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Home My WebLink About12-3161212410 THIS IS AN ARBITRATION MATTER. ASSESSMENT OF DAMAGES HEARING REQUIRED. GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 41200 7.001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 Main Street Acquisition Corp. P.O. BOX 2529, SUWANEE,GA 30024 vs. MARY E CASNER 8 HILL DR Newville PA 17241-8626 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO ,x-3(61 NOTICE f -r M CZ rTz -0 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 "HIS 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 70 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 TELEPHCNE 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 FEF. OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. BEDFORD STREET S CARLISLE, PA 17013 (717) 249-3166 1o3?s ? r75X5;Y 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 Discover Card. 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 S o 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 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 April 10, 2012 in the amount of $2,017.89. 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. t-7. , Defendant's last payment on account was made on 9/8/2011. WHEREFORE, plaintiff claims of the defendant(s) the sum of $2,017.89 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDERIC I. EINBERG, ESQUIRE JOEL M. L?TK, ESQUIRE Attorney for Plaintiff P01P.DB 2124310 11459806 Main Street Acquisition Corp. MARY E CASNER 6011381008810606 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. 2124310 Main Street Acquisition Corp. MARY E CASNER 6011381008810606 ArrTnAVTT I , Ginette Whap law, depose and say that: being duly served sworn according to 1. I am an affiant for the Plaintiff herein and I have access to 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 Discover Card. 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 $1,900.37 plus interest of $111.58 at the rate of 6% less credits in the amount of $.00 totaling $2,011.95 as of March 22, 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. AFFI T NAME: Ginette Whoo Sworn to and Subscribed before me this day of C? (- 20 Notary Public ??1111111//,, #0 6# \p,E:S H/,q NOrg9 t y cn A 14% BL I C `°: C' •:e::• ?UNTY G?G•?• ??'lllll?•°''?? SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff (? y .'a O???Yt}??11. iUI1111'r? _. hIIJ r?V I?1?'. ?k? Jody S Smith Chief Deputy j Richard W Stewart D C0U?I T ?, Solicitor G r. ,_, a l f'SYLVANIA Main Street Acquisition Corp. vs. Case Number Mary E. Casner 2012-3161 SHERIFF'S RETURN OF SERVICE 05/21/2012 04:27 PM - Shawn Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on May 21 2012 at 1627 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Mary E. Casner, by making known unto Loye Casner, Mother of Defendant at 8 Hill Drive, Newville, Cumberland County, Pennsylvania 17241 its contents and at the same time handing to her personally the said true and correct copy of the same. _ PIWW"UTSHAI-t,-f?E-RUTY SHERIFF COST: $40.00 May 22, 2012 SO ANSWERS, RONI'V R ANDERSON, SHERIFF lC' CO, 04S fife She. Te;<..,setl. 1 +.., i }-OFF 1( ° 2124310 GORDON & WEINBERG, P.C. ?OTIHONOTAR BY: FREDERIC I. WEINBERG, ESQUIRE OF Identification No.: 41360 2412 JUL -3 AM 8: 0 JOEL M. FLINK, ESQUIRE Identification No.: 818940 LAND WWTY 1001 E. Hector Street, Ste 220 0SYLVA141A Conshohocken, PA 19428 484/351-0500 Main Street Acquisition Corp vs. MARY E CASNER COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 12-31.61 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) above named only and assess damages certified to be calculable as a sum certain from the complaint, as follows: Principal $2,017.89 Less: Payments on Account ( $.00) Total: $2,017.89 Understanding the false s---atements made herein are subject to penalty under 18 Pa.C.S.A. §4904, Unsworn Falsification to Authorities, I verify tha-: 1. The last known addresses of the parties are: Main Street Acquisition Corp. and that the last known address of defendant, MARY E CASNER, 8 HILL DR, Newville PA 17241-8626. 2. The annexed not ice(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. 4 I (y. S8 P8 a f? cog as -7VO?I '? Mc' w 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 day of 2012 Judgment is entered in favor of the -)laintiff(s and a ainst defendant by default for want of an answer and damag as se the su_ o , $2,017.89 as per the above certificatio Prothonotary GORDON & WEI C. BY: FREDERIC INBERG, ESQUIRE JOEL M. K, ESQUIRE Attorney for Plaintiff 2124310 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 Stree- Acquisition Corp. vs. MARY E CASNER 8 HILL DR Newville PA 17241-8626 Pursuant to Pa.R.Civ.P. you are hereby notified you in the above proceei tX/ L-Z L-L L-L COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 12-3161 CIVIL TERM NOTICE 236 of the Supreme Court of Pennsylvania, that a judgment has been entered against ding as indicated below. Judgment by Default $2,017.89 Money Judgment $ Judgment on Award of Arbitrators$ Judgment on Verdict$ IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL ATTORNEYS: FREDERIC I. WEINBERG OR JOEL F K, IRES AT IS TELEPHONE NUMBER: 484/351-0500 P- I PROTHONOTARY 2124310 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. MARY E CASNER TO/PARA COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 12-3161 CIVIL TERM NOTICE OF INTENTION TO TAKE DEFAULT MARY E CASNER 8 HILL DR Newville PA 17241-8626 DATE OF NOTICE/FECHA DEL AVISO: June 13, 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. BY: P10D-2 FREDERI?7 I// WEINBERG, ESQUIRE JOEL M / FINK, ESQUIRE