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HomeMy WebLinkAbout11-6903 2107635 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 Asset Acceptance, LLC assignee of Chase Bank 28405 Van Dyke Avenue Warren, MI 48093 VS. HARPREET GULERIA MR-1920 KENT DR CAMP HILL PA 17011-5930 ASSESSMENT OF Cl) _ ° C _q -1 =; rn - 0 Nt"' ? o qC7 v orl ?? x• CD g a o s o r' c:n COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. q(7_ j 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 ]?ORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 50 C# is-G0-7 ? ?# a64/asa ( 7 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 August 31, 2011 in the amount of $1,752.31. 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 11/5/2007. WHEREFORE, plaintiff claims of the defendant(s) the sum of $1,752.31 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDERIC I. EIN ERG, ESQUIRE JOEL M. FLIN SQUIRE Attorney for Plaintiff P01A.DB 2107635 41328061 Asset Acceptance, LLC assignee of Chase Bank HARPREET GULERIA 1820000001714571 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 v PAMELA MCCULLOUGH EXHIBIT "A" 2277 2107635 41328061 Asset Acceptance, LLC assignee of Chase Bank HARPREET GULERIA 1820000001714571 AFFIDAVIT I,PAMELA "IN I I .H being duly served sworn according to law, depose and say that: 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 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 $1,115.69 plus interest of $550.79 at the rate of 18% less credits in the amount of $.00 totaling $1,666.48 as of March 28, 2011. 6. If called upon, affiant can testify at trial as to the facts pertaining to this matter. The above facts are true and corr t o the best of my knowledge, information and belief. iZA AFFI T Sworn to and Subscribed before me this day APR 2 7 2011 2011 Notary `Public -MArnum Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor Asset Acceptance LLC vs. Harpreet S. Guleria ?ti?4?tp Qf t?iun&???a tifr OFF CE OF ..c c?4ERIFf r 2011 HP 26 PM 2: 21 PENNSYI-VANIA I Case Number 2011-6903 SHERIFF'S RETURN OF SERVICE 09/22/2011 Ronny R. Anderson, Sheriff, who being duly sworn according to law, and inquiry for the within named defendant to wit: Harpreet S. Guleria, but was una bailiwick. He therefore returns the within Complaint and Notice as not foUes that he made a diligent search S. Guleria. Request for service at 1920 Kent Drive, Cam ble to locate him in his nd as defendant Harpreet p Hill, Pennsylvania 17011 the Defendant was not found. Current tenant of this address has resided here since May 2011 and to does the not know Defendant. The Camp Hill Postmaster has advised they are unable to forward H the SHERIFF COST: $48.00 arpreet S. Guleria's mail. SO ANSWERS, September 22, 2011 4RRRON7ACNDE-RSON, SHERIFF SHERIFF'S OFFICE OF CUMgERLAN D COUNTY (?i CountySuite Sh<?n,ff, Teieos??`t. Inc. r ' 2107635 GORDON & WEINBERG, P.C. B`.': 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 Chase Bank VS. HARPREET GULERIA 00 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 11-6903 CIVIL TERM PRAECIPE TO WITHDRAW COMPLAINT TO THE PROTHONOTARY: Kindly withdraw the above-captioned action, without prejudice. GORDON & WEINBERG, P.C. JV BY: l FREDERIC I. IN RG, ESQUIRE JOEL M. FLINK;---ESQUIRE Attorney for Plaintiff P006 CERTIFICATION OF SERVICE I, FREDERIC I. WEINBERG, ESQUIRE, hereby certify that I, on -he date below, served a copy of the Praecipe to Withdraw Complaint to Pa.R.C.P. 1028(c)(1), via First Class Mail, postage ore-paid, to all other parties or their counsel of record. FREDERIC I. W IN RG, ESQUIRE Dated {, ?' '