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Home My WebLink About12-1163THIS 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 2119992 ARBITRATION MATTER. OF DAMAGES HEARING REQUIRED. t-7 r , G.7 c) rrI ec. r- n ED rn- -'7 .r- tv ::um ? r? to ' - S <, C7 3> ? - rja -Tj =CD _ CD Main Street Acquisition Corp. P.O. BOX 2529, SUWANEE,GA 30024 vs. GORDON E NENNINGER 660 CONODOGUINET AVE Carlisle PA 17015-8971 NOTICE COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. a 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. 17 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 Q $ 69 7S fd a#y R ffa-7i y9,-A 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 Union Privilege 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)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 26, 2012 in the amount of $2,698.88. 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. 2119992 11064923 Main Street Acquisition Corp. GORDON E NENNINGER 5480420032461244 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. *4 twL NAM: trrn EXHIBIT "A" 2119992 Main Street Acquisition Corp. GORDON E NENNINGER 5480420032461244 AFFIDAVIT I, ??Mk? being duly served sworn according to law, depose and ay 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 Main Street Acquisition Corp. upon the purchase of debtor's account, which was issued by HSBC BANK NEVADA NA issuer of Union Privilege 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 $2,500.17 plus interest of $172.00 at the rate of 6% less credits in the amount of $.00 totaling $2,672.17 as of November 22, 2011. 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. AFF I T NAME: rmj (q I.l? ? Sworn to and Subscribed `` Subscribed `` before me this day Of 2 011 L? JAS0'N L0YD HAFIRISO d No ry Public IOTA FUL C 5 C1 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor Main Street Acquisition Corp. vs. Gordon E. Nenninger D l PEN'MUMMA Case Number 2012-1163 SHERIFF'S RETURN OF SERVICE 02/24/2012 02:48 PM - William Cline, Corporal, who being duly sworn according to law, states that on February 24, 2012 at 1448 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Gordon E. Nenninger, by making known unto Denise Nenninger, Wife of Defendant at 660 Conodoguinet Avenue, Carlisle, Cumberland County, Pennsylvania 17015 its contents and at the same time handing to her personally the said true and correct copy of the same. WILL AM CLINE, DEPUTY SHERIFF COST: $34.00 February 28, 2012 SO ANSWERS, RON* R ANDERSON, SHERIFF I9 GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 81894 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 Main Street Acquisition Corp. VS. GORDON E NENNINGER 2119992 r? C'.7 .Fri ^ J cry,. COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 2012-1163 CIVIL PRAECIPE FOR ENTRY OF JUDGMENT FOR WANT OF AN ANSWER ASSESWUNT 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) above named only and assess damages certified. to be calculable as a sum certain from the complaint, as follows: Principal $2,698.88 Less: Payments on Account ( $.00) Total: $2,698.88 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: Main Street Acquisition Corp. and that the last known address of defendant, GORDON E NENNINGER, 660 CONODOGUINET AVE, Carlisle PA 17015-8971. 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. -/? Lf 97y A/,o e- 41 Z 3. The said defendant(s) is (are) not in the military service of the United States or otherwise within the coverage of the Soldiers and Sailors Civil Relief Act and is (are) over 18 years of age. AND NOW, this 9#' day of 2012 Judgment is entered in favor of the plaintiff(s) and against defendant(s) by default for want of an answer an dama es assessed at the sum of , $2, 698.88 as per the above certifWati. 6!% GORDON & WEINBERG, P.C. BY: FREDERIC FPlainti NBERG, ESQUIRE JOEL M. F ESQUIRE Attorney ff 2119992 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. vs. GORDON E NENNINGER 660 CONODOGUINET AVE Carlisle PA 17015-8971 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO NOTICE 2012-1163 CIVIL 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 tr.e above proceeding as indicated below. /X/ Judgment by Default $2,698.88 " 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, ESQUIRES AT THIS TELEPHONE NUMBER: 484/351-0500 s 1 00k, PROTHONOTA ?/9?jz t 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. vs. GORDON E NENNINGER 2119992 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 2012-1163 CIVIL NOTICE OF INTENTION TO TAKE DEFAULT TO/PARA GORDON E NENNINGER 660 CONODOGUINET AVE Carlisle PA 17015-8971 DATE OF NOTICE/FECHA DEL AVISO: March 20, 2012 IMPORTANT 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. s.. BY: FREDERI I. WWRfNBERG, ESQUIRE JOEL M. FLINK, ESQUIRE PLOD-2