The URL can be used to link to this page

Home My WebLink About05-0147 2014318 THIS IS AN ARBITRATION MATTER. ASSESSMENT OF DAMAGES HEARING REQUIRED. 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 GATEWAY (CONSUMER) 10625 Techwoods Circle Cincinnati, OH 45242 COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. DOCKET NO. os - /47 Cv'~l~~ PEGGY A LEYDIG 103 SHOLLY DR MECHANICSBURG PA 17055 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, 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 merchandise 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 $1,459.66. 5. Plaintiff has made demand upon the defendant(s)for payment of the balance due of $1,459.66 but the defendant (s)has failed and refused and still refuses to pay the same or any part thereof. WHEREFORE, plaintiff claims of the defendant(s) the sum of $1,459.66 at the rate of 5% from the date of January 7, 2001, together with costs and attorney fees. GORDON & WEINBERG, P.C. BY: FREDERIC I. W ERG, ESQUIRE PAUL M. SCHOFIELD, JR., ESQUIRE Attorney for Plaintiff P01h 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, 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 I. WE EXHIBIT "A " AFFIDAVIT OF INDEBTEDNESS State of Ohio ) County of Hamilton ) ss. J 0 I L/31g Jessica Bergholz being sworn, deposes and says that she is Media Supervisor ofUnifund CCR Partners herein called assignee, which is doing business at 10625 Techwoods Circle, Cincinnati, Ohio 45242 and that she is authorized to make the statements and representations herein. The defendant is not in any branch of the military. There is due and payable from Peggy A Leydig, Account Number 6011766603331570, the amount of $1685.91 (principal balance in the amount of$1459.66 plus interest up through 09/08/2004 in the amount of$226.25). By the terms of the agreement between the defendant and the original creditor, interest is accruing from the aforesaid date at the rate of 5.00 percent per annum. This balance reflects any payments, credits or offsets made since the account was charged off This account was originated with GATEWAY (CONSUMER). Unifund CCR Partners purchased this account from GATEWAY (CONSUMER). Said account has been assigned, transferred and set over unto, Gordon & Weinberg P.C. with full power and authority to do and perform all acts necessary for the collection, settlement, adjustment, compromise or satisfaction of said claim, on behalf ofUnifund CCR Partners. By: Jessica Ber~olz Media Supervisor 10625 Techwoods Circle Cincinnati, OH 45242 Address sw7re iVy of September. ~ ./ /\ Notary Public j', I My commission Expires Client # 829 <; "'0 ~ ;y~~ ~ ~ .0 ~ CJ ~-rJ P- ~ --L. Q <1-' c~., ....,. 1"---=- . (J' ~ . ; - ( ," :--~ , ., ( . ~- '" :~... =2 .. "" = c::) () <:.rI -n i;: -i 7':: Fh :n I -0 Fr; -.J iI; Y ~ g~ ... "'Yo"" N :'D .< ~ 2014318 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 GATEWAY (CONSUMER) COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. DOCKET NO. 05-147 PEGGY A LEYDIG 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 I, PAUL M. SC Attorney f BY: Dated: February 15, 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 COURT OF COMMON PLEAS CUMBERLAND COUNTY UNIFUND CCR PARTNERS ASSIGNEE OF GATEWAY (CONSUMER) vs, DOCKET NO. 05-147 PEGGY A LEYDIG PRAECIPE FOR JUDGMENT The Prothonotary will please enter Judgment in the above matter by default for want of an answer against the Defendant, PEGGY A LEYDIG, and assesses the damage per statement below, FREDERIC I. WEINB PAUL M. SCHOFIE Attorney for PIa , SQUIRE I JR/.', ESQUIRE ~ff Principal Interest from January 7, 2001 @S% Total: $1,459.66 $299.93 $1,759.59 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) days prior to the date of the filing of this Praecipe, Filed: By the prothonotary: AND NOW, this Irrt-J...... day of hb. , 2005 Judgment is entered in favor of the plaintiff(s} and against defendant, for want of an answer and da ges assessed at ime f trial. Prothonotary ~ 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 GATEWAY (CONSUMER) COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. PEGGY A LEYDIG DOCKET NO. 05-147 CERTIFICATION OF ADDRESS I hereby certify that the precise residence of the holder of the within judgment is; UNIFUND CCR PARTNERS ASSIGNEEOF GATEWAY (CONSUMER) and that the last known address of defendant, PEGGY A LEYDIG, 103 SHOLLY DR, MECHANICSBURG PA 17055. GORDON & WEINBERG, P,C. BY: FREDERIC I, W ESQUIRE PAUL M, SCHO E 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 UNIFUND CCR PARTNERS ASSIGNEE OF GATEWAY (CONSUMER) COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. DOCKET NO. 05-147 PEGGY A LEYDIG 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, 103 SHOLLY DR, MECHANICSBURG PA 17055; 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 \ C; ~ay , 2005. a--_ " L. TH OF PENNSYLVA.NIA NOTARIAL SEAL JOHN V McBRIDE III, Notary Public City of Philadelphia Phila County M CommlS$ion Ex .res A ust 4, 2008 FREDERIC I. W ,..---~... ": 2014318 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 41360 ESQUIRE 81894 UNIFUND CCR PARTNERS ASSIGNEE OF GATEWAY (CONSUMER) COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. DOCKET NO. PEGGY A LEYDIG NOTICE OF INTENTION TO TAKE DEFAULT To/pARA PEGGY A LEYDIG 103 SHOLLY DR MECHANICSBURG PA 17055 DATE OF NOTICE/FECHA DEL AVISO, February 4, 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, (/;l.-~."..__."..,. BY: FREDERIC I. ,WEINBERG, ESQUIRE PAUL M. SCHbFIELD, JR., ESQUIRE L PI0D-2 .IQ. ~ P*, \\.. ~ -~ -~::j r",,"tl.- () 0. ~ ~~( .. . r ~ ~ --L '-<...) ..\ - - , ," (," SHERIFF'S RETURN - REGULAR CASE NO: 2005-00147 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND UNIFUND CCR PARTNERS VS LEYDIG PEGGY CPL, TIMOTHY REITZ , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon LEYDIG PEGGY A the DEFENDANT , at 2030:00 HOURS, on the lOth day of January 2005 at 103 SHOLLY DR MECHANICSBURG, PA 17055 by handing to PEGGY A LEYDIG a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof, Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18,00 7.40 .00 10,00 .00 35.40 .?",~~ R, Thomas Kline 01/1l/2005 GORDON & WEINBERG Sworn ~nd Subscribed to before .1< me this ..l'l - day of C)il-.tA.<.uuy J {JIJ ~ A, D . (. lyu_ an" pOPLL/ # I Prothonotary , By: _. /7 --;7 -~,/' ~'-7/~ I/o 4'9;i{h~rif/ 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 GATEWAY (CONSUMER) vs. DOCKET NO. 05-147 PEGGY A LEYDIG ORDER TO SATISFY JUDGMENT TO THE PROTHONOTARY: Kindly mark the judgment entered February 17, 2005 in the above-captioned matter satisfied upon payment of your costs only. GORDON' WE~C. BY: ~ FREDERIC I. Vi'EINBERG, ESQUIRE Attorney for Plaintiff P005 <2 d';~~' if/. "2 ~. l~2; "=:, "::i; q. ~~ ~'9, .- gr;:~h N --r""...~~ 0'"") ;.;...~ :6 .:c.\ ?1 .-> ~ G1" ~ G"' """ ':Jl: o -- o -