HomeMy WebLinkAbout12-51912138903
THIS IS AN ARBITRATION MATTER.
ASSESSMENT OF DAMAGES HEARING REQUIRED.
GORDON & WEINBERG, P.C.
BY: FREDERIC I. WEINBERG, ESQUIRE :
Identification No.: 41360 o T'
JOEL M. FLINK, ESQUIRE
6co
Identification No.: 41200
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1001 E. Hector Street, Ste 220 U,r iv ?
Conshohocken, PA 19428 -<:r- ° #
484/351-0500 -v
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Main Street Acquisition Corp. COURT OF COMMON PLEAS .
P.O. BOX 2529, CUMBERLAND COUNTY
SUWANEE',GA 30024
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VS.
SI
DOCKET NO. J?
MAHMOOD AHMED
4815 E TRINDLE RD APT 5
Mechanicsburg PA 17050-3709
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 CASEMAY 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, G0 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
Q??o3.75?d Q?
Cry 1-74141?
(L?l a?959?
COMPLAINT IN CIVIL-ACTION
1. Plaintiff, Main Street Acquisition Corp. , is a debt
buyer and successor in interest to the original creditor,
Chase/Washington Mutual issuer of Washington Mutual Fin Visa.
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 July 19, 2012 in
the amount. of $6,119.05.
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
6/23/2010.
WHEREFORE, plaintiff claims of the defendant(s) the sum of
$6,119.05 plus applicable costs, interest and attorney's fees.
GORDON & WEINBERG, P.C.
BY:
FREDERIC I. W NBERG, ESQUIRE
JOEL M. LI ESQUIRE
Attorney for Plaintiff
P01P.DB'
2138903
11685119
Main Street Acquisition Corp.
MAHMOOD AHMED
4185862003002161
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 . [Volt v
EXHIBIT "A"
2138903
Main Street Acquisition Corp.
MAHMOOD AHMED
4185862003002161
AWrTnAXTTM
I, O WCO being duly served sworn according to
law, depose an say that:
1. I am an affiant for the Plaintiff herein and I have access to the
files relalting 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
Chase/Washington Mutual issuer of Washington Mutual Fin Visa.
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 ate sought as a direct result of said breach;
5. There is now due and owing from defendant to plaintiff, the amount
of $5,64$.35 plus interest of $451.20 at the rate of 6% less credits in the
amount of $.00 totaling $6,099.55 as of June 28, 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.
FI NAME :
Sworn to and Subscribed
before me ',this .3 day
of 20
Notary PuYblic
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