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Home My WebLink About05-2422 2017779 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, OR 45242 COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. DOCKET NO. 05--<1/;),2... Civil IEfL~ KAREN M SHUGHART 143 CEDAR ST CARLISLE PA 17013 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 nAn. 4. All the credits to which the defendant(s)is entitled have been applied and there remains a balance due in the amount of $1,667.16. 5. Plaintiff has made demand upon the defendant(s)for payment of the balance due of $1,667.l6 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 $1,667.16 at the rate of 6% from the date of May 14, 2001, together with costs and attorney fees. GORDON & WEINBERG, P.C. BY: POlh FREDERIC I. PAUL M. SC Attorney for EJNBERG, ESQUIRE lELD, JR., ESQUIRE Plaintiff 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 ERG, ESQUIRE EXHIBIT "An AFFIDAVIT OF INDEBTEDNESS State of Ohio) County of Hamilton ) ss. Bharati Lengade 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. do\T-l- l q The defendant is not in any branch of the military, There is due and payable from Karen M Shughart, Account Number 4559501300465493, the amount of $2051.05 (principal balance in the amount of$1667,16 plus interest up through 03/15/2005 in the amount of$383,89), By the tenns of the agreement between the defendant and the original creditor, interest is accruing from the aforesaid date at the rate of6.00 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 perfonn all acts necessary for the collection, settlement, adjustment, compromise or satisfaction of said claim, on behalf ofUnifund CCR Partners, ~~-"._-----:-> D~DthisMarch 15, 2005 ~.~=77 '," '" ",-1 UNIFUND CCR PARTNERS By: Bharati Lengade Media Supervisor 10625 Techwoods Circle Cincinnati. OH 45242 Address , Subscribed and sworn to before this 12 day of March. 2005 Year Notary Public My commission Expires Client # 829 /<:~:~~'3.\:~;",~,.>" f ~". ! ',,>'0 \ f · t~::_' :<~ .?~~,._. \ - '\ ""' -,,-OJ> ~t* ~. \:: \.. :: ~l' ;/ -1, ~........"",,"~ ~ ~"":~,7.:~~~:>~ A'.r", '~:j_,:./ ,A I -.t.rl, L''''' -, i4dC":"q_~ ~ "', """ .... ..1('. ~;11 \' " I'dY'-r . .' -~ r/, '<. "\ J) /Vn7"1", lll.'I~~: "('~, '! f;r ..' I 1-' ~ . "it1 )lPI :"'/ 'ffU....0 - tl" -, /,'"'- 1"\ v, Iv I): ", I,: 0- -~~IC. , .P/i1E" t' v{- OHIO 0,) I 'lARCH S. ,2007 .8'29 Account Number I 4559501300465493 I Balance as of: Payment Due 03/15/2005 Date $'051 05 I P~s1 Dlle I Minimum Payment $'051 05 Payment Enclosed 1$ Make checks payable to: Unifund UNIFUND STATEMENT Karen M Shughart PO Box 567 Carlisle PA 17013-0567 MESSAGE FROM UNIFUND Your account is past due $2051.05. 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 beinlt serviced by: Gordon & Wembern'P.C. 21 S. 21st $I Philadelphia PA 19103 TRANSACTIONS: Date II Transaction II Balance $2051,05 II Due $2051,05 II Payments \I Ba~;;ce I $0 $2051,05 03/1512005 Unifund Purchased The 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 reCl.uires us to inform you that this is an attempt to collect a debt and any Information obtaineCl 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 the debt or any portion thereof is disJ1uted, we will obtain verification of the debt or a cOJ1Y of a judgment anCl we will mail you a COJ1Y of such verification or judgment to you. If you request this office in writing within 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. 7d (::I ~ it ~ 0 - --0 C> C) "" G 6"- V) r-' c::.) () ;;'::.::;' C..M " W ....::r -< --0 ~ -' tT:::!J L.J -.: ~ ,'" ~ C-J p::: 1 ) $ ::- :'i"J _.-'-. 1...) CJ ,""I --.-; .......' - -.J SHERIFF'S RETURN - REGULAR CASE NO: 2005-02422 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND UNIFUND CCR PARTNERS VS SHUGHART KAREN M GERALD WORTHINGTON , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon SHUGHART KAREN M the DEFENDANT at 1445:00 HOURS, on the 13th day of May at 143 CEDAR STREET 2005 CARLISLE, PA 17013 by handing to KAREN M SHUGHART 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 3.70 .00 10.00 .00 31.70 -~-' ";if'" /~ i;P'" ;~~2:;p".r/:.?~~~>.~ ~-J' R. Thomas Kline 05/16/2005 GORDON & WEINBERG Sworn and Subscribed to before me this ItS- day of BY:~/~~ Deputy She ff '71~, .J.tJo{ " A . D . Lh;-" (J. 1hn7t1I(,~Aqr.7f 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 PROVIDIAN NATIONAL BANK COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. DOCKET NO. 05-2422 CIVIL KAREN M SHUGHART PRAECIPE FOR JUDGMENT The Prothonotary will please enter Judgment in the above matter by default for want of an answer against the Defendant, KAREN M SHUGHART, and assesses the damages as per stat ent below. QUIRE ESQUIRE FREDERIC I. WEINBERG, "E PAUL M. SCHOFIELD~'./, Attorney for Pla~j~f Principal Interest from May 14, 2001 @6% Total: $1,667.16 $792.78 $2,459.94 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) d~ prior to the date of the filing of this Praecipe. ~---~,'\ ,-'" FREDERIC I. WEINBE ,~QUIRE PAUL M. SCHOFIELD ., ESQUIRE Attorney for Plaintiff Filed: By the Prothonotary: AND NOW, this ~D~ day of J/A-< )~ , 2005 Judgment is entered in favor of the plaintiff(s) and against defendant, for want of an answer and damages assessed at the sum of , $2,459.94 as per the above certification. 1'7 , ~ L:../A/J---tw ,j) ~ 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 PROVIDIAN NATIONAL BANK COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. KAREN M SHUGHART DOCKET NO. 05-2422 CIVIL CERTIFICATION OF ADDRESS I hereby certify that the precise residence of the holder of the within judgment is; UNIFUND CCR PARTNERS ASSIGNEEOF PROVIDIAN NATIONAL BANK and that the last k:nown address of defendant, KAREN M SHUGHART, 143 CEDAR ST, CARLISLE PA 17013. GORDON & WEINBERG, P.C. BY: ~ 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 COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. DOCKET NO. 05-2422 CIVIL KAREN M SHUGHART 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, 143 CEDAR ST, CARLISLE PA 17013; 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 of 'KEALTH 01' PENr~5YLVANIA NOTARIAL SEAL J OHN V McBRIDE, III, Nolary Public City of Philadelphia, Phila County M COmmisSion Expires Augusl4, 2008 FREDERIC I. WEINBERG, ESQUIRE PAUL M. SCHO EL~, ESQUIRE Attorney for Plaintiff 2017779 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 UN I FUND CCR PARTNERS ASSIGNEE OF PROVIDIAN NATIONAL BANK COURT OF COMMON PLEAS CUMBERLAND COUNTY VB. DOCKET NO, 05-2422 CIVIL KAREN M SHUGHART NOTICE OF INTENTION TO TAKE DEFAULT TO/PARA KAREN M SHUGHART 143 CEDAR ST CARLISLE PA 17013 DATE OF NOTICE/FECHA DEL AVISO: June 3, 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 BY: FREDERIC I. PAUL M. SC 2017779 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 COURT OF COMMON PLEAS CUMBERLAND COUNTY VS, DOCKET NO. 05-2422 CIVIL KAREN M SHUGHART 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 $2,459.94. IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL GORDON & WEINBERG, P.C. AT 215/988-9600. GORDON & WEINBERG, P.C. BY: EI ERG, ESQUIRE LD, JR., ESQUIRE Plaintiff FREDERIC I. PAUL M. SCH Attorney for Dated: June 14, 2005 , t ~ ~ 7V 1 ..() ~ ...., ~ C) 0 c:::::l 0 C::! " C> " ~ "". '-- -t F - - -u C~: :Ill f"" C> ..,j::.- Plp -,-,IT1 (/) ~ p:: "" -DO .L:: a ~j;~: .3 <5 - 1- -0 -,.'"".'TJ flJ ~:" ~,J() ~,--)rn ~ (.,) _..::-1 -;.. C) :5:.1 ...- ,-<