HomeMy WebLinkAbout12-1097THIS IS AN
ASSESSMENT
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 Acquisition Corp.
P.O. BOX 2529, SUWANEE,GA
30024
Vs.
CINDY UHAZIE
921 EPPLEY RD
Mechanicsburg PA 17055-9746
NOTICE
2121155
ARBITRATION MATTER.
OF DAMAGES HEARING REQUIRED.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
DOCKET NO. : /a _ /097
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CIVi??N?
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 prrf
CARLISLE, PA 17013 C /&z)(PO7
(717) 249-3166
0: a '7 i3oa
COMPLAINT IN CIVIL-ACTION
1. Plaintiff, Main Street Acquisition Corp. , is 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
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 $6,389.29.
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
7/5/2009.
WHEREFORE, plaintiff claims of the defendant(s) the sum of
$6,389.29 plus applicable costs, interest and attorney's fees.
GORDON & WEINBERG, P.C.
BY:
FREDERIC I. EINBERG, ESQUIRE
JOEL M. ELI ESQUIRE
Attorney or Plaintiff
P012.DB
I
2121155
11108467
Main Street Acquisition Corp.
CINDY UHAZIE
5458002219053297
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 verificati n is made subject to 18
Pa.C.S. §4904 which provides for certain penalties r making false
statements.
i?
,r
NAME:
EXHIBIT "A"
2121155
Main Street Acquisition Corp.
CINDY UHAZIE
5458002219053297
I Katresha Hughfey
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 $5,682.17 plus interest of $666.02 at the rate of 6% less credits in the
amount of $.00 totaling $6,348.19 as of December 14, 2011.
6. If called upon, affiant can testify t triad as to the facts
pertaining to this matter. l
The above facts are true and correglh, t?the be t of my knowledge,
information and belief. ,/ i i
AFF
AFFIDAVIT
hley
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson !!. 4 t ;_ : _ :_t f
Sheriff t
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
Main Street Acquisition Corp.
vs.
Cindy Uhazie
4.U?ltatr/4/16
Ail fl' ti 1
"n s.
FEMNSYLVANIA
Case Number
2012-1097
SHERIFF'S RETURN OF SERVICE
02/24/2012 07:19 PM - Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on February 24
2012 at 1919 hours, he served a true copy of the within Complaint and Notice, upon the within named
defendant, to wit: Cindy Uhazie, by making known unto Jason Uhazie, Son of Defendant at 921 Eppley
Road, Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time
handing to him personally the said true and correct copy of the same.
SHERIFF COST: $38.00
February 28, 2012
DENNI FRY, DEPU
SO ANSWERS,
RONI'V R ANDERSON, SHERIFF