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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 GE VISA CLASSIC-CONVERSION
10625 Techwoods Circle
Cincinnati, OH 45242
VS.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
DOCKET NO
ROBERT HORST JR
843 KIEHL DRIVE
LEMOYNE PA 17043
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 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
$989.98.
5. Plaintiff has made demand upon the defendant(s)for
payment of the balance due of $989.98 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
$989.98 at the rate of 24.99% from the date of January 8, 2003,
together with costs and attorney fees.
GORDON & WEINBERG, P.C.
t
BY:
FREDERIC I. W BERG, ESQUIRE
PAUL M. SCH ILLD, JR., ESQUIRE
Attorney f -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. W NBERG, ESQUIRE
EXHIBIT "A"
AFFIDAVIT OF INDEBTEDNESS
State of Ohio)
County of Hamilton) ss. C?
Jessica Bergholz being sworn, deposes and says that she is Media Supervisor of Unifund 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 Robert Horst Jr, Account Number 4366120007976885, the amount of
$1703.46 (principal balance in the amount of $989.98 plus interest up through 07/27/2004 in the amount of
$713.48). By the terms of the agreement between the defendant and the original creditor, interest is accruing
from the aforesaid date at the rate of 24.99 percent per annum. This balance reflects any payments, credits
or offsets made since the account was charged off.
This account was originated with GE VISA CLASSIC-CONVERSION. Unifund CCR Partners purchased
this account from GE VISA CLASSIC-CONVERSION. 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.
DATED this July 27, 2004
PARTNERS
By: Jessica Bergholz
Media Supervisor
10625 Techwoods Circle Cincinnati, OH 45242
Address
Subscribed and sworn to before me this 27 day of July, 2004
Year
Notary Public
Client # 829
My commission Expires
CHRISTINA NI. ALLEN
Notary Politic
In Iod liar the State d Ohio
illy Commission Expires
Feb. 1, 2007
?? ,?, T to
? j
SHERIFF'S
CASE NO: 2005-01278 P
COMMONTWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
UNIFUND CCR PARTNERS
VS
HORST ROBERT JR
Thomas Kline
- NOT FOUND
,Sheriff or Deputy Sheriff, who
duly sworn according to law, says, that he made a diligent sea
inquiry for the within named DEFENDANT
HORST ROBERT JR
unable to locate Him in his bailiwick
COMPLAINT & NOTICE
He therefore returns Ithe
NOT FOUND I
the within named DEFENDANT , HORST ROBERT JR
843 KIEHL DRIVE
PA 17043
GIVEN ADDRESS IS FOR ROBERT HORST SR. HE HAS NO IDEA
WHERE HIS SON IS LIVING.
ng
and
was
as to
Sheriff's Costs: So answers: - :-=' --?
Docketing 18 .00 71
-?
Service 20. 72
Not Found 5 .00 R. Thomas Kline
Surcharge 10. 00 Sheriff of Cumberland County
.00
53. 72 GORDON & WEINBERG
04/04/2005
Sworn and subscribed to before me
this ?- day of
,ZOO A.D.
Prothonotary
Curtis R. Long
Prothonotary
OfftLE of the Vrotbonotarp
Cumberzanb Countp
Renee K. Simpson
Deputy Prothonotary
John E. Slike
Solicitor
ns - 12,-1,Q CIVIL TERM
ORDER OF TERMINATION OF COURT CASES
AND NOW THIS 29TH DAY OF OCTOBER 2008 AFTER MAILING NOTICE OF
INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE
CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA
R C P 230.2
BY THE COURT,
CURTIS R. LONG
PROTHONOTARY
One Courthouse Square • Carlisle, Pennsylvania 17013 • (717) 240-6195 • Fax (717) 240-6571