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Home My WebLink About05-21472017169 THIS IS AN ARBITRATION MATTER. ASSESSMENT OF DAMAGES HEARING REQU 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 FUSA 10625 Techwoods Circle Cincinnati, OH 45242 vs. ROBERT M SHEELY 38 SHERWOOD CIRCLE ENOLA PA 17025 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO NOTICES : JS ' ?/'f7 YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLI SET FORTH IN THE FOLLOWING PAGES, YOU MUST TAKE ACTION WITHIN TWENTY (20; AFTER THIS COMPLAINT AND NOTICE ARE SERVED, BY ENTERING A WRITTEN APPEARi PERSONALLY OR BY ATTORNEY AND FILING IN WRITING WITH THE COURT YOUR DEFE1 OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. YOU ARE WARNED THAT FAIL TO DO SO THE CASE MAY PROCEED WITHOUT YOU AND A JUDGEMENT MAY BE EN AGAINST YOU BY THE COURT WITHOUT FURTHER NOTICE FOR ANY MONEY CLAIMED IN COMPLAINT OR FOR ANY OTHER CLAIM OR RELIEF REQUESTED BY THE PLAINTIFF. 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 LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BEI FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 DAYS NCE SES F YOU 'ERED THE OU AVE A iW TO COMPLAINT IN CIVIL-ACTION 1. At all times relevant hereto, the defendant(s) was holder of a credit card, which at the request of the defendan (s) was issued to the defendant(s) by the plaintiff under the terns of which the plaintiff agreed to extend to defendant(s)the us of plaintiff's credit facilities. 2. Defendant(s) accepted and used the aforesaid credi card so issued and by so doing agreed to perform the terms conditions prescribed by the plaintiff for the use of said coedit card. 3. The defendant(s)received and accepted goods and merchandise and/or accepted services or cash advances throug the use of the credit card issued by the Plaintiff. A true and correct copy of the Statement of Account is attached hereto s Exhibit "A". 4. All the credits to which the defendant(s)is entit have been applied and there remains a balance due in the of $6,312.19. 5. Plaintiff has made demand upon the defendant(s)fc payment of the balance due of $6,312.19 but the defendant(s failed and refused and still refuses to pay the same or any thereof. (has apart WHEREFORE, plaintiff claims of the defendant(s) the sudn of $6,312.19 at the rate of 6% from the date of June 27, 2001, together with costs and attorney fees. GORDON & WEINBERG, P.C. BY: FREDERIC I. kyrrgE- ESQUIRE PAUL M. SCH IELD, JR., ESQUIRE Attorney fo -laintiff P01h VERIFICATION FREDERIC I. WEINBERG, ESQUIRE, hereby states that he is attorney for the Plaintiff(s) in this action and verifies t 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 made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities. FREDERIC/I. WEINBERG, ESQUIRE EXHIBIT "A" AFFIDAVIT OF INDEBTEDNESS State of Ohio ) County of Hamilton ) ss. Vu, Bharati Lengade being sworn, deposes and says that she is Media Supervisor of Unifund CCR P ners herein called assignee, which is doing business at 10625 Techwoods Circle, Cincinnati, Ohio 45 42 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 M Sheely, Account Number 4366133068109544, the Tint unt o$7922.97 (principal balance in the amount of $6312.19 plus interest up through 02/17/2005 e amount of $1610.78). By the terms of the agreement between the defendant and the original creditor, i Brest is accruing from the aforesaid date at the rate of 6.00 percent per annum. This balance reflects an payments, credits or offsets made since the account was charged off. This account was originated with FUSA. Unifund CCR Partners purchased this account from SA. Said account has been assigned, transferred and set over unto, Gordon & Weinberg P.C. with full po er and authority to do and perform all acts necessary for the collection settlement, adjustment, compr raise or satisfaction of said claim, on behalf of Unifund CCR Partners. By: Subscribed and sworn to before me My Client # 829 ^n , ` yt? l ArdGclA L FREDMAN \1Jr PUE3lIC I r. it aJ+vN iXP1i iLS IVIARCH 5, 2001 17, 2005 Expires 629 Balance as of. Payment Due Minimum Payment Account Number 02/17/2005 Date Payment Enclosed Make checks Unifund Robert M Shealy 38 Sherwood Clr Enola PA 17025-1840 UNIFUND STATEMENT MESSAGE FROM UNIFUND Your account is past due $7922.97. The past due amount is included in the minimum nk alrready sent payment for the above payment. Please remit immediatam nt t you. ha ou This account is currently being serviced by: P C . . Gordon & Weinberg 21 S. 21 st St Philadelphia PA 19103 TRANSACTIONS: Date Transaction a ance ue aymen ew Balanc 02/17/2005 Unifund Purchased The $7922.97 $7922.97 $0 $7922.97 Above Referenced account from FUSA 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 ill be credited to your account as of our next business day. The crediting to your acco nt of payments received at any location other than the above address may be delay d up to 5 days of receipt This communication inform you that this obtained will be use( 30 days after receivi or any portion there notify this office in the debt or any porti debt or a copy of verification or ludgrr name ar creditor. from a debt collector. Federal law requires is to an attempt to collect a debt and any inform tion r that purpose. Unless you notify this office thin this notice that you dispute the validity of this ebt this office will assume this debt is valid. If you ing within 30 days from receiving this notice that thereof is disputed, we will obtain verification the Iudgment and we will mail you a cop of uch t to you. If you request this office in wiing ithin this notice, this office will provide you it the the original creditor, if different from the cu nt n ^' Gt c, 7' V1 'o+V m -G N `J i ? ? V 10 SHERIFF'S RETURN - REGULAR CASE NO: 2005-02147 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND UNIFUND CCR PARTNERS VS SHEELY ROBERT M SHANNON SHERTZER Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon SHEELY ROBERT M the DEFENDANT , at 1550:00 HOURS, on the 16th day of May 2005 at 38 SHERWOOD CIRCLE ENOLA, PA 1702 by handing to TONI SHEELY 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 18.00 Service 10.36 Affidavit .00 Surcharge 10.00 .00 38.36 Sworn and Subscribed to before me this day of ?7?L 2 t`US? A.D. h , . f ) -?l. .,a. A tJA So Answers: R. Thomas Kline 05/17/2005 GORDON & WEINBERG By: Deputy Sherif rothonotary 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 FUSA vs. ROBERT M SHEELY COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO PRAECIPE FOR JUDGMENT : 05-2147 civil t The Prothonotary will please enter Judgment in the above matter by default for want of an answer against the Defendant, ROBERT M SHEELY, and assesses the damages der statement below. FREDERIC I, BE SQUIRE PAUL M. SCHOFIELD JR., ESQUIRE Attorney for Pla nt' Principal $6,312.19 Interest from June 27, 2001 Q6% $3,120.52 Total: $9,432.71 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. FREDERIC I. WE BER , ESQUIRE PAUL M. SCHOFI , JR., ESQUIRE Attorney for Plaintiff Filed: By the Prothonotary: AND NOW, this e294?- day of NItwl? 2005 Judgment is entered in favor of the plaintiff(s) and against defendant, for want of an answer and damages assessed at th sum of , $9,432.71 as per the above certificat'on. 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 FUSA VS. ROBERT M SHEELY COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 05-2147 civil t CERTIFICATION OF ADDRESS I hereby certify that the precise residence of the holder of the within judgment is; UNIFUND CCR PARTNERS ASSIGNEEOF FUSA and that the last known address of defendant, ROBERT M SHEELY, 38 SHERWOOD CIRCLE, ENOLA PA 17025. GORDON & WEINBERG, P.C. BY. FREDERIC I. rF-Lg E ESQUIRE PAUL M. SCHOWF JR. ,ESQUIRE Attorney for ntiff 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 FUSA VS. ROBERT M SHEELY COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 05-2147 civil t 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, 36 SHERWOOD CIRCLE, ENOLA PA 17025; 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 Before me this a f` Day 2005. NOTARIAL SEAL JOHN V MCBRIDE, III, Notary Public City of Philadelphia, Phh County Iv Commission Expires August A, 200 FREDERIC I. PAUL M. SCHq Attorney for $, ESQUIRE JR. ESQUIRE iff 2017169 GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 PAUL M. SCHOFIELD, JR. , ESQUIRE Identification No.: 61894 21 SOUTH 21ST STREET PHILADELPHIA, PA 19103 215/988-9600 UNIFUND CCR PARTNERS ASSIGNEE OF FUSA vs. ROBERT M SHEELY TO/PARA COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 05-2147 Civil t NOTICE OF INTENTION TO TAKE DEFAULT ROBERT M SHEELY 38 SHERWOOD CIRCLE ENOLA PA 17025 DATE OF NOTICE/FECHA DEL AVISO: June 7, 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 . WE ERG, ESQUIRE PAUL M. S IELD, JR., ESQUIRE P10D-2 jtl, iL?rF? a. m vO zPA w l% t„ A N ? 2017169 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 FUSA COURT OF COMMON PLEAS CUMBERLAND COUNTY VS. ROBERT M SHEELY DOCKET NO. : 05-2147 Civil t 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 IN THE AMOUNT OF $9,432.71. IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL GORDON & WEINBERG, P.C. AT 215/988-9600. GORDON & WEINBERG, P.C. BY: FREDERIC I. EI ERG, ESQUIRE PAUL M. SC OF LD, JR.,ESQUIRE Attorney for Plaintiff Dated: June 21, 2005 2017169 GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 215/988-9600 UNIFUND CCR PARTNERS ASSIGNEE OF FUSA COURT OF COMMON PLEAS CUMBERLAND COUNTY VS. ROBERT M SHEELY DOCKET NO. : 05-2147 civil t ORDER TO SATISFY JUDOMMU TO THE PROTHONOTARY: Kindly mark the judgment entered June 29, 2005 in the above- captioned matter satisfied upon payment of your costs only. GORDON & WEINBERG, P.C. BY: FREDERIC I. NBE G, ESQUIRE JOEL M. FLINK UIRE Attorney for Plaintiff P005 r.. ,? 52 4 'r