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HomeMy WebLinkAbout05-44652020332 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 AMERICAN APPLIANCE 10625 Techwoods Circle Cincinnati, OH 45242 Vs. THOMAS E HORNBAKER 60 SHARON RD ENOLA PA 17025 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO 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 $2,093.16. 5. Plaintiff has made demand upon the defendant(s)for payment of the balance due of $2,093.16 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 $2,093.16 at the rate of 6% from the date of October 13, 2001, together with costs and attorney fees. GORDON & WEINBERG, P.C. BY: FREDERIC I. PAUL M. SCHO Attorney for ERg/,, ESQUIRE JR., ESQUIRE ntiff P01h 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. AE-PfqBERG, ESQUIRE EXHIBIT "A" 829 Balance as of: Payment Due Minimum Payment Account Number 07/11/2005 Date Payment Enclosed 0699-070883 $2497.91 1 Past Due .9 Make checks payable to: Unifund UNIFUND STATEMENT Thomas E Hombaker 60 Sharon Rd Enola PA 17025-1827 MESSAGE FROM UNIFUND Your account is past due $2497.91, 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. TRANSACTIONS: a e Transaction a ante ue aymen Balance 07/11/2005 Wells Fargo's account was $2497.91 $2497.91 $0 $2497.91 issued under the name of AMERICAN APPLIANCE. Unifund CCR Partners purchased this account from Wells Fargo. 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. a_ Z V ?t t1" t vt d W UU) F? tJ ?Sl h! SHERIFF'S RETURN - REGULAR CASE NO: 2005-04465 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND UNIFUND CCR PARTNERS VS HORNBAKER THOMAS E RICHARD SMITH Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon THOMAS E DEFENDANT the at 1640:00 HOURS, on the 9th day of September, 2005 at 60 SHARON RD ENOLA, PA 17025 THOMAS HORNBAKER by handing to a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 12.80 Affidavit .00 Surcharge 10.00 .00 40.80 Sworn and Subscribed to before me this day of ry L A.D. Pr of y So Answers: -40 R. Thomas Kline 09/12/2005 GORDON & WEINBE By: Deputy Sheriff Curtis R. Long Prothonotary office of the Protbonotarp Cutnberfanb Countp Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor S - 14 4'LS0 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) 240-6573 2020332 WE s GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 81894 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 UNIFUND CCR PARTNERS ASSIGNEE OF AMERICAN APPLIANCE VS. THOMAS E HORNBAKER COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 05-4465CIVIL SUGGESTION OF BANKRUPTCY OF DEFENDANT TO THE PROTHONOTARY: AND NOW, this March 9, 2009, it is suggested of record that Defendant, THOMAS E HORNBAKER, filed a petition in bankruptcy under Chapter 13 of the Bankruptcy Code on or about October 11, 2005, in the United States Bankruptcy Court for the Middle District of Pennsylvania, docket number bk-07553-MDF. Therefore, this matter should be stayed until further notice. GORDON & WEINBERG, P.C. BY: FREDERIC WEINBERG, ESQUIRE JOEL M. FLINK, ESQUIRE Attorney for Plaintiff C"S ---