HomeMy WebLinkAbout12-4344r
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ASSET ACCEPTANCE LLC
PO BOX 2036
Warren, MI 48090
: CIVIL ACTION
Plaintiff
vs.
MARJORIE GARDNER
609A ERFORD RD
CAMP HILL PA 17011-1123
NO: 19-W(ly
Defendant
NOTICE TO DEFEND
?r°'i_.EU-CFFICE
-PROTHONOTARY
2.112 JUL 13 AM I11: 31
"EJMBERLANO CUNTY
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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
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 enters
against you by the court without further notice for any money claimed in the Complaint or for a
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 LEGAI. HELP.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE
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
a 41
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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.
NO:
MARJORIE GARDNER
609A ERFORD RD :
CAMP HILL PA 17011-1123
Defendant
COMPLAINT
Plaintiff, Asset Acceptance LLC, by and through its attorneys, Edwin A. Abrahamsen
Associates, P.C., complains of the Defendant as follows:
1. 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 Marjorie Gardner (hereinafter "Defendant") is an adult individual
residing at 609A Erford Rd Camp Hill PA 17011-1123.
3. At all relevant times herein, Plaintiff was engaged in the business of debt purcha
and collection.
4. Defendant applied for and received a credit card issued by Citibank (South
Dakota), NA with the account number ending in 0040.
5. The within account was sold by Citibank (South Dakota), NA to Asset Acc
LLC for valuable consideration and all rights under said accounts were assigned to Asset
Acceptance LLC .
r
6. Use of the Citibank (South Dakota), NA 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 Citibank (South Dakota), NA and will be provided
upon receipt.
7. Defendant used the Citibank (South Dakota), NA credit card account number
ending in 0040, 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 refusi?g
to make monthly payments on the account as they became due.
10. The Defendant last made a payment on April 15, 2009.
11. The principal amount was $12,309.40 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 $12,309.40.
WHEREFORE, Plaintiff requests judgment in its favor and against Defendant in the
amount of $12,309.40 plus costs of suit and any other relief as the Court deems just and
appropriate.
Respectfully
i PWw?fi A. Abrahams?iO Assoc.
Michael F. Ratchfo, Esquire
Attorney I.D. Nos. 86285
120 North Keyse Ave.
Scranton, PA 1 04
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
the best of my knowledge, knowing that any false statements are punishable by law pursuant tc
18 C.S.A. 4904.
F. Ratchfi6rdJ Tsquire
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
011 ?%V at ? 11 ;f I
?l PfCTf1 'fir'"
2012 JUL 23 AM $, 16
CUMBERLAND COU'N R ,f?
PENNSYLVANIA
Asset Acceptance LLC
vs.
Marjorie Gardner
Case Numbi
2012-4344
SHERIFF'S RETURN OF SERVICE
07/16/2012 08:07 PM - Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on July 16,
2012 at 2007 hours, he served a true copy of the within Complaint and Notice, upon the within named
defendant, to wit: Marjorie Gardner, by making known unto herself personally, at 609A Erford 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.
DENNJSFRY, DEP
SHERIFF COST: $43.00
July 17, 2012
SO ANSWERS,
RON R ANDERSON, SHERIFF
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