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Home My WebLink About12-08182122073 THIS IS AN ARBITRATION MATTER. ASSESSMENT OF DAMAGES HEARING REQUIRED. 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 Unifund Corporation 10625 Techwoods Circle, Cincinnati OH 45242 vs. CATHERIN GALENA 460 STONE CHURCH RD CARLISLE PA 17015 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : IA_ 818 NOTICE a fY^r -? > co ?.v rk Civ i1Term 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 O 32 S. BEDFORD STREET 103.75 PO ArrY CARLISLE, PA 17013 a-*)(f605Lf (717) 249-3166 0108a8 COMPLAINT IN CIVIL-ACTION 1. Plaintiff, Unifund Corporation , is a debt buyer and successor in interest to the original creditor, CITIBANK SOUTH DAKOTA 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 January 27, 2012 in the amount of $7,071.49. 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 8/16/2009. WHEREFORE, plaintiff claims of the defendant(s) the sum of $7,071.49 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDERIC (. WZINBERG, ESQUIRE JOEL M. F , ESQUIRE Attorney for Plaintiff P01P.DB 2122073 U3994389 Unifund Corporation CATHERIN GALENA 5256502246310200 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. NAME: 3yo 'Brat EXHIBIT "A" 2122073 Unifund Corporation CATHERIN GALENA 5256502246310200 AFFIDAVIT I,? being duly served sworn according to law, depose and say that: 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 Unifund Corporation upon the purchase of debtor's account, which was issued by CITIBANK SOUTH DAKOTA NA. 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 $6,352.21 plus interest of $710.93 at the rate of 6% less credits in the amount of $.00 totaling $7,063.14 as of January 19, 2012. 6. If called upon, affiant can testify at trial as to the facts pertaining to this matter. The above facts are true and correct to the best of my knowledge, information and belief. AFFIANT NAME: Sworn to and Subscribed before me this Zp day of 2012 Not Public ?? SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ?4tt?11?, ni tsrrraGrr/r?d r"lr;?` 2012 MAR -.1 PM 3:42 0UM$ER4 AH0 l?OUN T PENHSYLb`t MIA Unifund Corporation vs. Catherin Galena Case Number 2012-818 SHERIFF'S RETURN OF SERVICE 02/16/2012 02:49 PM - Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on February 16, 2012 at 1449 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Catherin Galena, by making known unto herself personally, at 5 Ridge Avenue, 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. SHERIFF COST: $40.00 February 24, 2012 TIM LACK, DEPUTY SO ANSWERS, RON R ANDERSON, SHERIFF 2122073 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 Unifund Corporation VS. CATHERINE GALENA (-) tll? C . _ n -c C r- ' -<X;.. ... c -4 C) bQ ? 2 C 3 co 2>z +a arc 3 -?s COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 12-818 ORDER TO SZ VLE DISCONTINM AND END TO THE PROTHONOTARY: Kindly mark the above-captioned matter settled, discontinued and ended upon payment of your costs only. GORDON & WEINBERG, P.C. BY: FREDERI? JOEL M. Attorney EINBERG, ESQUIRE K, ESQUIRE or Plaintiff P003