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Home My WebLink About04-6274 2013095 THIS IS AN ARBITRATION MATTER. ASSESSMENT OF DAMAGES HEARING REQUIRED. GORDON & WEINBERG I P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 PAUL M. SCHOFIELD I JR., ESQUIRE Identification No. : 81894 21 SOUTH 21ST STREET PHILADELPHIA, PA 19103 215/988-9600 UNIFUND CCR PARTNERS ASSIGNEE OF PROVIDIAN NATIONAL BANK 10625 Techwoods Circle Cincinnati I OH 45242 COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. DOCKET NO. 04 - b~'lf C'UlUEIt..vy\ JEANNE R DUNCANSON 408 NORMAN RD 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. BEDFORD STREET CARLISLE I PA 17013 (717) 249-3166 COMPLAINT IN CIVIL-ACTION 1. 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 plaintiff under the terms of which the plaintiff agreed to extend to defendant(s)the use of plaintiff's credit facilities. 2. 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 plaintiff for the use of said credit card. 3. 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 Plaintiff. A true and correct copy of the Statement of Account is attached hereto as Exhibit "A". 4. All the credits to which the defendant (s) is entitled have been applied and there remains a balance due in the amount of $3,401.42. 5. Plaintiff has made demand upon the defendant(s)for payment of the balance due of $3/401.42 but the defendant(s)has failed and refused and still refuses to pay the same or any part thereof. WHEREFORE I plaintiff claims of the defendant{s) the sum of "$3/401.42 at the rate of 6% from the date of December 11, 2000, together with costs and attorney fees. GORDON & WEINBERG I P.C. BY: FREDERIC I. NB RG, ESQUIRE PAUL M. SCHO , JR., ESQUIRE Attorney for Plaintiff POlh VERIFICATION FREDERIC I. WEINBERG, ESQUIRE, hereby states that he is the attorney for the Plaintiff(s) in this action and verifies that the statements made in the foregoing pleading are true and correct to the best of his knowledge I information and belief. The undersigned understands that the statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities. FREDERIC EXHIBIT" A" 829 Account Number 4479480100451143 Balance as of: Payment Due 07/28/2004 Date $4063_64 Past nue I Minimum Payment $4063.64 Payment Enclosed Is Make checks payable to: Unitund UNIFUND STATEMENT Jeanne R Duncanson 408 Norman Rd Camp Hill PA 17011-6130 MESSAGE FROM UNIFUND Your account is past due $4063.64. The past due amount is included in the minimum payment. Please remit immediately. If y.ou have already sent payment for the above amount, thank you. This account is currently bein~serviced by: Gordon & WelObern -P.C. 21 S. 21st St Philadelphia PA 19103 TRANSACTIONS: Date II 07/28/2004 Unifund Purchased The Above Referenced account from Providian National Bank Transaction II Balance II Due $4063.64 $4063.64 II Payments II New Balance $0 $4063.64 Prompt crediting of payments. To receive credit for payments as of the date of receipt, we must receive your check or money order at: Unifund 10625 Techwoods Circle Cincinnati, OH 45242 Payments received at the above address in the manner specified after that time will be credited to your account as of our next business day. The crediting to your account of payments received at any location other than the above address may be delayed up to 5 days of receipt This communication is from a debt collector. Federal law reCl.uires us to inform you that this is an attempt to collect a debt and any Information obtaineCl will be used for that purpose. Unless you notify this office within 30 days after receiving this notice that you dispute the validity of this debt or any portion thereof1 this office will assume this debt is valid. If you notify this office in writing within 30 days from receiving this notice that the debt or any portion thereof is disputed, we will obtain verification of the debt or a copy of a judgment anCi we will mail you a copy of such verification or judgment to you. If you request this office in writing within 30 days after receiving this notice, this office will provide you with the name and address of the original creditor, if different from the current creditor. , . BALANCE AS PAYMENT ACCOUNT NUMBER OF061281Oi DUE DATE 4479-4801-0045-1143 $3,401.4211 JUL23, 20011 o Indloate change 01 addr... on back MINIMUM PAYMENT AMOUNT ENCLOSED PROVIDIAN VISA CARD $803.00 I [ $ Make Checks Payable to Providian 11.1..1111I11....11..1111I1111I1111111"111.1.1111..1.1111.111 PROVIDIAN VISA CARD PO BOX 60005 LOS ANGELES CA 90060-0005 Please be sure .... this address appears in the window. 1",III,"IJ1III".II'IlII.II"".IIIIII,llu.IIII,I,.I'III.11 JEANNE R DUNCANSON 408 NORMAN RD CAMP HILL PA 17011-6130 Page 1 of 1 000000 2Z0 44794801004511430080300034014200000 OET<,CH HERE ~ MESSAGES FROM PROVIDIAN VISA CARD Your account Is past due and must bl> paid Immediately to avoid funher credit damage and possible reh,rral of your account tor additional collection action. If you are unable to make your paymGrtllmmedlately. callus at 1.600.918.9180. Also note that your account is $752.42 over your $2,649.00 credit line. While your Account Agreement may require you to pay this overlimlt amount. we are giving you the flexibility of paying only $803.00. Paying jUSlthls minimum due payment will leave your account in an overlimlt status. We encourage you to pay the additional $752.42 as soon as posslbll>. TRANSACTIONS Post Date Description Trans Date Reference Number Amount No Activity This Month .. AVAILABLE CREDIT .. Your Total Available Credit Is $.00 ... $0.00 of your Available Credit can be accessed for Cash Advances. .. The portion of your credit line that can be used for Cash Advances is limited to $2.649.00. ACCOUNT SUMMARY FOR BILLING ERRORS AND IMPORTANT INFORMATION, SEE REVERSE SIDE. STATEMENT DATE 06nB/01 PAYMENT INFORMATION Number of Days in Billing Cycle 17 Previous Balance - Credits - Payments + Purchases & other Charges + Cash Advances + FINANCE CHARGE; On Balances + late Charge = NEW BALANCE ??oo??oo0 1541 A151 $3,401.42 Account Number 44794801 0045 1143 .00 Purchase Cash Advance .00 Average Credit Line .." $2,649 Daily Balance $.00 $.00 .00 Available Credit ".. $.00 .00 ANNUAL PERCENTAGE RA TE 0.00% 0.00% Minimum Payment Due $803.00 .00 .00 Daily Periodic Rate .000000% .0??oo0 % Payment Due Date 07n3101 $3,401 .42 p ~ 1 1- ~ r-.;> 0 B (") f"";:':? ,--,") -n " ~ ..1_- -1 ~ r-;-? i~:i ;q ..c:: (> \", ~ ..Q Ci -r'~ ~ -. ) \. ) ~ r ,'.., L f' ;'r.~ - r'-'~ \ 1 Y- '" , <-:? ". en ." ; ...,~ (.::> 2013095 GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No. : 41360 PAUL M. SCHOFIELD, JR., ESQUIRE Identification No.: 81894 21 SOUTH 21ST STREET PHILADELPHIA, PA 19103 215/988-9600 UNIFUND CCR PARTNERS ASSIGNEE OF PROVIDIAN NATIONAL BANK COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. DOCKET NO. 04-6274 JEANNE R DUNCANSON NOTICE PURSUANT TO RULE 236 OF THE SUPREME COURT OF PENNSYLVANIA, YOU ARE HEREBY NOTIFIED THAT A JUDGMENT BY DEFAULT HAS BEEN ENTERED AGAINST YOU IN THE ABOVE PROCEEDING. IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL GORDON & WEINBERG, P.C. AT 215/988-9600. GORDON & WEINBERG, P.C. FREDERIC PAUL M. S IELD, JR. ,ESQUIRE Attorney for Plaintiff BY: Dated: February 4, 2005 GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No. : 41360 PAUL M. SCHOFIELD, JR., ESQUIRE Identification No.: 81894 21 SOUTH 21ST STREET PHILADELPHIA, PA 19103 215/988-9600 UNIFUND CCR PARTNERS ASSIGNEE OF PROVIDIAN NATIONAL BANK COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. DOCKET NO. 04-6274 JEANNE R DUNCANSON PRAECIPE FOR JUDGMENT The Prothonotary will please enter Judgment in the above matter by default for want of an answer against the Defendant, JEANNE R DUNCANSON, and assesses the dama per statement below. SQUIRE ESQUIRE Principal Interest from December 11, 2000 @6% Total: $3,401.42 $847.65 $4,249.07 I hereby certify that written notice of the intention to file this Praecipe was mailed or delivered to the parties against whom judgment is to be entered and to his attorney of record, if any, after the default occurred and at least ten (10) 'or to the date of the filing of this Praecipe. Filed: By the Prothonotary: AND NOW, this 7../.1.. day of T~. , 2005 Judgment is entered in favor of the plaintiff(s) and against defendant, for want of an answer and dam es as~ess~~ tim f trial. Prothonotary , ESQUIRE PAUL M. SCHOF JR., ESQUIRE Attorney for Plaintiff < GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 PAUL M. SCHOFIELD, JR., ESQUIRE Identification No.: 81894 21 SOUTH 21ST STREET PHILADELPHIA, PA 19103 215/988-9600 COURT OF COMMON PLEAS CUMBERLAND COUNTY UNIFUND CCR PARTNERS ASSIGNEE OF PROVIDIAN NATIONAL BANK vs. DOCKET NO. 04-6274 JEANNE R DUNCANSON CERTIFICATION OF ADDRESS I hereby certify that the precise residence of the holder of the within judgment is; UNIFUND CCR PARTNERS ASSIGNEEOF PROVIDIAN NATIONAL BANK and that the last known address of defendant, JEANNE R DUNCANSON, 408 NORMAN RD, CAMP HILL PA 17011. GORDON & WEINBERG, P.C. BY: GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 PAUL M. SCHOFIELD, JR., ESQUIRE Identification No.: 81894 21 SOUTH 21ST STREET PHILADELPHIA, PA 19103 215/988-9600 UNIFUND CCR PARTNERS ASSIGNEE OF PROVIDIAN NATIONAL BANK COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. DOCKET NO. 04-6274 JEANNE R DUNCANSON AFFIDAVIT OF NON-MILITARY SERVICE FREDERIC I. WEINBERG, ESQUIRE, being duly sworn according to law, deposes and says that he represents the plaintiff in the above- entitled case; that he is authorized to make this affidavit on behalf of the plaintiff; and that the above-named defendant is over twenty- one years of age; that the address of the defendant is, 408 NORMAN RD, CAMP HILL PA 17011; that the occupation of the defendant is unknown; and that the defendant is not in the Military Service of the United States, nor any State or Territory thereof or its allies as defined in the Soldiers' and Sailors' Civil Relief Act of 1940 and the amendments thereto. Sworn to and Subscribed ,d -( tI Before me this ~ Day , 2005. LTHOt- ....1:-. NOTARIAL SEAL JOHN V McBRIDE, III, Notary PuOIl< C"y of Philadelphia. Phila. County M CommllliOll Expirel A It 4, 2008 FREDERIC I. WE GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, Identification No. : PAUL M. SCHOFIELD, JR., Identification No. : 21 SOUTH 21ST STREET PHILADELPHIA, PA 19103 215/988-9600 ESQUIRE 413 60 ESQUIRE 81894 UNIFUND CCR PARTNERS ASSIGNEE OF PROVIDIAN NATIONAL BANK COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. DOCKET NO. 04-6274 JEANNE R DUNCANSON NOTICE OF INTENTION TO TAKE DEFAULT TO/PARA JEANNE R DUNCANSON 408 NORMAN RD CAMP HILL PA 17011 DATE OF NOTICE/FECHA DEL AVISO: January 18, 2005 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 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 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 GORDON & WEINBERG, P.C. BY: FREDERIC I. WE PAUL M. ESQUIRE P10D-2 SHERIFF'S RETURN - REGULAR CASE NO: 2004-06274 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND UNIFUND CCR PARTNERS VS DUNCANSON JEANNE R RON KERR , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania I who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon DUNCANSON JEANNE R the DEFENDANT at 1857:00 HOURS I on the 29th day of December, 2004 at 408 NORMAN RD CAMP HILL, PA 17011 by handing to SCOTT DUNCANSON I HUSBAND a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 11.84 .00 10.00 .00 39.84 So Answers: .-.,~a:;:/ . ~~ Y'A' .r ,_<,;~,:;:":{'7':C"",,,-1'::-..'::... <.~~ R. Thomas Kline 12/30/2004 GORDON & WEINBERG Sworn and Subscribed to before By: ~U~ l~ Deputy Sheriff me this 1G5- /0 '-- day of I '-I""<"~ J"'~ A.D. C A lh <: t?tf!t", ~ Pr. onotary ,