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Home My WebLink About12-29792122042 THIS IS AN ARBITRATION MATTER. ASSESSMENT OF DAMAGES HEARING REQUIRED. GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE 'v3 +'v -3 Identification No.: 41360 2rn 231- nr--. JOEL M. FLINK, ESQUIRE c?nr" _? Identification No.: 41200 ?7 1001 E. Hector Street, Ste 220 < C? ; Conshohocken, PA 19428 7z;W - 484/351-0500 cz -- PORTFOLIO AMERICA ASSET MANAGEMENT, LLC ASSIGNEE OF WELLS FARGO FINANCIAL PO BOX 55245 ATLANTA, GA 30343 vs. BETH CARMONA 1510 ORRS BRIDGE RD ENOLA PA 17025-1922 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : /,- pQL 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 14AY 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 103.75 PD A7"7-y (717) 249-3166 Cir 1&5,7/S pit JAS/ ql 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 germs 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, 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 $13,175.20. 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 1.2;26/2008. WHEREFORE, plaintiff claims of the defendant(s) the sum of $13,175.20 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDERIC I. EIN ERG, ESQUIRE JOEL M. FLIN SQUIRE Attorney for Plaintiff P01A.DB 2122042 00004992 PORTFOLIO AMERICA ASSET MANAGEMENT, LLC ASSIGNEE OF WELLS FARGO FINANCIAL BETH CARMONA 50237593191019001 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 langusge 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 EXHIBIT "A" 2414 2122042 00004992 PORTFOLIO AMERICA ASSET MANAGEMENT, LLC ASSIGNEE OF WELLS FARGO FINANCIAL BETH CARMONA 50237593191019001 AFFIDAVIT if A p Lf'y) &6 , being duly served sworn according to law, depose and say that: 1. I am the agent for the Plaintiff herein and I have custody and control 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 damages are sought as a direct result of said breach; 5. There is now due and owing from defendant to plaintiff, the amount of $13,175.20 plus interest of $.00 at the rate of 0% less credits in the amount of $.00 totaling $13,175.20 as of January 17, 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. I(----- AFFIANT Sworn to and Subscribed before me this -7-1- day of 2012 otary Pub c ```111111/////' 0,M1SS(pN •.:`?o?i ?O Aq or, AUS LAG r 011 " ••12, 213 .•'l ?I •o.ooo••• ?llilll SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor Portfolio America Asset Management, LLC vs. Beth Lynn Carmona SHERIFF'S RETURN OF SERVICE IT I 5 AM 9: ?" psi Yl-VAMA Case Number 2012-2979 05/22/2012 05:42 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on May 22, 2012 at 1742 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Beth Lynn Carmona, by making known unto herself personally, at 1510 Orrs Bridge Road, Enola, Cumberland County, Pennsylvania 17025 its contents and at the same time handing to her personally the said true and correct copy of the same. RYAN BURGETT, DE SHERIFF COST: $43.00 May 25, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF 'ci S l k0 Sh( ff. 1 Irc L sw0 Q # JCE 2122042 GORDON & WEINBERG, P.C. O"TARY BY: FREDERIC I. WEINBERG, ESQUIRE' Identification No.: 41.360 2 PH 4; 17 JOEL M. FLINK, ESQUIRE Identification No.: 41200 WRLANO COWTY 1001 E. Hector S`reet, Ste 220 !'ENNSYLVANIA Conshohocken, PA 19428 484/ 351-0500 PORTFOLIO AMERICA ASSET MANAGEMENT, LLC ASSIGNEE OF WELLS FARGO FINANCIAL vs. BETH CARMONA COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 12-2979 CIVIL TERM PRAECIPE FOR ENTRY OF JUDGMENT FOR PANT 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) BETH CARMONA above named only and assess damages certified to be calculable as a sum certain from the complaint, as follows: Principal $13,175.20 Total: $13,175.20 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: PORTFOLIO AMERICA ASSETMANAGEMENT, LLC ASSIGNEE OF WELLS FARGO FINANCIAL and that the last known address of defendant, BETH CARMONA, 1510 ORRS BRIDGE RD, ENOLA PA 17025-1922. 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. 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. ?9 SS di 701 L\ PA AND NOW, this day of Lkl 2012 Judgment is entered in favor of the plaintiff(s) and aga'nst defendant(s) by default for want of an answer an dam es assessed at t sum of , $13,175.20 as per the above certi 'cati 'Qir? ab 0001m;/ W40 Proth GORDON & WEINBERG, P.C. BY: FREDERI I. EINBERG, ESQUIRE JOEL M. NK, ESQUIRE Attorney for Plaintiff 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 2122042 PORTFOLIO AMERICA ASSET MANAGEMENT, LLC ASSIGNEE OF WELLS FA.RGO FINANCIAL vs. BETH CARMONA 1510 ORR.S BRIDGE RD ENOLA PA 17025-1922 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 12-2979 CI'JIL TERM NOTICE 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 $13,175.20 Money Judgment $ Judgment on Award of Arbitrators$ Ll Judgment on Verdict$ IF YOU HAVE ANY QUESTIONS CONCERNING HTak NOTICE, PLEASE CALL ATTORNEYS: FREDERIC I. WEINBERG OR JOEL FL S RES AT S TELEPHONE NUMBER: 484/351-0500 PROTHONOTARY 2122042 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 PORTFOLIO AMERICA ASSET MANAGEMENT, LLC ASSIGNEE OF WELLS FARGO FINANCIAL VS. BETH CARMONA TO/PARA COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 12-2979 CIVIL TERM NOTICE OF INTENTION TO TAKE DEFAULT BETH CARMONA 1510 ORRS BRIDGE RD ENOLA PA 17025-1922 DATE OF NOTICE/FECHA DEL AVISO: June 13, 2012 II-IPORTANT 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 JOEL M. FINBERG, ESQUIRE ESQUIRE P10D-2