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Home My WebLink About11-8494 2116207 THIS IS AN ARBITRATION MATTER. -, ASSESSMENT OF DAMAGES HEARING REQU, , 71 --a GORDON & WEINBERG, P.C. `rn CD BY: FREDERIC I. WEINBERG, ESQUIRE `ice Identification No.: 41360 JOEL M. FLINK, ESQUIRE n -a ?- Identification No.: 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 Main Street Acquisition Corp. P.O. BOA: 2529, SUWANEE, GA 30024 Vs. COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. 1 I, ?( Y LORI BARRICK 8 TOPVIEW DR Carlisle PA 17015-9532 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 Qa) ga.?Pd C?? ? X7073 / ?2oa aU COMPLAINT IN CIVIL-ACTION 1. Plaintiff, Main Street Acquisition Corp. a debt buyer and successor in interest to the original creditor, HSBC BANK NEVADA NA :Issuer of Direct Merchants Mastercard. 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)tae 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 September 23, 2011 in the amount of $3,986.71. 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 06/29/2008. WHEREFORE, plaintiff claims of the defendant(s) the sum of $3,986.71 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDERIC I. JOEL M. FLIN Attorney for A RG, ESQUIRE UIRE aintiff P01P.DB 2116207 10981617 Main Street Acquisition Corp. LORI BARRICK 5458001553456421 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 penaltiep for making false statements. ?,t NAME: ?? I Katresha Mughley EXHIBIT "A" • LORI BARRICK 5458001553456421 2116207 Main Street Acquisition Corp. AFFIDAVIT I , Katrpwu- huynlcy law, depose and say that: being duly served sworn according to 1. I am an affiant 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 Main Street Acquisition Corp. upon the purchase of debtor's account, which was issued by HSBC BANK NEVADA NA Issuer of Direct Merchants Mastercard. 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 $3,454.18 plus interest of $522.88 at the rate of 6% less credits in the amount of $.00 totaling $3,977.06 as of September 6, 2011. 6. If called upon, affiant can testify at trial as to the facts pertaining to this matter. The above facts are"true and cor t to e?est of my knowledge, information and belief. AFFIANT/NAME: Sworn to and Subscribed befor e this ?? da of 2011 Notary Public ?GITE .., ?j ..., F H".. ri n :. ?,OTA,9 + • lousUG az Co U N % ? l11111? Katresha hughley SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor vow' t ?. OFFICE FIL D` z' 1-1E PiF 0I'll OPSt',TE?tr, . 2311 NOV 28 AM 8: 41 CUMBERLAND COLIN'T j PENNSYLVANIA Main Street Acquisition Corp. Case Number vs. Lori Barrick 2011-8494 SHERIFF'S RETURN OF SERVICE 11/17/2011 03:50 PM - William Cline, Corporal, who being duly sworn according to law, states that on November 17, 2011 at 1550 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Lori Barrick, by making known unto herself personally, at 8 Topview Drive, Carlisle, Cumberland County, Pennsylvania 17015 its contents and at the same time han ing to her personally the said true and correct copy of the same. f,. WILLIAM LINE, DEPUTY SHERIFF COST: $34.00 November 18, 2011 SO ANSWERS, RONI'V R ANDERSON, SHERIFF r. Coun'? a ? ^er?.•t f ?, ? uYf. Ir,;. 2116207 0 THoli 0TA 2814 -9 411112 5 GORDON & WEINBERG, P. C. CUNB o, BY: IdeDtRificationlNoERG41360UIRE p��SYCVq /A��/ JOEL M. FLINK, ESQUIRE Identification No. : 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 Main Street Acquisition Corp. COURT OF COMMON PLEAS CUMBERLAND COUNTY vs . DOCKET NO. : 11-8494 CIVIL LORI BARRICK ORDER TO SETTLE, DISCONTINUE AND END TO THE PROTHONOTARY: ERE Kindly mark the above-captioned matter settled, discontinued and EEIE ended upon payment of your costs only. GORDON & WEINBERG, P.C. BY: FREDE,' WEINBERG, ESQUIRE JOEL M. LINK, ESQUIRE Attorney for Plaintiff P003