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HomeMy WebLinkAbout11-69042112648 GORDON & WEINBERG, P.C. C-) p BY: FREDERIC I. WEINBERG, ESQUIRE (= o Identification No.: 41360 ma) JOEL M. FLINK, ESQUIRE 2x -p -,r'- Identification No.: 41200 cnr + ?'© 1001 E. Hector Street, Ste 220 <o °' o? Conshohocken, PA 19428 3>c") x o--n 484/351-0500 Dc Q VION HOLDINGS LLC COURT OF COMMON PLEAFK Pv 400 Interstate North Pkwy, CUMBERLAND COUNTY THIS IS AN ARBITRATION MATTER. ASSESSMENT OF DAMAGES HEARING REQUIRED. Atlanta GA 30339 VS. DOCKET NO. 76`0 7 y JOHN NOONAN 526 TERRACE DR NEW CUMBERLAND PA 17070 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, 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 )p #7 A 1 ?&-5- 0 57 't ?) - &0 ?d Al?l e *13(91 COMPLAINT IN CIVIL-ACTION 1. Plaintiff, VIOLA HOLDINGS LLC a debt buyer and successor in interest to the original creditor, HSBC BANK NEVADA NA. 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 merchandise 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 16, 2011 in the amount of $1,006.09. 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 7/25/2009. WHEREFORE, plaintiff claims of the defendant(s) the sum of $1,006.09 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C BY: FREDERIC I. WE-INBERG, ESQUIRE JOEL M. FLINK, ESQUIRE Attorney for Plaintiff 2112648 VION HOLDINGS LLC JOHN NOONAN 2116041017429318 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. MARIA SELAGEA EXHIBIT "A" 2112648 VION HOLDINGS LLC JOHN NOONAN 2116041017429318 State of Georgia § County of Cobb § AFFIDAVIT I, MARIA SELAGEA, being duly served sworn according to law, depose and say that: 1. I am an authorized representative of Vion Holdings, LLC which is the record holder for VION HOLDINGS LLC with full authority to make this Verification on behalf of VIOLA HOLDINGS LLC. Plaintiff the current owner of, and successor to, the obligation sued upon, and was assigned all the rights, title and interest to defendant's account as assigned to Vion Holdings, LLC by the original creditor or its assignee; 2. Plaintiff's files are maintained in the usual and ordinary course of business; 3. This action is based on a claim for breach of contract and that damages are sought as a direct result of said breach; 4. There is now due and owing from defendant to plaintiff, the amount of $1,006.09 plus interest of $.00 at the rate of 0% less credits in the amount of $.00 totaling $1,006.09 as of 7/7/11. 5. If called upon, affiant can testify at trial as to the facts pertaining to this matter. The above facts are true and correct to the best of my knowledge, information and belief. MARIA SELAGEA, OPERATIONS MANAGER Sworn to and Subscribed before me this day of 2011 ?P1NE p Notary Public _ m. =GZ a w? ;r.A% UC+ iO2 r ? F 20 20'g'•?? ?Z ' NTY, 1111111 Office of - - _/ +�~/��«f�~?t�)t«�V �y�6 /Tnnvtu - - '��/' - —'/''_'-- '`rk,-.-''u`--Q. Solicitor N.-09401/ CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 28TH 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 PA R]C.P.230.2. BY THE COURT, DAVID D. BUELL PROTHONOTARY