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Home My WebLink About11-8524 2116211 THIS IS AN ARBITRATION MATTER. ASSESSMENT OF DAMAGES HEARING REQUWED. GORDON & WEINBERG, P.C. rn Co rn BY: FREDERIC I. WEINBERG, ESQUIRE :z X= .< -,r- Ident:ification No.: 41360 ,(n<Sr, c5o JOEL M. FLINK, ESQUIRE <d = o Identification No.: 41200 Dn = CD o -n 1001 E. Hector Street, Ste 220 =C 2> _ CDrm C Conshohocken, PA 19428 = --q Cn 484/351-0500 ° Main Street Acquisition Corp. COURT OF COMMON PLEAS P.O. BOX 2529, SUWANEE,GA 30024 CUMBERLAND COUNTY VS. DOCKET NO. JEAN M HARRINGTON 900 SCOTTISH CT Mechanicsburg PA 17050-1807 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 CO (717) 249-3166 --?Lpgl R z' 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 Union Privil. Plat. 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 20, 2011 in the amount of $8,329.95. 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 08/24/2008. WHEREFORE, plaintiff claims of the defendant(s) the sum of $8,329.95 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDERIC I. WE BERG, ESQUIRE JOEL M. FLI , ESQUIRE Attorney for Plaintiff P01P.DB 2116211 10984190 Main Street Acquisition Corp. JEAN M HARRINGTON 5407070006998349 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. EXHIBIT "A" 2116211 Main Street Acquisition Corp. JEAN M HARRINGTON 5407070006998349 AFFIDAVIT Katre;,;,:: ; ;ughley I, 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 Union Privil. Plat. 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 $7,220.24 plus interest of $1,093.09 at the rate of 6% less credits in the amount of $.00 totaling $8,313.33 as of September 6, 2011. 6. If called upon, affiant can testify a tri 1 as to the facts pertaining to this matter. The above facts are true and corr to?e bes of my knowledge, information and belief. rj. AFF Sworn to and Subs before me this 1/-' -1 day of f 011\-? N tary Public i? `?\111i11fft \CITE • O ?? • .9A ti ?O? CoUN,0 `Cl Katru;?u Hughley SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ???i°ti1?, ?f ?luntrrtl,r?ta sit) t. { d_ .,.?!r; Tu (j t %t I ! NOY 28 AM 8: 42 4UMBERLAND C-IU Tyr 'EMNSYl-W, 41A Jody S Smith Chief Deputy Richard W Stewart Solicitor Main Street Acquisition Corp. Case Number vs. Jean M. Harrington 2011-8524 SHERIFF'S RETURN OF SERVICE 11/17/2011 03:53 PM - Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on November 17, 2011 at 1553 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Jean M. Harrington, by making known unto Paul Harrington, Husband of Defendant at 900 Scottish Court, Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time handing to him personally the said true and correct copy of the same. -A? L)46? GERALD WORTHINGT DEPUTY SHERIFF COST: $38.00 November 18, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF culnt,su fe o ;0}t. Inc. i GORDON & WEINBERG, P C. BY: FREDERIC I. WEINBERG, ESQUIRE IdentificationlNo.: 41360 JOEL M. FLINK, (ESQUIRE Identification!,No.: 41200 1001 E. Hector Street Ste 220 Conshohocken, PA 19 28 484/351-0500 OF THF1110' D1VDYpRY 2011 DEC 27 PM 2: 17 CUMBERLAND COUNTY PENNSYLVANIA Main Street Acquisition Corp VS. JEAN M HARRINGTON TO THE PROTHONOTARY:? COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 2011-08524 Enter judgment for want of an answer for plaintiff and against defendant(s) JEAN M WARRINGTON above named only and assess damages certified to be calc lable as a sum certain from the complaint, as follows: Principal Interest from 02/28/2009 @60 Costs (Complaint & Service) Less,: Payment on Account Total: $7,220.24 $1,217.72 $130.00 ( $.00) $8,567.96 Understanding the fa?se statements made herein are subject to penalty under 18 Pa.C.S.A. 904, Unsworn Falsification to Authorities, I verify that: j 1. The last ]mown addresses of the parties are: Main Street Acquisition Corp. Land that the last known address of defendant, JEAN M HARRINGTON, 9?0 SCOTTISH CT, Mechanicsburg PA 17050-1807. 2. The annexed notice(s) of intention to file this praecipe was (were) mailed to all parties, defendant and to their record attorneys, if any, after default occurred, and at least ten days prior to the date of filing of this praecipe. 3. The said efendant(s) is (are) not in the military service of the United States or otherwise within the coverage of the Soldiers and Sailors Civil Re ief Act and is (are) over 18 years of age. au•? ? /y °°?d A ?" c?N ?(,aosy ]A A AND NOW, this y`-? day of _J?A ( - 2011 Judgment is entered in favor of the plaintiff(s) and against defendant(s) by default for want of an answer and d age ss d at the um of , $8,567.96 as per thejabove certifica 'on. Prothonot GORDON & WEINBERG, P. BY: FREDERIC I. EIN RG, ESQUIRE JOEL M. FLI SQUIRE Attorney for Plaintiff 2116211 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 Main Street Acquisit'on Corp. vs. ll JEAN M HARRINGTON 900 SCOTTISH CT Mechanicsburg PA 1700-1807 III COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 2011-08524 NOTICE Pursuant to Pa.R.Civ P. 236 of the Supreme Court of Pennsylvania, you are hereby notified hat a judgment has been entered against you in the above proceedingi,as indicated below. IXI Judgment by Default $8,567.96 Money Judgment $ Judgment on Award of Arbitrators$ Judgment on Verdict$ IF YOU HAVE ANY QUES IONS CONCERNING THIS NOTICE, PLEASE CALL ATTORNEYS: FREDERIC WEINBERG OR JOEL FL K, E UIRES AT TkqS TELEPHONE NUMBER: 484/351-0500 / PROTHONOTARY 2116211 GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBEjRG, ESQUIRE Identification No.',: 41360 JOEL M. FLINK, ESQUIRE Identification No.',: 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 Main Street AcquisitionCorp. COURT OF COMMON PLEAS CUMBERLAND COUNTY III Vs. DOCKET NO. : 2011-08524 JEAN M HARRINGTON TO/PARA DEFAULT JEAN M HARRINGTON 900 SCOTTISH CT Mecha csburQ PA 17050-1807 DATE OF NOTICE/FECHA DE4 AVISO: December 8, 2011 nVORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY AN ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE T IS 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. ERLAND COUNTY BAR ASSOCIATION 32 S. BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 GORDON & WEINBERG, P.C. BY. FREDERIC!/.'WEINBERG, ESQUIRE JOEL M.F NK, ESQUIRE P10D-2