HomeMy WebLinkAbout05-44662020151
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 CITI PLATINUM SELECT
10625 Techwoods Circle
Cincinnati, OH 45242
vs.
PHILIP V HOFFMAN
72 LADNOR LN
CARLISLE PA 17013
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
$13,239.33.
5. Plaintiff has made demand upon the defendant(s)for
payment of the balance due of $13,239.33 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
$13,239.33 at the rate of 5% from the date of August 30, 2002,
together with costs and attorney fees.
GORDON & WEINBERG, P.C.
BY:
FREDERIC I.
PAUL M. SCH
Attorney fo
NBZRG, ESQUIRE
JR., ESQUIRE
aintiff
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. IN RG, ESQUIRE
EXHIBIT "A"
Za Zo ?S I
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 Philip V Hoffman, Account Number 4059052011440917, the amount of
$14680.95 (principal balance in the amount of $13239.33 plus interest up through 06/27/2005 in the
amount of $1441.62). By the terms of the agreement between the defendant and the original creditor,
interest is accruing from the aforesaid date at the rate of 5.00 percent per annum. This balance reflects any
payments, credits or offsets made since the account was charged off.
Citibank (South Dakota) National Association's account was issued under the name of CITI PLATINUM
SELECT. Unifund CCR Partners purchased this account from Citibank (South Dakota) National
Association. Said account has been referred to 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.
D s 7 ne 27, 2005
CCR PARTNERS
By: Bharati Lenizade
Media Supervisor
10625 Techwoods Circle Cincinnati, OH 45242
Address
Subscribed and sworn to before me this 27 day of June, 2005
Year
Notary Public
My commission Expires
Client # 829
??????111J?y9? :A NGELA L. FRECKMAN
NOTARY PUBLIC
STATE OF OHIO
Comm. Expires
MARCH 05, 2007
829
Balance as of: Payment Due Minimum Payment
Account Number 06/27/2005 Date Payment Enclosed
4059052011440917 $14680.95 Past Due $14680.95 1$
VaW checks payable to:
Unifmd
UNIFUND STATEMENT
Philip V Hoffman
72 Ladnor Ln
Carlisle PA 17013-9215
MESSAGE FROM UNIFUND
Your account is past due $14680,95, 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:
Date Transaction aance ue ayments Balance
06/27/2005 Citibank (South Dakota) Nationlid4680.95 $14680.95 $0 $14680.95
Association's account was issued
under the name of CITI
PLATINUM SELECT. Unifund
CCR Partners purchased this
account from Citibank (South
Dakota) National Association.
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.
7J- V r?
t* (R to
cjlz
SHERIFF'S RETURN - REGULAR
CASE NO: 2005-04466 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
UNIFUND CCR PARTNERS
VS
HOFFMAN PHILIP V
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
HOFFMAN PHILLIP V the
DEFENDANT
at 72 LADNOR LN
, at 1421:00 HOURS, on the 7th day of September, 2005
CARLISLE, PA 17013
PHILIP HOFFMAN
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 4.00
Affidavit .00
Surcharge 10.00
.00
32.00
Sworn and Subscribed to before
me this day of
V
Pr o ar
So Answers:
R. Thomas Kline
09/09/2005
GORDON & WEINBE G
By:
Deputy Sheriff
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
CITI PLATINUM SELECT
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
VS.
PHILIP V HOFFMAN
DOCKET NO. : 05-4466 CIVIL
PRAECIPE FOR JUDGMENT
The Prothonotary will please enter Judgment in the above matter
by default for want of an answer against the Defendant, PHILIP V
HOFFMAN, and assesses the damages as per statement below.
FREDERIC I. IN RG, ESQUIRE
PAUL M. SCH F D, JR., ESQUIRE
Attorney for Plaintiff
Principal $13,239.33
Interest from August 30, 2002
Q5% $2,076.58
Total: $15,315.91
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. ??2
FREDERIC I. ERG, ESQUIRE
PAUL M. SCHOFIELD, JR., ESQUIRE
Attorney for Plaintiff
Filed:
By the Prothonotary: /?\ r
AND NOW, this ?2C- day of /(?/1r)PrvihFO 2005 Judgment
is entered in favor of the plaintiff(s) and against defendant, for
want of an answer and damages assessed at the s m of , $15,315.91 as
per the above certification.
Prothon tary
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
CITI PLATINUM SELECT
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
Vs.
PHILIP V HOFFMAN
DOCKET NO. : 05-4466 CIVIL
CERTIFICATION OF ADDRESS
I hereby certify that the precise residence of the holder of the
within judgment is; UNIFUND CCR PARTNERS ASSIGNEEOF CITI PLATINUM
SELECT and that the last known address of defendant, PHILIP V
HOFFMAN, 72 LADNOR LN, CARLISLE PA 17013.
GORDON & WEINBERG, P.C.
BY:
FREDERI I. INBERG, ESQUIRE
PAUL M. SCHOFIELD, JR.,ESQUIRE
Attorney for Plaintiff
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
CITI PLATINUM SELECT
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
VS.
PHILIP V HOFFMAN
DOCKET NO. : 05-4466 CIVIL
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, 72 LADNOR LN,
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 2?- Day
of OttU<-- 2005.
h AA ,Ib 1M P
Notary Public
NOTAPoAL SEAL
CHRISTINE MARSHALL, Notary Public '
Wayne, che" County
Canth" Ex M 0** 24, 2005
FREDERIC I.(_W-Fai ERG, ESQUIRE
PAUL M. SCHOFIELD, JR. ESQUIRE
Attorney for Plaintiff
2020151
GORDON & WEINBERG, P.C.
BY: FREDERIC I. WEINBERG, ESQUIRE
Identification No.: 91360
PAUL M. SCHOFIELD, JR., ESQUIRE
Identification No.: 81899
21 SOUTH 21ST STREET
PHILADELPHIA, PA 19103
215/988-9600
UNIFUND CCR PARTNERS ASSIGNEE OF
CITI PLATINUM SELECT
VS.
PHILIP V HOFFMAN
TO/PARA
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
DOCKET NO. : 05-9966 CIVIL
NOTICE OF INTENTION TO TAKE DEFAULT
PHILIP V HOFFMAN
72 LADNOR LN
CARLISLE PA 17013
DATE OF NOTICE/FECHA DEL AVISO: October 6, 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) 299-3166
GORDON & WEINBERG, P.C.
BY:
FREDERIC NBERG, ESQUIRE
PAUL M. SCHOFIELD, JR., ESQUIRE
PLOD-2
G
(? 91, VA
7
d
2020151
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
CITI PLATINUM SELECT
vs.
PHILIP V HOFFMAN
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
DOCKET NO. : 05-4466 CIVIL
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 $15,315.91. IF YOU HAVE
ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL GORDON & WEINBERG,
P.C. AT 215/988-9600.
GORDON & WEINBERG, P.C.
BY:
FREDERI I. WE BERG, ESQUIRE
PAUL M. ?UGFi IELD, JR., ESQUIRE
Attorney for Plaintiff
Dated: October 18, 2005
2020151
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 CITI PLATINUM SELECT
VS.
PHILIP V HOFFMAN
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
DOCKET NO. : 05-4466 CIVIL
ORDER TO SATISFY JUDGMENT
TO THE PROTHONOTARY:
Kindly mark the judgment entered November 3, 2005 in the
above-captioned matter satisfied upon payment of your costs only.
GORDON & WEINBERG, P.C.
BY:
FREDERIC I. EI ERG, ESQUIRE
JOEL M. FLINI, ESQUIRE
Attorney for Plaintiff
P005
r?.a
?Rn{?; ?
n°?: ?-?-
?; r
n?
??
x
_ rti,a :?
'
^•9w. k
??1
+. ?_ ??. a
•?-