HomeMy WebLinkAbout11-69052112644
GORDON & WEINBERG, P.C. C-)
BY: FREDERIC I. WEINBERG, ESQUIRE C -°
Identification No.: 41360 zm C
JOEL M. FLINK, ESQUIRE
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Identification No.: 41200 rnD o ;0t-1
1001 E. Hector Street, Ste 220 r- + -to
Conshohocken, PA 19428
484/351-0500 _ C
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VION HOLDINGS LLC COURT OF COMMON PLEAS<
400 Interstate North Pkwy, CUMBERLAND COUNTY
THIS IS AN ARBITRATION MATTER.
ASSESSMENT OF DAMAGES HEARING REQUIRED.
Atlanta GA 30339
VS.
DOCKET NO
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BECKY DECHENE
356 SAWMILL RD
NEWVILLE PA 17241
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
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COMPLAINT IN CIVIL-ACTION
1. Plaintiff, VION 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 $1,084.08.
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 9/13/2009.
WHEREFORE, plaintiff claims of the defendant(s) the sum of
$1,084.08 plus applicable costs, interest and attorney's fees.
GORDON & WEINBERG, P.C.
BY:
FREDERIC I. WEINBERG, ESQUIRE
JOEL M. FLINK, ESQUIRE
Attorney for Plaintiff
2112644
VION HOLDINGS LLC
BECKY DECHENE
2116040900273809
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"
2112644
VION HOLDINGS LLC
BECKY DECHENE
2116040900273809
State of Georgia §
County of Cobb §
AFFIDAVIT
that:
I, MARIA SELAGEA, being duly served sworn according to law, depose and say
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 VION 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
$1,084.08 plus interest of $.00 at the rate of 0% less credits in the amount of $.00
totaling $1,084.08 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 S, OPERATIONS MANAGER
Notary Publ
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Sworn to and Subscribed
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before me this Z day
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
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Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
2311 PICT -3 AM 9: 51
'CUMBERLAND
PENNSYLVA, 1A
Vion Holdings, LLC
vs.
Becky K. Dechene
Case Number
2011-6905
SHERIFF'S RETURN OF SERVICE
09/27/2011 10:45 AM - William Cline, Corporal, who being duly sworn according to law, states that on September 27,
2011 at 1045 hours, he served a true copy of the within Complaint and Notice, upon the within named
defendant, to wit: Becky K. Dechene, by making known unto herself personally, at The Cumberland
County Sheriffs Office, 1 Courthouse Square, Room 303, Carlisle, Cumberland County, Pennsylvania
17013 its contents and at the same time handing to her personally the said true and correct copy of the
same.
WILLIAM CLINE, DEPUTY
SHERIFF COST: $40.00
September 28, 2011
SO ANSWERS,
RON R ANDERSON, SHERIFF
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