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Home My WebLink About05-4840BURTON 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 NV 89144 Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. CATHY L. SOUDERS 1 Mount Zion Road, Carlisle PA 17013 Defendant NO, C) S- - 41,P410 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 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. LAWYER REFERENCE AND INFORMATION SERVICE Cumberland County Bar Assoc. 32 South Bedford Street Carlisle, PA 17013 Telephone No. 717-249-3166 or 800-990-9108 64284 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 NV 89144 Plaintiff V. CATHY L SOUDERS I Mount Zion Road, Carlisle PA 17013 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. OS - gFYO cl,YLl" CIVIL ACTION - LAW Complaint The plaintiff is Worldwide Asset Purchasing LLC , a business corporation, with place of business located at 9911 Covington Cross Dr., Las Vegas NV. 2. The defendant is Cathy L Souders, who resides at 1 Mount Zion Road, Carlisle, Cumberland County, Pennsylvania. 3. At the defendant's request, Direct Merchants Bank furnished consumer credit to defendant bearing account number 5462812142031937 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 $11,560.36. 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 Bank 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 $11,560.36, the defendant failed and refused to pay all or any part thereof. Wherefore, plaintiff demands judgment against the defendant in the sum of $11,560.36 and the costs of this action. BURTON NVIL & ASSOCIATES, P.C. By: #i1, Esquire 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. C S,_?ection 4904, relating to unsworn falsification to authorities. Date: !] ? ? ?, u5 f snares Cathy L Souders 5462812142031937 w a cr% r? ;? OV) SHERIFF'S RETURN - REGULAR CASE NO: 2005-04840 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WORLDWIDE ASSET PURCHASING LLC VS SOUDERS CATHY L CHARD SMITH Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon SOUDERS CATHY L the DEFENDANT , at 1901:00 HOURS, on the 26th day of September, 2005 at 1 MOUNT ZION ROAD CARLISLE. PA 17 by handing to DENNIS ALBRIGHT. HUSBAND 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 4.80 Postage .37 Surcharge 10.00 .00 33.17 Sworn and Subscribed to before me this II day of v?1 U A.D. Prot o ar? So Answers: R. Thomas Kline 09/27/20 BURTON N By: WORLDWIDE ASSET PURCHASING LLC 9911 Covington Cross Dr., Las Vegas NV 89144 Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY. PENNSYLVANIA vs. CATHY L SOUDERS 1 Mount Zion Road Carlisle PA 17013 Defendant NO. 05-4840 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: $11,560.36 Credit: $ 2,300.00 TOTAL $9,260.36 Understanding that false statements herein made are subject to penalty under 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities, I verify that: 1. The above are the precise last-known addresses of the 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 20 1 (b)(1)(A) of the Servicemembers Civil Relief Act of 2003 (SCRA), the defendant is not in the military service of the United States based on information received3from the defendant and/or the Department of Defense website. JUDGMENT BY DEFAULT ENTERED AND DAMAGES ASSESSED AS ABOVE. NOTIC GIVEN UNIAR PA.R.CIV.P. 236 Pro rothonota The law firm of Burton Neil & Associates is a debt collector. BURTON X1E L & ASSOCIATES, P.C. BY: 1rto4C?Ie ,Esquire Attorney r Plaintiff I.D.#11 48 1060 A drew Drive, Suite 170 W. Chejter. PA 19380 64284 64284 WORLDWIDE ASSET PURCHASING LLC Plaintiff vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 05-4840 CATHY L SOUDERS Defendant CIVIL ACTION - LAW Notice of Intention to File Praecipe for Default Judgment TO: Cathy L Souders 1 Mount Zion Road Carlisle PA 17013 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 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. LAWYER REFERENCE AND INFORMATION SERVICE Cumberland County Bar Assoc. 32 South Bedford Street Carlisle, PA 17013 Telephone No. 717-249-3166 or 800-990-9108 DATE OF NOTICE: October 18, 2005 In making this communication, we advise our office is a debt collector. BURTON NE & ASSOCIATES, P.C. By: Bruton Nei , sq re i Attorney for Plaintiff / Identification No. 1 1 48 1060 Andrew Drive, uite 170 West Chester, PA 193 0 (610) 696-2120 111111111111111111111111 In 111111111111111 Ills 1111 IN III III IN 1 P n w V 74- "` ?i C.. YY` e M1? L} C.? r' C=' 1.7 `T{ -'1 1: - -n 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 : IN THE COURT OF COMMON PLEAS Plaintiff Vs. CATHY L SOUDERS CUMBERLAND COUNTY, PENNSYLVANIA NO. 05-4840 Defendant : CIVIL ACTION - LAW RULE OF CIVIL PROCEDURE NO. 236 (REVISED) Notice is given that a JUDGMENT in the above captioned matter has been entered against you on Prothonotary By: If you have any questions concerning the above, please conta t: Burton Neil, Esquire Attorney for Parry Filing 1060 Andrew Drive, Suite 170 West Chester, PA 19380 Phone: 610-696-2120 The law firm of Burton Neil & Associates is a debt collector. Burton Neil & Associates, P.C. By Burton Neil, Esquire ID. NO. 11348 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff WORLDWIDE ASSET PURCHASING LLC Plaintiff V. CATHY L SOUDERS Defendant IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 05-4840 CIVIL ACTION - LAW Praecipe to Satisfy Judgment To the Prothonotary: Mark the judgment Satisfied on payment of your costs only. Burton Neil & ssociates, P.C. By: urton il, Esquire Attorney or Plaintiff The law firm of Burton Neil & Associates is a debt collector. 64284 -. ^C11' C riles `Jt