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Home My WebLink About05-3937 BURTON NEIL & ASSOCIATES, P .C. By: Burton Neil, Esquire Identification No. 11348 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS WORLDWIDE ASSET PURCHASING, LLC 9911 Covington Cross Dr Las Vegas NY 89144 Plaintiff v. RICHARD NEIL 1065 Myerstown Road, Gardners PA 17324-9037 Defendant CUMBERLAND COUNTY, PENNSYLVANIA NO. OS - 3Q],7 c,'ulL~82...~ : CIVIL ACTION - LAW COMPLAINT 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 (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 claim set forth against you. You are warned that if you fail to do so, the case may proceed without you and a judgment 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. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAYBE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERENCE AND INFORMATION SERVICE Cumberland County Bar Assoc. 32 South Bedford Street Carlisle, PAl 7013 Telephone No. 717-249-3166 or 800-990-9108 61306 BURTON NEIL & ASSOCIATES, P.C. By: Burton Neil, Esquire Identification No. 11348 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 Attorney for Plaintiff WORLDWIDE ASSET PURCHASING,LLC 9911 Covington Cross Dr Las Vegas 89144 IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. NO. O~ - 3Q3'1 CIf..>iL /VL"l RICHARD NEIL 1 065 Myerstown Road, Gardners, P A Defendant : CIVIL ACTION - LAW Complaint I. The plaintiff is Worldwide Asset Purchasing, LLC , a business corporation, with place of business located at 9911 Covington Cross Dr, Las Vegas. 2. The defendant is Richard Neil, who resides at 1065 Myerstown Road, Gardners, Cumberland County, Pennsylvania. 3. At the defendant's request, Direct Merchants Credit furnished consumer credit to defendant bearing account number 5458004572013306 hereinafter referred to as the credit card account. 4. The defendant accepted the credit card account by making purchases, balance transfers and/or cash advances. 5. Monthly statements were sent to defendant each month which detailed the charges and credits made to the credit card account for the prior month. 6. The balance due on the credit card account is $10,081.09. 7. Defendant did not pay the balance due on the credit card account in full upon receipt of the monthly billing statements and also did not make the required minimum monthly payment set forth in the monthly billing statement. As such, defendant is in default on the credit card account. 8. Plaintiff purchased the defendant's account from Direct Merchants Credit and is now the holder and owner of the account. 9. Although demand has been made by plaintiff upon defendant to pay the sum of$1O,081.09, the defendant failed and refused to pay all or any part thereof. Wherefore, plaintiff demands judgment against the defendant in the sum of $10,081.09 and the costs of this action. BURTON NEIL &'f,.SSOCIATES, P.C. / .-' By: .... l "" Burton Neil, Esquire \ Attorney for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. Verification Chanel Soares is Attorney Relationship Manager for WORLDWIDE ASSET PURCHASING,LLC, the within Plaintiff, and makes this statement on its behalf as to the truthfulness of the facts set forth in the foregoing Complaint subject to the penalties of 18 Pa. Date: C.S. Section 4904, relating to unsworn falsification to authorities. Y)~6') , \ Richard Neil 5458004572013306 N (J ~ It- ~ if? .vt ..... ":::::. ~ ()'- ..0 p:! ~ 6' cY ~ - t: ~ -..(, ~,' ;:'; C) 8 ,~, --n :T1 ) ;<'i-r<, I f'\.) .,',", , C:) ",] \... -< WORLDWIDE ASSET PURCHASING, LLC 9911 Covington Cross Dr, Las Vegas 89144 Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 2005-03937 P RICHARD NEIL 1065 Myerstown Road Gardners PA 17324-9037 Defendant : CIVIL ACTION - LAW Praecipe for Default Judgment To the Prothonotary: Please enter judgment by default for want of an answer in the above case in favor of the plaintiff and against the defendant, and assess damages as follows: Principal: $10,081.09 TOTAL $10,081.09 Understanding that false statements herein made are subject to penalty under 18 Pa. C.S. S 4904 relating to unsworn falsification to authorities, I verifY that: I. The above are the precise last-known addresses ofthe judgment debtor and creditor. 2. The annexed notice of intention to file this praecipe was mailed to all parties against whom judgment is to be entered and to their record attorneys, if any, after the default occurred. and at least ten days prior to the date of the filing of this praecipe. 3. Pursuant to Section 201 (b)( 1 )(A) ofthe Servicemembers Civil Relief Act of2003 (SCRA), the defendant is not in the military service of the United States based on information received from the defendant and/or the Department of Defense website. :~R:~N~6'TES '.C. Burton Neil, Esquire Attorney for Plaintiff J.D. #11348 1060 Andrew Drive, Suite 170 W. Chester, PA 19380 JUDGMENT BY DEFAULT ENTERED AND DAMAGES ASSESSED AS ABOVE. NOTIC GIVEN UND PA.R.CIV.P.236 The law firm of Burton Neil & Associates is a debt collector. 61306 11111111111111111111111111111111111 11111111111111111111111111111111111111111111111111111111111111I11I111111111I11111111111111 61306 WORLDWIDE ASSET PURCHASING,LLC IN THE COURT OF COMMON PLEAS Plaintiff vs. CUMBERLAND COUNTY, PENNSYLV ANlA : NO. 2005-03937 P RICHARD NEIL Defendant : CIVIL ACTION - LAW Notice of Intention to File Praecipe for Default Judgment TO: Richard Neil 1065 MyerstownRoad Gardners PA 17324-9037 IMPORTANT NOTICE You are in default because you have failed to enter a written appearance personally or by attorney and file in writing with the court your defenses or obligations to the claims set forth against you. Unless you act within ten (10) 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 notice to your lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help. This office can provide you with infonnation about hiring a lawyer. If you cannot afford to hire a lawyer, this office may be able to provide you with infonnation about agencies that may offer legal services to eligible persons at a reduced fee or no fee. LAWYER REFERENCE AND INFORMATION SERVICE Cumberland County Bar Assoc. 32 South Bedford Street Carlisle, PA 17013 Telephone No, 717-249-3166 or 800-990; In making this communication, we advise our office is a debt collector. BURTONN &ASSOCIATES,P.C. --~ By: l/ Burton Neil, Es ire Attorney for Plaintiff Identification No. 11348 1060 Andrew Drive, Suite 170 WestChester, PA 19380 (610) 696-2120 DATE OF NOTICE: September 13,2005 1IIIIlIWBlnlllUllW 1IIIMllmIR~lm~.IWIIIIIIIIIIWHIIII.lm II. r:;:. ~ ~ 1- ~ ....a 0 - - ~ ~ - ..J:: () ~ 0 I;~ = -0 ~ ~ F 'cc cf' (/~J .--\ f' :1;-,-, ~ -0 " c; n'f::'::: )v E ,-", =gt:~~ \U ~ 0 '-;3/) ~ C> J ".,-t", r ::? .;"~ -t,! ._> t-', (;, r;,? (~'5rh '."1 r ;.::"l ..~? N ~.L: ~- N -< BURTON NEIL & ASSOCIATES, P.C. BY: Burton Neil, Esquire Identification No. 11348 1060 Andrew Drive, Suite 170 West Chester. PAl 93 80 610-696-2120 A TTORNEY FOR: Plaintiff WORLDWIDE ASSET PURCHASING, LLC Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL Y ANIA YS. NO. 2005-03937 P RICHARD NEIL Defendant : CIVIL ACTION - LA W RULE OF CIVIL PROCEDURE NO. 236 (REVISED) Notice is given that a JUDGMENT in the above captioned matter has been entered against you on ~ € r-r+- _ < (') d../bS I I ry By: If you have any questions concerning the above, please contact: Burton Neil, Esquire Attorney for Party Filing 1060 Andrew Drive, Suite 170 West Chester, P A 19380 Phone: 610-696-2120 The law firm of Burton Neil & Associates is a debt collector. SHERIFF'S RETURN - REGULAR CASE NO: 2005-03937 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WORLDWIDE ASSET PURCHASING LLC VS NEIL RICHARD DAVID MCKINNEY , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon NEIL RICHARD the DEFENDANT , at 1950:00 HOURS, on the 19th day of Auqust , 2005 at 1065 MYERSTOWN ROAD GARDNERS, PA 17324-9037 by handing to JULIE NEIL, WIFE 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 Postage Surcharge So Answers: 18.00 8.80 .37 10.00 .00 37.17 __,..",-t-/."f;/ /~ ,-r ~~';~-9'?"'~~"t:'/~ R. Thomas Kline 08/22/2005 BURTON NEIL Sworn and Subscribed to before By: 1/ &t '/1~W/ Deputy Sherif me this A.D. day of S'