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Home My WebLink About12-10912107609 THIS IS AN ARBITRATION MATTER. ASSESSMENT OF DAMAGES HEARING REQUIRED. GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE - Identification No.: 41360 c-? ? . JOEL M. FLINK, ESQUIRE Identification No.: 41200 "m n rq 1001 E. Hector Street, Ste 220 co F -am Conshohocken, PA 19428 fit... fV :;*G C) 484/351-0500 ? - = < rs r:) a Asset Acceptance, LLC assignee COURT OF COMMON PLEAS of World Financial Network CUMBERLAND COUNTY National Bank 28405 Var.. Dyke Avenue Warren, MI 48093 vs. DOCKET NO. : /o't - 104/ 0'fV1/Te'rN PHILIPM M: HEINICK 4 W SCHOCLSIDE DR MECHANICSBURG PA 17055-2743 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 C-S) 4lc) -75 Po Arr-/ C# cow qq l? a17ia99 COMPLAINT IN CIVIL-ACTION 1. Plaintiff is a debt buyer and successor in interest to the original creditor as set forth in the caption of this Complaint.. 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, 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 of $818.38. 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 -0 1 3/11/2008. WHEREFORE, plaintiff claims of the defendant(s) the sum of $818.38 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDERIC I. EINB RG, ESQUIRE JOEL M. FLI K, QUIRE Attorney for aintiff P01A.DB 2107609 39835243 Asset Acceptance, LLC assignee of World Financial Network National Bank PHILIPM M HEINICK 000000006005407264 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. Deonno EXHIBIT "A" h ? 2277 2107609 39835243 Asset Acceptance, LLC assignee of World Financial Network National Bank PHILIPM M HEINICK 000000006005407264 Deanna Jose I, law, depose and say that: AFFIDAVIT , being duly served sworn according to 1. I am the agent for the Plaintiff herein and I have custody and cont=rol of the files relating to this account; 2. I have knowledge of the facts and circumstances in connection with this case; 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 aamages are sought as a direct result of said breach; 5. There is now due and owing from defendant to plaintiff, the amount of $615.1 plus interest of $$197.53 at the rate of 10`o less credits in the amount of $.00 totaling $812.65 as of January 11, 2012. 6. If called upon, affiant can testify at trial as to the facts pertaining to this matter. The above facts are true information and belief. Sworn to and Subscribed before me this day ??AN 16 201Z of 2012 Notary Public MAUREEN CHASE Notary Public - Michigan Macomb County My Commission Expires Jul 1 Acting in the county of ct to the best of my knowledge, SHERIFF'S OFFICE OF CUMBERLAND COUNTY k . Ronny R Anderson - Sheriff t Jody S Smith Chief Deputy Richard W Stewart Solicitor Asset Acceptance LLC vs. Philip M. Heinick vx a X11,1" r/ # la 88 " ?r2 FEN SY!AANIA Case Number 2012-1091 SHERIFF'S RETURN OF SERVICE 0212412012 07:59 PM - Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on February 24 2012 at 1959 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Philip M. Heinick, by making known unto Angela Heinick, Mother of Defendant at 4 W. Schoolside Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $38.00 February 28, 2012 DENN FRY, DEPUT SO ANSWERS, RONKY R ANDERSON, SHERIFF 0 GORDON & WE INBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL, M. FLINK, ESQUIRE Identification No.: 41200 1001 E. Hector Street, Ste 220 Conshohoc.<en, PA 19428 484/351-0500 Asset Acceptance, LLC assignee of World Financial Network National Bank vs. PHILIPM M HEINICK 2107609 COURT OF COMMON PLEAS CUMBERLAND COUNTY U) r? >? rv r-- DOCKET NO. : 12-1091 CIVIL TERM PRAECIPE FOR ENTRY OF JUDGMENT FOR WANT OF AN ANSWER ASSESSMENT OF DAMAGES, VERIFICATION OF ADDRESS AND NON-MILITARY SERVICE TO THE PROTHONOTARY: Enter judgment for want of an answer for plaintiff and against defendant(s) PHILIPM M HEINICK above named only and assess damages certified to be calculable as a sum certain from the complaint, as follows: Principal $818.38 Total: $818.38 Understanding the false statements made herein are subject to penalty under 18 Pa.C.S.A. §4904, Unsworn Falsification to Authorities, I verify that: 1. The last known addresses of the parties are: Asset Acceptance, LLC assigneeof World Financial Network National Bank and that the last known address of defendant, PHILIPM M HEINICK, 4 W SCHOOLSIDE DR, MECHANICSBURG PA 17055-2743. 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 failing of this praecipe. 3. The said defendant(s) is (are) of the United States or otherwise within and Sailors Civil Relief Act and is (are) not in the military service the coverage of the Soldiers over 18 years of age. e# 169 7 6- R* a 739.2 No c e Awl.4&Cl AND NOW, this q" day of 2012 Judgment is entered in favor of the plaintiff(s) and against defendant(s) by default for want of an answer d damages assessed at the sum of , $818.38 as per the above certifi atigSk Prot not ,% GORDON & WEINBERG, P. BY: FREDERIC INBERG, ESQUIRE JOEL M. FL K, ESQUIRE Attorney for Plaintiff 2107609 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 Asset Acceptance, LLC assignee of World Financial Network National Bank COURT OF COMMON PLEAS CUMBERLAND COUNTY VS. PHILIPM M HEINICK 4 W SCHOOLSIDE DR MECHANICS13URG PA 17055-2743 DOCKET NO. NOTICE 12-1091 CIVIL TERM Pursuant to Pa.R.Civ.P. 236 of the Supreme Court of Pennsylvania, you are hereby notified that a judgment has been entered against you in the above proceeding as indicated below. /X[ Judgment by Default $818.38 Money Judgment $ L_L Judgment on Award of Arbitrators$ Judgment on Verdict$ IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL ATTORNEYS: FREDERIC I. WEINBERG OR JOEL M. FLINK, ESQUIR AT THIS TELEPHONE NUMBER: 484/351-0500 g d PROT'A4?? ?? ??? Z 2107609 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 Asset Acceptance, LLC assignee of World Financial Network National Bank vs. PHILIPM M HEINICK COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 12-1091 CIVIL TERM NOTICE OF INTENTION TO TAKE DEFAULT TO/PARA PHILIPM M HEINICK 4 W SCHOOLSIDE DR MECHANICSBURG PA 17055-2743 DATE OF NOTICE/FECHA DEL AVISO: March 20, 2012 n4PORTANT 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 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 GORDON & WEINBERG, P.C. BY: FREDERIC I \----W -NBERG, ESQUIRE JOEL M. FLINK, ESQUIRE P10D-2