDERSON, SHERIFF