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Home My WebLink About12-60582125435 THIS IS AN ARBITRATION MATTER. ASSESSMENT OF DAMAGES HEARING REQUIRED. GORDON & WEINBERG, P . C . ,,..,, BY: FREDERIC I. WEINBERG, ESQUIRE ~ ~ ,~ m__ ~ Identification No.: 41360 ~~~,-~'-, ~ ;~~ .~~_~ JOEL M. FLINK, ESQUIRE =~~='~' ra i '" r ~ ~z t~`. T~ i . Identification No.. 41200 ,,, -~.~` ~ .,,1 tic-' 1001 E. Hector Street, Ste 220 y ~-' ~ ~ :,.~'=r~ Conshohocken, PA 19428 r .~ ~- :~=-~ 484/351-0500 -rt``~ ~,.. `:~ `°''` Main Street Acquisition Corp. COURT OF COMMON PLEAS P.O. BOX 2529, CUMBERLAND COUNTY SUWANEE,GA 3002.4 vs . DOCKET N0. /a - ~pQJ$ l~1V i ~ ~~°!'~ CHRISTINA M GEORGE 448 SIOUX DR Mechanicsburg PA 17050-2592 NOTICE YOU HAVE BEF,N SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIMS SET FORTH IN THE FOLLGWING 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 'FAKE 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 YOL' 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 ~~03.75 P~gp7~ ~~ ~~ y ~R~ 2'~a8 i a8a COMPLAINT IN CIVIL-ACTION 1. Plaintiff, Main Street Acquisition Corp. is a debt buyer and successor in interest to the original ~~reditor, HSBC BANK NEVADA NA issuer of Direct Merchants Mastercard. 2. At all times relevant hereto, the defendant (s;l 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 credit.or's credit facilities. 3. Defer..dant(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 servic:es 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 Aff=idavit of Account, if available, is attached hereto as Exhibit "A" 5. All the credits to which the defendant (s) is entitled have been applied ar_d there remains a balance due as of July 31., 2012 in the amount of 52,326.49. 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 arty part thereof. 7. Defendant's last payment on account was made on 6/25/2009. WHEREFORE, plaintiff claims of the defendant(s) the sum of $2,326.49 plus applicable costs, interest and attorney's fees. CORDON & WEINBERG, P.C;. BY: FREDERIC I WEI~i'E3ERG, ESQUIRE JOEL M. FL N ;'ESQUIRE Attorney for Plaintiff POlP.DB 2125435 11131975 Main Street Acquisition Corp. CHRISTINA M GEORGE 5458001578194023 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 r certain penalties for making false statements. /~ ) / h, NAME ~ (, l~V~sha Hughley EXHIBIT ~~A" 2125435 Main Street Acquisition Corp. CHRISTINA M GEORGE 5458001578194023 KaVesha Hughley I, to law, depose and say that: being duly served sworn according 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 Mastercard. 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 $2,023.17 plus interest of $295.01 at the rate of 6~ less credits in the amount of $.00 totaling $2,318.18 as of,July 6, 2012. 6. If called upon, affiant can testif at tria as to the facts pertaining to this matter. The above facts are true ~ corre ' to h b~ t of m knowled e Y g , information and belief. ~ ~~ 'i AFFIANT Sworn to and Subscribed before me this ~~~~ day of 2012 ~~ ~ Notary Public l ~~ ,: ,,. ' J r a ,,;,. ~ f,,, _xJ ~:. 1,r}~5. : s ~ y T . . S 1 ~ ' 'S'=, ~ ! 1 n~~rr~nvrm ~. - ~ •- - 2125435 GORDON fx WEINBERG, P.C. _ ? ~ ;.' ,~ BY: FREDERIC I . WEINBERG, ESQUIRE ~, ~' 'a; <. :Identification No.: 41360 JOEL M. FUNK, ESQUIRE Identification No.: 41200 1001 E. ~iectcr Street, Ste 220 Consriohocken, PA 19428 484/351-0500 Main Street Acquisition Corp. v:~ . CHRISTINA M GEORGE COUNT OF COM]`40N PLEAS CUMBERLAND COUNTY DOC:~ET N0. 12-6058 CIVIL PRAECIPE FOR ENTRY OF JUDGMENT BY AGREEMENT TO THE PROTHONOTARY: Enter judgment by agreement for plaintiff and against. defendant(s) CHRISTINA M GEORGE above named only and assess damages certified to be calculable as a sum certain from. tYie complaint, as follows: Principal Total: $2, 556. 1.9 $2,556.19 Understanding the false statements made herein are subje:t to penalty under .L8 Pa. C.S.A.. X4904, Unsworn Falsification -e AutY~~or_i.t ies, I verify that: 1. The last known addresses of the parties are: Main Street Acquisition Corp. and that the last known. address o defendant, CHRISTINA M GEORGE, 448 SIOUX DR, Mechanicsburg PA 1705-2592. 2. The annexed notice (s) of int:enticn to file th_i_s praecipE was (were) mailed to all parties, defendant and t:~ their record attorneys, if any, after default occurred, and ate least ten days prior to the date of filing of this pr_aecipe. ~ w.~~~.s~~d a~ ~ ~~~~ ~~~ ,~~~ 3. The said defendant(s) is (are) not in the military serv_ce :~f the United States or otherwise withi:~ the coverage of the :soldiers and Sailors Civil Relief Act and is (are) o~~er 18 year: o f age . ~ I ANI:~ NOW, this ~ _ day of ! va~~ , 2012 ~Tudgment by agreement is entered in favor of e plaintif_f(s) and against defer:dant(s)at the sum of $2,556.19 s p th ove cert' 'cation. Prothonota „~ GORDON & W~INBERG,,~`, P . C . BY. ~// FREDERIC ~ . ~LGEINBERG, E:?QUIRE JOEL M. F'~~NK, ESQUIRE Attorney :Eor Plaintiff 2125435 GORDON & WEINBERG, P.C. BY: FRE;DERIC I. WEINBERG, ESQUIRE Ider_tification No.: 41360 JOE;-~ M. FUNK, ESQUIRE IdE_~ntification No.: ~f1200 1001 E. Hector ,Street, Ste 220 Consr~ohocken, PA 19428 484/ 151--0500 Mai~_ Street Acauisi~ion Corp. COURT OF COMMON PLEAS CUMF3ERLAI~(D COUNTY vti~. DOCKET N0. 12-6058 CIVIL CHRISTINA M GEORGE NOTICE Purstant to Pa.R.Civ.P. 236 of the Supreme Court of Pennsylvania, you ~.re hereby Notified that a judgment= has been entered against you :,.n the above proceeding as indicated below. LXL Judgment by Agreement $2,556.19 LL Money Judgment $ ~L Judgment on Award of Arbitrators$ LL Judgment on Verdict$ IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, P SE CALL ATTORNEYS: FREDEF;IC I. WEINBERG OR JOEL FL S IRES A IS TELEPHONE NUMBER: 484/351-0500 ~- 11' S I ~- - _..-_- F'ROTHONOTARY GORDON & WEINBERG, P.C. BY: FF'.EDER_IC I. WEINBERG, ESQUIRE Ident~ication No.: 41360 JCFL ^". F~IN:C, ESQUIRE Icae:`l'.~ ~icati.:~n No.. 41200 1~~0" __. :iec'_or Street, Ste 220 Conshor_oc;~:e~~, P.A 19428 484/3`;1.-O~~C~ 2125435 Mair. Street Acquisition Corp. COURT C;F CC'"~IMON PLEAS Prothonot_ar~~ of Cumberland Court i DOCK`' NO. : I2-6058 CIVIL vs. CHRISTINA M GEORGE JUDGMENT BY AGREEMENT AND N C W , this _~ ~ '..-~ day o ~ ~~ ~~~" ~ ~~~~_,. 2 ~;:! 1 ~' , i t i s hereb~.~ st ~r~ulated and agreed to by and between, CHRISTIN)'~ ~i GEORGE hi.s/her successors and ass=i_gns and Frederi~~ I. Weinberg, esquire, counsel fog Main Street Acquisition Co_~p. that the Cour~_. enter a determir:ation in the above-captioned case as follows: 1. Judgment shall be entered in the amount of TWO THOUSAND, FIVE HUNDRED, FIFTY SIX DOLLARS AND NINETEEN CENTS($2,555.1~:~; _n favor of Mair. Sty eet Acquisition Corp. and against, CHRISTINA M C=.F:C>RGE her successors ar.d assigns; 2. F':_ainti`:f, Main Street Acquisition. Corp. ~.~il~_ =gree to accept she sum. of :32,556.19 from, CHRISTINA M GEORGE her succ:=ssors and assigns. T~.e first payment of $255.00 shall become due and pa~,~able on Oct . 3 ~, 2. 12, ther; 255.00 due Nov. 30, 2012, then 550. 00 -~ mo-~.t.:~ due on the 30t~, c.~ every month thereafter until the Stipulated ,~~dcment is paid it `_i:1 - ; 3. In the event that. CHRISTINA N[ GEORGE her successors and assigns do ~:.ot make payments as prescribed ir. paragraph 2, tc,~ y will be cons~idere~ ,n default and the Plaintiff, Main St:r.eet Acqu~sit=.o~ Corp. sha--1 ,,F~ allowed to exercise any and a=~1 remedies availab'~_e at law. Date: f~~._.~,,Z._~?: ~~ r~L .~ __ CHRISTINA M GEORGE Defendant FREDERIC I. WE ERG, squire Attorney for Plaintiff I.D. #41360 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500