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Home My WebLink About12-3387• 2123093 THIS IS AN ARBITRATION MATTER. ASSESSMENT OF DAMAGES HEARING REQUIRED. GORDON & WEINBERG, P.C. ?„- -- -? BY: FREDERIC I. WEINBERG, ESQUIRE Idetitification No.. 41360` JOEL M. FLINK, ESQUIRE N Idexitification No.. 41200- -- 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 SKUTR FINANCIAL, LLC COURT OF COMMON PLEAS 1291 W GALLERIA DR # 125, CUMBERLAND COUNTY HENDERSON, NV 89014 VS. DOCKET NO. . /a- 3M7 (21vil to "Yh JODIE TIEFENBRUNN 333 W PENN ST CARLISLE PA 17013 NOTICE YOU NAVE 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 ATTOIRNEY 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 32 S. BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 103. 75 PO A 77-Y O# i9y b9 P,'ff ol -75-8 V-3 COMPLAINT IN CIVIL-ACTION 1. Plaintiff, SKUTR FINANCIAL, LLC , is a debt buyer and successor in interest to the original creditor, HSBC. 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 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 5/1/12 in the amount of $2,695.69. 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 10/31/2008. WHEREFORE, plaintiff claims of the defendant(s) the sum of $2,695.69 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDER C I WEINBERG, ESQUIRE JOEL NK, ESQUIRE Attorney for Plaintiff P01P.DB 2123093 704050 SKUTR FINANCIAL, LLC JODIE TIEFENSRUNN 7021260031922859 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. §49!04 which provides for certain penalties for making false statements. JODIE TIEFENBRUNN 7021260031922859 2123093 SKUTR FINANCIAL, LLC AFFIDAVIT I , (-pypiTS being duly served sworn according to law, depose and say that: 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 SKUTR FINANCIAL, LLC upon the purchase of debtor's account, which was issued by HSBC. 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 $2,695.,69 plus interest of $.00 at the rate of 0% less credits in the amount of $.00 totaling $2,695.69 as of March 13, 2012. 6. If called upon, affiant can testify at trial as to the facts pertaining to this matter. The above facts are true and information and belief. Sworn to and Subscribed before me this ?A day of f 2012 Notary Pubii _ ect to th t of y owledge, NAME: ZAL"Pri I E4 '-> NM B. NLVUW E= N"YPWk.$NOdit"k APPO M sM W 124427-1 My AW. ExPW" Ow 18, 2015 SHERIFF'S OFFICE OF CUMBERLAND COUNTY:-- Ronny R Anderson Sheriff Jody S Smith Chief Deputy Y, Richard W Stewart Solicitor ; _ . Skutr Financial, LLC vs . I Case Number Jodie L. Tiefenbrunn 2012-3387 SHERIFF'S RETURN OF SERVICE 06/07/2012 07:41 PM - Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on June 7, 2012 at 1941 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Jodie L. Tiefenbrunn, by making known unto herself personally, at 333 W. Penn Street, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to her personally the said true and correct copy of the same. ICHAEL BARRICK, DE UTY SHERIFF COST: $34.00 June 08, 2012 SO ANSWERS, RON ~ R ANDERSON, SHERIFF (C; COW'.TYSJi.C°. S" enff. Te:r. ,.. r--...-- GORDON & WEINBERG, P.C.W. BY: FREDERIC I. WEINBERG, ESIUIRE Vt ?6 P? 1? p4 Identification No.. 41360ItIl A- iNo4UIRE ERL Identification ayp?,N1A 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 2123093 SKUTR FINANCIAL, LLC VS. JODIE TIEFENBRUNN COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 12-3387 CIVIL TERM 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 $2,695.69 Less: Payments on Account ( $.00) Total: $2,695.69 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: SKUTR FINANCIAL, LLC and that the last known address of defendant, JODIE TIEFENBRUNN, 333 W PENN ST, CARLISLE PA 17013. 2. The annexed notice(s) of intention to file this praecipe was (were) mailed to all parties, defendant and to the 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 o the Soldiers and Sailors Civil Relief Act and is (are) over 18 years of age. d ?. ?l lo. SD ??- hc? Mou. AND 'IOW, 'this day of 2012 Judgment is entered in favor of the plaintiff( Les agAinst defendant(s) by default for want of an answer and dames t the s of , $2,695.69 as per the above certificat Prothonotary GORDON & W NBERG.C. i BY: FREDERIfC I. EINBERG, ESQUIRE JOEL M. NK, ESQUIRE Attorney for Plaintiff 2123093 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 SKUTR FINANCIAL, LLC VS. JODIE TIEFENBRUNN 333 W PENN ST CARLISLE PA 17013 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 12-3387 CIVIL 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. /XL Judgment by Default $2,695.69 Money Judgment $ Ll 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 T IS TELEPHONE NUMBER: 484/351-0500 1 In I?` a PROTHONOitA w 2123093 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 SKUTR FINANCIAL, LLC COURT OF COMMON PLEAS CUMBERLAND COUNTY JODIE TIEFENBRUNN TO/PARA Vs. DOCKET NO. : 12-3387 CIVIL TERM NOTICE OF INTENTION TO TAKE DEFAULT JODIE TIEFENBRUNN 333 W PENN ST CARLISLE PA 17013 DATE OF NOTICE/FECHA DEL AVISO: June 28, 2012 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARAN E PERSONALLY OR BY AN ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSE 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 LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVI 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 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: FREDER C I. INBERG, ESQUIRE JOEL M. LINK, ESQUIRE P10D-2