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Home My WebLink About11-7367 2114549 ' THIS IS AN ARBITRATION MATTER. -per -- -d ASSESSMENT OF DAMAGES HEARING REQUIRE Ql r?o !? s GORDON & WEINBERG, P.C. N "3:-", BY: FREDERIC I. WEINBERG, ESQUIRE tom- Identification No.: 41360 JOEL M. FLINK, ESQUIRE ? Identification No.: 41200 - 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 Razor Capital II, LLC COURT OF COMMON PLEAS 8000 Norman Center Drive, CUMBERLAND COUNTY Bloomington, MN 55437 Vs. DOCKET NO. KELLI FRAKER 55 WARWICK CIR MECHANICSBURG PA 17050 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 Qom} ?9 a•? ? ° ? C?-? ASS ?? a? s,31? vr"wL COMPLAINT IN CIVIL-ACTION 1. Plaintiff, Razor Capital II, LLC a debt buyer and successor in interest to the original creditor, Credit One Bank, N.A.. 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 defend- ant(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 18, 2011 in the amount of $1,965.72. 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 1/11/2010. WHEREFORE, plaintiff claims of the defendant(s) the sum of $1,965.72 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDERIC I. WF NBERG, ESQUIRE JOEL M. FLI , ESQUIRE Attorney for. Plaintiff POIP.DB f 2114549 23RO7883 Razor Capital II, LLC KELLI MAKER 4447962140453543 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. -2 TODD ANDERSON, DIRECTOR OF OPERATIONS EXHIBIT "A" I ' l 2114549 Razor Capital II, LLC KELLI FRAKER 4447962140453543 State of Minnesota § County of Hennepin § AFFIDAVIT I, TODD ANDERSON being duly served sworn according to law, depose and say that: 1. I am employed as the legal outsourcing clerk for the Plaintiff herein and I have custody and control of the files relating to this account; 2. I have personal knowledge of the facts and circumstances in connection with this case and base this affidavit on Plaintiff's records, as well as the account information provided to Plaintiff by credit One Bank, N.A. when Credit One Bank, N.A. sold the account to Razor Capital II, LLC. 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 $1,595.29 plus interest of $359.98 at the rate of 23.9% less credits in the amount of $.00 totaling $1,955.27 as of August 8, 2011. 6. If called upon, affiant can testify at trial as to the facts pertaining to this matter. The above facts are true and correct t e best of my knowledge, information and belief. TODD ANDERSON, DIRECTOR OF OPERATIONS Sworn to and Subscribed before me this day of f 1 rV) , 2011 Ange se Phyllis Doylel is NOTARY PUBLIC -- _ = MINNESOTA 2016 My Commission Exp+res Jan. 31, SHERIFF'S OFFICE OF CUMBERLAND COUNTY F ! t» r Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor 4 ! C'rT 28 A Razor Capital II, LLC Case Number vs. Kelli Fraker 2011-7367 SHERIFF'S RETURN OF SERVICE 10/25/2011 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Kelli Fraker, but was unable to locate her in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant Kelli Fraker. Request for service at 55 Warwick Circle, Mechanicsburg, Pennsylvania 17050 the Defendant was not found. Deputies were advised, current occupants moved to this residence in May of 2011. SHERIFF COST: $43.00 SO ANSWERS, October 25, 2011 RON R ANDERSON, SHERIFF (Ci CoumySutt" Sher,ff. Teieas<>fi b;c � � David-D.`'ue� Trothonotary �-�n � ()f7�C�n�fO��/u�Q�y/[>t��V '�L/ - } ` ~ ~~�_/ C»m5errand County, Tennsylvania -~rk_,--` ESQ Solicitor �� ~� �� . � r� CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS Z8r*DAY OFOCTOBER, ZO14,AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE -THE ABOVE '[ASE|SHERE8YTERk4|NATEOVVITHPRBUD|CE|NA[[ORDANCEVV|TH BY THE COURT, DAVID D. BUELL