HomeMy WebLinkAbout12-2382IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ASSET ACCEPTANCE LLC
PO BOX 2036
Warren, MI 48090
vs.
CIVIL ACTION
Plaintiff :
NO:
DEBRA L GURR
209 MAPLE AVE
CAMP HILL PA 17011-4123
Defendant
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?LAND COUNT"
INNS Y LVAN1A
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NOTICE TO DEFEND
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 to
Defend are served, by entering a written appearance personally or by an 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 judgment 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.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO
PROVIDE YOU WITH INFORMATION ON AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT REDUCED FEE OR NO FEE.
MIDPENN LEGAL SERVICES
401 EAST LOUTHER STREET
CARLISLE, PA 17013
717-243-9400
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ASSET ACCEPTANCE LLC
PO BOX 2036 CIVIL ACTION
Warren, MI 48090
Plaintiff
vs.
DEBRA L GURR
209 MAPLE AVE
CAMP HILL PA 17011-4123
NO:
Defendant
COMPLAINT
Plaintiff, ASSET ACCEPTANCE LLC, by and through its attorneys, Edwin A.
Abrahamsen & Associates, P.C., complains of the Defendant as follows:
I. Plaintiff, ASSET ACCEPTANCE LLC, (hereinafter "Plaintiff") is a corporation
with a principal place of business located at P.O.Box 2036 Warren, MI 48090.
2. The Defendant DEBRA L GURR (hereinafter "Defendant") is an adult individual
residing at 209 MAPLE AVE CAMP HILL PA 17011-4123.
3. At all relevant times herein, Plaintiff was engaged in the business of debt purchase
and collection.
4. Defendant applied for and received a credit card issued by BANK OF AMERICA
with the account number ending in 6605.
5. The within account was sold by BANK OF AMERICA to ASSET
ACCEPTANCE LLC for valuable consideration and all rights under said accounts were assigned
to ASSET ACCEPTANCE LLC.
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6. Use of the BANK OF AMERICA credit card was subject to the terms of the
Cardmember Agreement, a copy of which was sent to the Defendant along with the credit card. A
copy of this document has been requested from BANK OF AMERICA and will be provided upon
receipt.
7. Defendant used the BANK OF AMERICA credit card account number ending in
6605, for purchases, cash advances and/or balance transfers.
8. The Defendant was mailed account statements relative to the Defendant's use of the
subject credit card.
9. The Defendant defaulted under the terms of the Agreement by failing and refusing
to make monthly payments on the account as they became due.
10. The Defendant last made a payment on May 30, 2009.
11. The principal amount was $13,107.43 at the time it was received by Plaintiff.
12. Pursuant to the account agreement, any unpaid balance accrues interest.
13. The total amount due and owing the Plaintiff including interest, is $13,449.67.
WHEREFORE, Plaintiff requests judgment in its favor and against Defendant in the
amount of $13,449.67 plus costs of suit and any other relief as the Court deems just and
appropriate.
1F.?1,iwiri A. Abrahamsen &
Michael F. Ratchford, Es
Attorney I.D. Nos.: 8628
120 North Keyser Ave.
Scranton, PA 18504
mratchford@eaa-law.com
VERIFICATION
I, Michael F. Ratchford, attorney for Plaintiff, ASSET ACCEPTANCE LLC, am fully
familiar with the facts set forth in the within Complaint and am authorized to make this
Verification on behalf of Plaintiff. I Verify that the facts set forth in the within allegations are
true and correct to the best of my knowledge, knowing that any false statements are punishable
by law pursuant to 18 C.S.A. 4904.
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
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2012 MAY -8 AN 9:55
CUM kLANO COUNTY
P`E, NSYLVANIA
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
Asset Acceptance LLC
vs. Case Number
.
Debra L. Gurr 2012-2382
SHERIFF'S RETURN OF SERVICE
04/23/2012 04:01 PM - Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on April 23,
2012 at 1601 hours, he served a true copy of the within Complaint and Notice, upon the within named
defendant, to wit: Debra L. Gurr, by making known unto Mary Albani, Mother of Defendant at 209 Maple
Avenue, Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing
to her personally the said true and correct copy of the same.
DENNIS RY, DEPUTY
SHERIFF COST: $43.00
April 27, 2012
SO ANSWERS,
RON R ANDERSON, SHERIFF
(c) C011MYSuite Snentt. Te:ecsott. I.'.;;
ASSET ACCEPTANCE LLC
In the Court of Common Pleas of a
Plaintiff CUMBERLAND County, Pennsylvan' ; ...;
Civil Division r
,
C- M-
vs. r N
r,
NO: 2012-2382 CIVIL
DEBRA L GURR
" "
Praecipe to Defer/Suggestion of Bankruptcy
Defendant :
To the Prothonotary of CUMBERLAND County Pennsylvania:
Please enter the above Praecipe to Defer/Suggestion of Bankruptcy.
Thank
Michael F. Ratch rcVEsquire
Edwin A. Ab sen & Associates, P.C.
Lawyer ID # 285
120 N. Keys r Avenue
Scranton, A 18504
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ASSET ACCEPTANCE LLC
Plaintiff
CIVIL DIVISION
VS.
NO: 2012-2382 CIVIL
DEBRA L GURR
Defendant
CERTIFICATE OF SERVICE
I, Michael F. Ratchford, Esquire, hereby certify that on the date indicated below, I served
a copy of the Praecipe to Defer/Suggestion of Bankruptcy in the above captioned matter by mailing
the same via First Class United States mail, postage prepaid addressed as follows:
J Palmer Lockard
Widener University School of Law
2°d Floor 3605 Vartan Way
Harrisburg, Pa 17110
Date: June 25, 2012
Edwin A. Abrahamsen & Associates, P.C.
Michael F. Ratchford s
Attorney 1. D. No.: 285
120 N. Keyser A enue
Scranton, PA 1 04
(570) 558-5510