HomeMy WebLinkAbout12-36672123268
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 rn
F.
1001 E. Hector Street, Ste 220 use" ._.. .--
Conshohocken, PA 19428
484/351-0500
STELLAR RECOVERY, INC. COURT OF COMMON PLEAS
1327 Highway 2 West, CUMBERLAND COUNTY
Kalispell, MT 59901
vs . DOCKET NO. . 1a - ,3(o(07 Urvi 1 (8-m
ANTHONY HARGROVE
401 MEADOW DR
CAMP HILL PA 17011
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 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
5
32 S. BEDFORD STREET O
CARLISLE, PA 17 013 # J03,7s AO A >7Y
(717) 249-3166 611769,8
Q*a7(v s96
COMPLAINT IN CIVIL-ACTION
1. Plaintiff, STELLAR RECOVERY, INC. , is a debt buyer and
successor in interest to the original creditor, HSBC Bank N.A..
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 May 30, 2012 in
the amount of $1,229.27.
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
5/10/2010.
WHEREFORE, plaintiff claims of the defendant(s) the sum of
$1,229.27 plus applicable costs, interest and attorney's fees.
GORDON & WEINBERG, P.C.
BY:
FREDERIC I W
. NBERG, ESQUIRE
JOEL M. , ESQUIRE
Attorney for Plaintiff
P01P.DB
2123268
STELLAR RECOVERY, INC.
ANTHONY HARGROVE
7021270353452542
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.
N E: DOFFIE HOWARD
2123268
STELLAR RECOVERY, INC.
ANTHONY HARGROVE
7021270353452542
State Montana §
County of Flathead §
AFFIDAVIT
I, DOFFIE HOWARD, being duly served sworn according to law, depose and say that:
1. I am employed 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 by HSBC Bank N.A. when HSBC Bank N.A. sold the
account to STELLAR RECOVERY, INC..
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
$1,214.74, which includes original interest as of May 10, 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. -4
A ANT: DOFFIE HOWARD
Sworn to and Subscribed
before me this 10 day
of OVA 2012
Notary Public
AS?? p,n? E IMMAMS
N?y?? O`S' Y P ubk • SW@ Qr FRkMdft
MY COMM. Expina May 1, 2016
'• ,,,,,; ;,??`' COmmiasfon #F EE 194676
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
?°??tp nt ?embcrr??d
' E'! f9y
OFFICE "1F 7! E °-ERIFF
Richard W Stewart
Solicitor
PEP4 . S t 4l- d'w
Stellar Recovery, Inc. I
vs.
Anthony Hargrove
Case Number
2012-3667
SHERIFF'S RETURN OF SERVICE
06/20/2012 01:13 PM - Michelle Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on June
20, 2012 at 1313 hours, she served a true copy of the within Complaint and Notice, upon the within named
defendant, to wit: Anthony Hargrove, by making known unto Charise Spradley, Fiance of Defendant at 401
Meadow Drive, 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.
SHERIFF COST: $43.00
June 21, 2012
M1, <- Lc-:- ? ? I ?
MICHELLE GUTSHALL, DEPUTY
SO ANSWERS,
RON R ANDERSON, SHERIFF
;C) COUrP,'SUIte Snerift, Teieosott Inc
ro rt ICE
-?? 123268
GORDO`] & WEINBERG, P.C.
BY: FREDERIC I. WEINBERG, ESQUIRE
--der_tification No.: 41360 ?CINIJL 30 Pit 2. 18
JOEL M. FLINK, ESQUIRE
dertification No.: 41200 ljO COUNTY
10K H. Sector Street, Ste 220 ????5`(LVANIA
Cons,,ohec-Ken, PA 19428
484/371-,)500
STELLAR RECOVERY, INC.
VS.
ANTHCCNY HARGROVE
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
DOCKET NO. : 12-3667 CI'V'IL 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 aqa__nst
defendant(s) ANTHONY HARGROVE above named only and assess damages
certified to be calculable as a sum certain from the complaint., as
fcllccas :
Principal $1,229.27
Total: $1,229.27
Undeistanding the false statements made herein are subject to penalty
unde IE Pa.C.S.A. §4904, Unsworn Falsification to Authorities, I
veril 'i -.hat.:
The last known addresses of the parties are: STELLAR
RECOVERY, INC. and that the last known address of defendan',
ANTHONY HARGROVE, 401 MEADOW DR, CAMP HILL PA 17011.
2. The annexed notice(s) of intention to file this praecipe was
(were) mailed to all parties, defendant and to their record aa;,torneys,,
if any, after default occurred, and at least ten days prior tc) the
date :)f f_linq of this praecipe.
3. The said defendant(s) is (are) not in the military service
o'_- ti-,e C?r.ited States or otherwise within -`he coverage of the r o-.diers
and :ai:_crs Civil Relief Act and is (are) over 18 years of acfe.
a?? ?1le.Sb"W L1- l
?? t? 18?13?0
lll???
AND NOW, this 21b_ day of
is entered in favor of the plaintiff(s) and ag
default for want of an answer and dXg e.sftse
$1,22-^.2'7 as per the above certificn.,/?`
Prothonot
2012 lodgment
nst defend t(s) by
at the of
GORDON & WEINBERG, P.C.
ti
BY:
FREDERIC , K INBERG, E::') QUIRE
JOEL M. FLINK, ESQUIRE
Attorney for Plaintiff
2123268
GOI DC'v & WEINBERG, P.C.
BY: FREDERIC I. WEINBERG, ESQUIRE
idert:.ification No.: 41360
JOEL M. FLINK, ESQUIRE
identification No.: 41200
1001 E. Hector Street, Ste 220
Conshohocken, PA 19428
484/351-0500
STELLAR. RECOVERY, INC.
VS.
ANTHONY HARGROVE
401 MEADOW DR
CAMP IL PA 1`7011
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
DOCKET NO. : 12-366? =,'IL TERM
NOTICE
Pursuant to Pa.R.Civ.P. 236 of the Supreme Court of Pennsylvania, you
are ?erety notified that a -udgment has been enuered. against you in
the a'oove proceeding as indicated below.
/X/ Judgment by Default $1,229.27
Money Judgment $
Judgment on Award of Arbitrators$
Judgment on Verdict$
IF YC`:J HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL
ATTORNEYS: FREDERIC I. WEINBERG OR JOEL M. FLINK, ESQUIRES THIS
TELEPHONE NUMBER: 484/351-0500
-1?'(Aua -
PROT O
2123268
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
STELLAR RECOVERY, INC.
VS.
ANTHONY HARGROVE
TO/PARA
COURT OF COMMON PLEAS
CUMBERLAND COJNTY
DOCKET NO. : 12-3667 CIV7:1, TERM
NOTICE OF INTENTION TO TAKE DEFAULT
ANTHONY HARGROVE
401 MEADOW DR
CAMP HILL PA 17011
DATE OF NOTICE/FECHA DEL AVISO: July 11, 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 KAY 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 A130UT 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 ?! EINBERG, ESQUIRE
JOEL M. YL K, ESQUIRE
P10D-2