HomeMy WebLinkAbout05-23882017803
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 PROVIDIAN NATIONAL BANK
10625 Techwoods Circle
Cincinnati, OH 45242
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
VS.
RICHARD K HUSLER
90 SPRINGERS LN LOT 91
NEW CUMBERLAND PA 17070
DOCKET NO
NOTICE
: OS C1U"
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 $1,022.32.
5. Plaintiff has made demand upon the defendant(s)for
payment of the balance due of $1,022.32 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
$1,022.32 at the rate of 6% from the date of May 11, 2001,
together with costs and attorney fees.
GORDON & WEINBERG, P.C.
BY:
FREDERIC J.NBERG, ES?Ulx?
PAUL M. CHOFIELD, JR., ESQUIRE
Attorn y,€-Or 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. WEINBERG, ESQUIRE
EXHIBIT "A"
AFFIDAVIT OF INDEBTEDNESS
State of Ohio )
County of Hamilton ) ss.
Bharati Lengade 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 Richard K Husler, Account Number 4479412825204929, the amount of
$1233.45 (principal balance in the amount of $1022.32 plus interest up through 03/15/2005 in the amount
of $211.13). By the terms of the agreement between the defendant and the original creditor, interest is
accruing from the aforesaid date at the rate of 6.00 percent per annum. This balance reflects any payments,
credits or offsets made since the account was charged off.
This account was originated with Providian National Bank. Unifund CCR Partners purchased this account
from Providian National Bank. 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 of Unifund CCR Partners.
DATED thisMarch 15, 2005
UNH UND CCR PARTNERS
By: Bharati Lenaade
Media Supervisor
10625 Techwoods Circle Cincinnati, OH 45242
Address
Subscribed and sworn to before me this 15/day of March. 2005
7-- Year
Notary runuc
My commission Expires
P?t?r»RY PU8LIC
v OHIO
My C0 !ua3i0N EXPIRES MARCH 5, 2001
Client # 929
828
Balance as of: Payment Due Minimum Payment
Account Number 03/15/2005 Date Payment Enclosed
945 Past D
4479412i?'
,
Make checks payable to:
Un'rfund
UNIFUND STATEMENT
Richard K Husler
Lot 91
90 Springers Ln
New Cumberland PA 17070-2441
MESSAGE FROM UNIFUND
Your account is past due $1233.45. The past due amount is included in the minimum
payment. Please remit immediately. If you have already sent payment for the above
amount, thank you.
This account is currently beg Grviced by:
C
Gordon & Weinberg P
,
21 S. 21 st St
Philadelphia PA 19103
TRANSACTIONS:
Date ransacton aan?e ue ayments Bal nce
03/15/2005 Unifund Purchased The $1233.45 $1233.45 $0 $1233.45
Above Referenced account
from Providian National Bank
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 requires us to
inform you that this is an attempt to collect a debt and any information
obtained 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 thereof, this office will assume this debt is valid. if you
notify this office in writing within 30 days from receiving this notice that
we will obtain verification of the
uted
tio
thereof is dis
th
d
bt
,
p
or any por
n
e
e
debt or a copy of a udgment and we will mail you a copy, of such
ou request this office in wnng within
ou
If
or jud
meni to
erificatio
g
y
.
y
v
n
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.
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2017803
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
484/351-0500
UNIFUND CCR PARTNERS ASSIGNEE
OF PROVIDIAN NATIONAL BANK
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
VS.
RICHARD K HUSLER
90 SPRINGERS LN LOT 91
NEW CUMBERLAND PA 17070
DOCKET NO. : 05-2388 CIVIL
PRAECIPE TO REINSTATE COMPLAINT
TO THE PROTHONOTARY:
Kindly reinstate the Plaintiffs.' Complaint in Civil Action
in the above-captioned matter for an additional thirty (30) days.
GORDON & WEINBERG, P.C.
BY:
FREDERIC INBERG, ESQUIRE
JOEL M. FLINK, ESQUIRE
Attorney for Plaintiff(s)
Balance as of: Payment Due Minimum Payment
Account Number 0311512005 Date Payment Enclosed
hblo dMOMs pgli?b ta:
unftw
UNIFUND STATEMENT
David Acosta
4657 Edmund St
Philadelphia PA 191243409
MESSAGE FROM UNIFUND
Your account is past due $1252.74. T mthank due amount is included in the minhnum
payment. Please remit Immediately.l ave already sent payment for the above
amou you.
This account on WernbberyP C?i? by:
21 S. 21st St
Philadelphia PA 19103
I Transaction a ante ue L- Psymerft J1 Balance
03/158005 Unifund Purchased The $1282.74 $1262.74 $0 .. $1262.74
Above Referenced account
from Providian National Hank
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 43242
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 re Ldres us to
inform you that this Is an attempt to collsi t a debt and any information
obtained 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 there this office will assume this debt Is valid. If you
notify this office in writing within 30' days from rscehg this notice that
the debt or any portion thereof Is disputed, we wIN obtain Verification of the
debt or a copy of a judgment and we will mail you a copy of such
verification or judgment to you. p you request this office In wribnp within
30 days after receiving this notice, this office will provide you with the
name and address of -the original creditor, if dH%rent from the current
creditor.
a
2017803
THIS IS AN ARBITRATION MATTER:
ASSESSMENT OF DAMAGES HEARING REQUIRED.
GORDON & WEINBERG, P.C.
BY: FREDERIC I. WEINBERG, ESQUIRE,
Identification No.: 41360, 0 ? 0
PAUL M. SCHOFIELD, JR., ESQUIRE- r-:
81894 7,;_
Identification No.:
21 SOUTH 21ST STREET
PHILADELPHIA, PA 19103 u-!
215/988--9600 rr
r = ;. )
N
UNIFUND CCR PARTNERS ASSIGNEE COURT OF COMMON PLEAS uz
OF PROVIDIAN NATIONAL BANK CUMBERLAND COUNTY
10625 Techwoods Circle
Cincinnati, OH 45242
VS. DOCKET NO. : QS ac,6-Ts
RICHARD K HUSLER
90 SPRINGERS LN LOT 91
NEW CUMBERLAND PA 17070
99TICE
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
r
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 $1,022.32.
5. Plaintiff has made demand upon the defendant(s)for
payment of the balance due of $1,022.32 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
$1,022.32 at the rate of 6% from the date of May 11, 2001,
together with costs and attorney fees.
GORDON & WEINBERG, P.C.
BY:
FREDERIC BERG, ESQUIRE
PAUL M. CHO' ELD, JR., ESQUIRE
Attorn Y?'dr Plaintiff
P01h
A Ali` yW..
VERIFICATI
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.
FREDERI WF,,I BERG, ESQUIRE
EXHIBIT "A"
AFFIDAVIT OF INDEBTEDNESS
State of Ohio) a o
County of Hamilton ) ss.
Bharati Lengade 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 Richard K Husler, Account Number 4479412825204929, the amount of
$1233.45 (principal balance in the amount of $1022.32 plus interest up through 03/15/2005 in the amount
of $211.13). By the terms of the agreement between the defendant and the original creditor, interest is
accruing from the aforesaid date at the rate of 6.00 percent per annum. This balance reflects any payments,
credits or offsets made since the account was charged of
This account was originated with Providian National Bank Unifund CCR Partners purchased this account
from Providian National Bank, 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 of Unifund CCR Partners.
8"arch 15, 2005
LNWUND CR PARTNERS
By: Bharati Lengg„de
Media Supervisor
10625 Techwoods Circle Cincinnati OH 45242
A ress
Subscribed and sworn to before me this
. '` My commission Expires
PUBLIC
; . :. 1'. , :? ? ,?, ? OF OHIO
+?,r MY COMASSION EXPIRES MARCH 5, M7
Client # 829
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2017803
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
484/351-0500
UNIFUND CCR PARTNERS ASSIGNEE
OF PROVIDIAN NATIONAL BANK
VS.
RICHARD K HUSLER
90 SPRINGERS LN LOT 91
NEW CUMBERLAND PA 17070
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
DOCKET NO. : 05-2388 CIVIL
PRAECIPE TO REINSTATE COMPLAINT
TO THE PROTHONOTARY:
Kindly reinstate the Plaintiffs' Complaint in Civil Action
in the above-captioned matter for an additional thirty (30) days.
GORDON & WEINBERG, P.C.
BY:
FREDERIC I. EINBERG, ESQUIRE
JOEL M. FLINK, ESQUIRE
Attorney for Plaintiff(s)
d
V?
fi
.
Cam ?
,
r= c)
,
(David Z). Bueff
,prothonotar),
XirkS. SoFionage, Q
Soricitor
o<i
Renee K. Simpson
I" Deputy (Prothonotary
Irene E. Morrow
Zd- Deputy Trothonotary
Office of the Prothonotary
Cumberfand County, 1Tennsykania
n5- 2,78 U CIVIL TERM
ORDER OF TERMINATION OF COURT CASES
AND NOW THIS 25TH DAY OF OCTOBER, 2011, 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,
DAVID D. BUELL
PROTHONOTARY
One Courthouse Square 9 Suite 100 • CardsCe, Tq 17013 • (717 240-6195 • Fax (717 240-6573