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HomeMy WebLinkAbout13-3881 Supreme Court of Pennsylvania For Prothonotar Use Onl Court of Common Pleas Docket No: Civil Cover Sheet 3 CUMBERLAND County The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the filing and service ofpleadings and other papers required by law or rules of the court. Commencement of Action: ® Complaint ❑ Writ of Summons ❑ Petition ❑ Transfer from Another Jurisdiction ❑. Declaration of Taking S E Lead Plaintiffs Name: Lead Defendant's Name: . C MIDLAND FUNDING LLC LARE GRINAWAY T I Any money damages requested ?: ® Yes ❑ No Dollar Amount Requested: ® within arbitration limits O (check one) ❑ outside arbitration limits N Is this a Class Action Suit? ❑ Yes ® No Is this an MDJAppeal? ❑ Yes ® No A Name of Plaintiff/Appellant's Attorney: Yale D. Weinstein, Esquire ❑ Check here if you have no attorney (are a Self - Represented [Pro Se] Litigant) Nature of the Case Place and "X" to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim, check the one that you consider most important. TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS ❑ Intentional ❑ Buyer Plaintiff Administrative Agencies ❑ Malicious Possession ® Debt Collection: Credit Card ❑ Board of Assessment S ❑ Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections E ❑ Nuisance ❑ Depart. of Transportation C ❑ Premises Liability ❑ Statutory Appeal: Other T ❑ Product Liability (does not ❑ Employment Dispute: I include mass tort) Discrimination O ❑ Slander/Libel/Defamation ❑ Employment Dispute: Other ❑ Zoning Board N ❑ Other: ❑ Other: B ❑ Other: MASS TORT • Asbestos • Tobacco ❑ Toxic Tort - DES • Toxic Tort - Implant • Toxic Waste • Other: REAL PROPERTY MISCELLANEOUS ❑ Ejectment ❑ Common Law /Statutory Arbitration ❑ Eminent Domain /Condemnation ❑ Declaratory Judgment ❑ Ground Rent ❑ Mandamus ❑ Landlord/Tenant Dispute ❑ Non - Domestic Relations ❑ Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABILITY ❑ Mortgage Foreclosure: Commercial ❑ Quo Warranto ❑ Dental ❑ Partition ❑ Replevin ❑ Legal ❑ Quiet Title ❑ Other: ❑ Medical ❑ Other: ❑ Other Professional: c � z u t? 1 C F f E 1i mill: I10hVb 1 A J ?013 JAL PH CUMOERLAND COUN P ENNS YLVA NIA Burton Neil & Associates, P.C. By: Yale D. Weinstein, Esquire ID. NO. 89678 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696 -2120 Attorney for Plaintiff MIDLAND FUNDING LLC IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. LARE GRINAWAY NO. 1028 Teakwood Ln Enola PA 17025 Defendant CIVIL ACTION -LAW Complaint - 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 (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 claim 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 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. 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. LAWYER REFERENCE AND INFORMATION SERVICE Cumberland County Bar Assoc. 32 South Bedford Street Carlisle, PA 17013 S Telephone No. 717- 249 -3166 or 800 - 990 -9108 168570/304 am ��a3, d�► co/ Yv-)S� CIVIL ACTION 1. Plaintiff, MIDLAND FUNDING LLC, is a business entity with offices located at 8875 Aero Drive, Suite 200, San Diego, CA 92123. 2. MCM§ records show that the Defendant(s) LARE GRINAWAY is/ are individual(s) residing at 1028 TEAKWOOD LN, ENOLA, PA 17025. 3. As set forth in records maintained on behalf of Plaintiff, this action is based upon a credit agreement entered into between Defendant(s) and the original credit grantor. 4. Plaintiff is the current owner of, and/or successor to, the obligation sued upon, and was assigned all the rights, title and interest to Defendant§ HSBC BANK NEVADA, N.A. account XXXXXXXXXXXX8538 (hereinafter "the account "). Midland Credit Management, Inc. (hereinafter "MCM ") services the account on behalf of Plaintiff. 5. MCM§ records state that this action is based upon a credit agreement entered into between defendant(s) and the original credit grantor. MCM§ records further state that defendant(s) used or authorized the use of the credit account but failed to make the payments due pursuant to the agreement. 6. MCM§ records show that the defendant(s) owed a balance of $3561.55 as of 2013- 05 -14. WHEREFORE, Plaintiff respectfully requests that jud tith favor of Plaintiff and against Defendant(s) in the amount of $3561.55 togst and costs. B At ey for Plaintiff Page - 1 8533726907 AFFINDEBT C0118421 Verification Melissa Harne, being duly sworn (or affirmed) according to law deposes and says that I am employed as a Legal Specialist for Midland Credit Management, Inc. ( "MCM "), servicer of this account on behalf of plaintiff. I am a competent person over eighteen years of age, and make these statements herein based upon personal knowledge of those account records maintained on plaintiffs behalf. I am authorized to make this verification on plaintiffs behalf. The facts set forth in the foregoing pleading are true and correct. The undersigned understands that the statements therein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. MAY 2 2 2013 Date Melissa Harne GA 1 Frederick J Hanna & Associates, P.C. Page - 2 I�Igq IIIIII�I�IIIIIIIgq�IA 1001111111®AMI111111llll 111111Illgll���lllllllllq� 8533726907 AFFINDEBT C0118421 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Jody S Smith Chief Deputy 2913 JUL 18 AM 9'. 5 9 Richard W Stewart PENNSYLVANIA Midland Funding LLC Case Number vs. | 2013-3881 LanwGhnoway | SHERIFF'S RETURN OF SERVICE O7/OQ/2013 O7:26PM-Deputy Amanda Cobough. being duly sworn according tolaw, served the requested Complaint& Notice by^peroonoUy'' handing m true copy hoo person representing themselves tobethe Defendant,ho wit: LaroGhnawayat1O28 Teakwood Lane, East Pennoboro Emo\a PA 17025. SHERIFF COST: s44.Q5 SO ANSWERS, July 1O. 2O13 RONNYR ANDERSON, SHERIFF 168570/221 MIDLAND FUNDING LLC IN THE COURT OF COMMON PLEAS 8875 Aero Drive, Suite 200 San Diego, CA 92123 Plaintiff CUMBERLAND COUNTY,PENNSYLV4NI,4, C-) V. XPI rrl-- NO. 13-3881-CIVIL, C= LAKE GRINAWAY 1028 Teakwood Ln =_--n Enola PA 17025 Defendant CIVIL ACTION-LAW C__ Praecipe for Default Judgment To the Prothonotary: Please enter judgment by default for want of an answer in the above case in favor of the plaintiff and against the defendant, and assess damages as follows: Principal: $3,561.55 TOTAL $3,561.55 Understanding that false statements herein made are subject to penalty under 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities, I verify that: 1. The above are the precise last-known addresses of the judgment debtor and creditor. 2. The annexed notice of intention to file this praccipe was mailed to all parties against whom judgment is to be entered and to their record attorneys,if any,after the default occurred,and at least ten days prior to the date of the filing of this praecipe. 3. Pursuant to Section 201(b)(1)(A)of the Servicemembers Civil Relief Act of2003(SCRA), the defendant is not in the military service of the United States based on informati received from the defendant and/or the Department of Defense website. JUDGMENT BY'DEFAULT ENTERED Burton it& s ciates, P.C.,- AND DAMAGES ASSESSED AS ABOVE. based n on inf 0 s rmat c i iat r esreceived Pv C NOTICE G17 UNDER]""I,CIV,P. 23(*1 By: Weinstein, Esc Yal Weinstein, Esquire i f f wa. A 09V A mey for Plaintiff Pro ProflMn I. 0 9 otafy/'ft4L 1. .NO. 89678 0 0 0 i S Andrew r v 1 60 Andrew Drive, Suite 170 West Chester, PA 19380 This is an attempt to collect a debt, and any information obtained will be used for that purpose. This communication is from a debt collector. 1 68570/265 MIDLAND FUNDING L LC : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY,PENNSYLVANIA V. : NO. 13-3881-CIVIL LAKE GRINAWAY Defendant : CIVIL ACTION - LAW TO: Lare Grinaway 1028 Teakwood Ln Enola PA 17025 DATE OF NOTICE:August 10,2013 IMPORTANT NOTICE You are in default because you have failed to enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten(10) days from the date of this notice,a judgment may be entered against you without a bearing 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 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. LAWYER REFERENCE AND INFORMATION SERVICE Cumberland County Bar Assoc. 32 South Bedford Street Carlisle,PA 17013 Telephone No. 717-249-3166 or 800-990-9108 Burton N it &As iat P.C. Burton BY D n tein, 6ire Attorney f r laintiff This is an attempt to collect a debt,and any information Identifica n No. 89678 obtained will be used for that purpose. This 1060 An rew Drive, Suite 170 communication is from a debt collector. West Chester, PA 19380 (610)696-2120 Burton Neil&Associates,P.C. By: Yale D. Weinstein,Esquire ID.NO. 89678 1.060 Andrew Drive, Suite 170 West Chester,PA 19380 610-696-2120 Attorney for Plaintiff MIDLAND FUNDING LLC IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY,PENNSYLVANIA V. NO. 13-3881-CIVIL LARE GRINAWAY Defendant CIVIL ACTION-LAW Rule of Civil Procedure NO. 236 (Revised) Notice is given that a JUDGMENT in the above captioned matter has been entered against you on 2D 1 Prothonotary By:— Deputy If you have any questions concerning the above,please contact: Yale D. Weinstein,Esquire Attorney for Party Filing 1060 Andrew Drive, Suite 170 West Chester, PA 19380 Phone: 610-696-2120 This is an attempt to collect a debt,and any information obtained will be used for that purpose. This communication is from a debt collector.