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Home My WebLink About05-67422023175 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 CITIBANK 10625 Techwoods Circle Cincinnati, OH 45242 vs. MARY S SOKOLOSKI 38 CHESTNUT ST NEWVILLE PA 17241 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO NOTICE nS9 - /I 7yk (. -[u; - 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 OF, 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 I. 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)tae 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 $1,598.75. 5. Plaintiff has made demand upon the defendant(s)for payment of the balance due of $1,598.75 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 $1,598.75 at the rate of 24.74% from the date of February 4, 2002, together with costs and attorney fees. GORDON & WEINBERG, P.C. BY: FREDERIC I.k; ERG, ESQUIRE PAUL M. SCH I JR., ESQUIRE Attorney for Plaintiff 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. WEI G, ESQUIRE EXHIBIT "A" 829 202 3175 Balance as of: Payment Due Minimum Payment Account Number 10/26/2005 Date Payment Enclosed UNIFUND STATEMENT Mary S Sokoloski 38 Chestnut St Newville PA 17241-1331 MESSAGE FROM UNIFU14D Your account is past due $3035.63. 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. 10/26/2005 Citibank (South Dakota) Natforpl Association's account was issued under the name of Citibank. Unifund CCR Partners purchased this account from Citibank (South Dakota) National Association. $3035.63 $0 $3035.63 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. /v 1, ' 1 l -77 Ti 4- W SHERIFF'S RETURN - REGULAR CASE NO: 2005-06742 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND UNIFUND CCR PARTNERS VS SOKOLOSKI MARY S 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 SOKOLOSKI MARY S the DEFENDANT at 0953:00 HOURS, on the 4th day of January , 2006 at 38 CHESTNUT STREET NEWVILLE, PA 17241 MARY S SOKOLOSKI 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 18.00 Service 9.68 Affidavit .00 Surcharge 10.00 .00 37.68 Sworn and Subscribed to before me this Aq% day of ?trp A. D. Prot ary by handing to So Answers: R. Thomas Kline 01/06/2006 GORDON & WEINBERG 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 CITIBANK VS. MARY S SOKOLOSKI COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO 05-6742CIVIL PRAECIPE FOR JUDGMENT The Prothonotary will please enter Judgment in the above matter by default for want of an answer against the Defendant, MARY S SOKOLOSKI, and assesses the dam s as per statement below. FREDERIC I. WEIN E , ESQUIRE PAUL M. SCHOFIELD, JR., ESQUIRE Attorney for Plaintiff Principal $1,598.75 Interest from February 4, 2002 @24.74% $1,602.71 Total: $3,201.46 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 ys prior to the date of the filing of this Praecipe. FREDERIC I. WEINB^ , ESQUIRE PAUL M. SCHOFIELD, JR., ESQUIRE Attorney for Plaintiff Filed: By the Prothonotary: AND NOW, this ? day of /'Lao 2006 Judgment is entered in favor of the plaintiff(s) and against defendant, for want of an answer and damages assessed at the sum of , $3,201.46 as per the above certification. /I 1. -(/ Prothonot ry GORDON & WEINBERG, P.C. BY:. FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 PAUL M. SCHOFIELD, JR., ESQUIRE Identification No.: 81894 21 SOUTH 21ST STREET PHILADELPHIA, PA 19103 215/988-9600 UNIFUND CCR PARTNERS ASSIGNEE OF CITIBANK VS. MARY S SOKOLOSKI COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO 05-6742CIVIL CERTIFICATION OF ADDRESS I hereby certify that the precise residence of the holder of the within judgment is; UNIFUND CCR PARTNERS ASSIGNEEOF CITIBANK and that the last known address of defendant, MARY S SOKOLOSKI, 38 CHESTNUT ST, NEWVILLE PA 17241. GORDON & WEINBERG, P.C. BY: FREDERIC I PAUL M. SC Attorney f BERG, ESQUIRE D, JR.,ESQUIRE intiff GORDON & WEINBERG, P.C. BY:_ FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 PAUL M. SCHOFIELD, JR., ESQUIRE Identification No.: 81894 21 SOUTH 21ST STREET PHILADELPHIA, PA 19103 215/988-9600 UNIFUND CCR PARTNERS ASSIGNEE OF CITIBANK VS. MARY S SOKOLOSKI COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 03-6742CIVIL AFFIDAVIT OF NON-MILITARY SERVICE FREDERIC I. WEINBERG, ESQUIRE, being duly sworn according to law, deposes and says that he represents the plaintiff in the above- entitled case; that he is authorized to make this affidavit on behalf of the plaintiff; and that the above-named defendant is over twenty- one years of age; that the address of the defendant is, 38 CHESTNUT ST, NEWVILLE PA 17241; that the occupation of the defendant is unknown; and that the defendant is not in the Military Service of the United States, nor any State or Territory thereof or its allies as defined in the Soldiers' and Sailors' Civil Relief Act of 1940 and the amendments thereto. Sworn to and Subscribed r?? Before me this Day o??? ??{l?h? /72006. Notary Public COMMONWEALTH OF PENNSYLVANIA NOTARIAI, SEAL CHRISTINE M. COLON, Notary Public City of Philadelphia, Phila. County MyCnmmission Exqires_N4Y,,., rBlgk$, 12009 FREDERIC I. INB G, ESQUIRE PAUL M. SCHOFIELD, JR. ESQUIRE Attorney for Plaintiff 2023175 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 CITIBANK VS. MARY S SOKOLOSKI TO/PARA COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 05--6742CIVIL NOTICE OF INTENTION TO TAKE DEFAULT MARY S SOKOLOSKI 38 CHESTNUT ST NEWVILLE PA 17241 DATE OF NOTICE/FECHA DEL AVISO: February 7, 2006 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 GORDON & WEINBERG, P.C. BY: FREDERIC I WEINB RG, ESQUIRE PAUL M. Sj I, JR., ESQUIRE P10D-2 2023175 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 CITIBANK COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. MARY S SOKOLOSKI DOCKET NO NOTICE 05-6742CIVIL 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 $3,201.6, IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL GORDON & WEINBERG, P.C. AT 215/988-9600. GORDON & WEINBERG, F.C. D, JR.,ESQUIRE Attorney for Plaintiff BY: FREDERIC I. EL ERG, ESQUIRE PAUL M. ECHO EL Dated: February 22, 2006 ? ? ' ? ?? a _, _; -? ? .? ? ?-- ? 4 -? ?- 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 CITIBANK COURT OF COMMON PLEAS CUMBERLAND COUNTY VS. MARY S SOKOLOSKI 38 CHESTNUT ST NEWVILLE PA 17241 and Bank of America 100 Progress Dr Doylestown, PA 18901 GARNISHEE DOCKET NO. : 05-6742CIVIL BUCKS COUNTY DOCKET NO. : PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue writ of execution in the above matter, directed to the Sherif ucks County; ONLY GABNISflBE WILL -?_ BE SERVED (1) against MARY S SOKOLOSKI defendant(s)and (2) against Bank of America garnishee(s) (3) AMOUNT DUE $3,201.46 INTEREST from March 2, 2006 $493.65 COSTS Prothonotary fee TOTAL Z----Z? FREDERIC I. EI ERG, ESQUIRE JOEL M. FLINK, ESQUIRE Attorney for Plaintiff -6A- ra 44 O + - T WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 05-6742 Civil CIVIL ACTION - LAW TO THE SHERIFF OF BUCKS COUNTY: To satisfy the debt, interest and costs due UNIFUND CCR PARTNERS ASSIGNEE OF CITIBANK, Plaintiff (s) From MARY S. SOKOLOSKI, 38 Chestnut Street, Newville, PA 17241 (1) You are directed to levy upon the property of the defendant (s)and to sell (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: BANK OF AMERICA, 100 Progress Drive, Doylestown, PA 18901 and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof, (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $3,201.46 L.L. $.50 Interest from 3/02/06 - $493.65 Atty's Comm % Atty Paid $129.18 Plaintiff Paid Due Prothy $2.00 Other Costs Date: 10/14/08 (Seal) REQUESTING PARTY: Name FREDERIC E. WEINBERG, ESQUIRE Address: GORDON & WEINBERG, P.C. ?7'6h # -001 L?Z- g ".e ==Mwy C s R. Lo ro onotary By: Deputy 1001 E. HECTOR STREET, SUITE 220 CONSHOHOCKEN, PA 19428 Attorney for: PLAINTIFF Telephone: 484-351-0500 Supreme Court ID No. 41360 Unifund CCR Partners Plaintiff Vs. Mary Sokoloski Defendant and Bank of America Court of the Common Pleas Cumberland County No: 05-6742 Bank of America's Garnishee's Answers to Interrogatories 1. No. 2. No the defendant does not possess an account with Bank of America. 3. N.A. 4. N.A. 5. N.A. 6. N.A. 7. N.A. 8. N.A. 9. N.A. By: Date: t?Q Sarah DiLapi Northeast Legal Order Processing Bank of America (315) 738-5851 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 CITIBANK vs. MARY S SOKOLOSKI 38 CHESTNUT ST NEWVILLE PA 17241 and Bank of America 100 Progress Dr Doylestown, PA 18901 GARNISHEE COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 05-6742CIVIL BUCKS COUNTY DOCKET NO. : INTERROGATORIES IN ATTACHMENT TO: Bank of America - GARNISHEE You are required to file answers to the following Interrogatories within twenty (20) days after service upon you. Failure to do so my result in judgment against you. 1. At the time you were served or at any subsequent time did you owe the defendant(s) any money or were you liable to the defendant on any negotiable or other written instrument, or did the defendant claim that you owed the defendant any money or were liable to the defendant for anv reason? 2. At the time you were served or at any subsequent time was there in your possession, custody or control or in the joint possession, custody or control of yourself and one or more other persons any property of any nature owned solely or in part by the defendant. 3. At the time you were served or at any subsequent time did you hold legal title to any property of any nature owned solely or in part by the defendant or in which defendant held or claimed any interest. 4. At the time you were served or at any subsequent time did you hold as fiduciary any property in which the defendant(s) had an interest? 5. At any time before or after you were served did the defendant(s) transfer or deliver any property to you or to any person or place pursuant to your direction or consent and what was the consideration thereof? 6. At any time after you were served did you pay, transfer or deliver any money or property to the defendant(s) or to any person or place pursuant to his(her, their) direction or otherwise discharge any claim of the defendant(s) against you? 7. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the defendant have funds on deposit in an account in which funds are deposited electronically on a recurring basis and which are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law? If so, identify each account and state the reason for the exemption, the amount being withheld under each exemption and the entity electronically depositing those funds on a recurring basis. 8. If you are a bank or other financial institution, at the time you were served or any subsequent time did the defendant have funds on deposit in an account in which the funds on deposit, not including any otherwise exempt funds, did not exceed the amount of the general monetary exemption under 42 Pa.C.S. 98123? If so, identify each account. 9. How much is the value of any property in your possession belonging to the defendant(s)? <?Z? FREDERIC I. WEI BERG, ESQUIRE JOEL M. FLI , ESQUIRE Attorney for Plaintiff DATED: VERIFICATION I, Sarah DiLapi hereby verifies that I am an authorized representative of Bank of America; that the statements made in the foregoing Answers to Interrogatories are true and correct to the best of my knowledge, information and belief and that these statements are made subject to the penalties of 18 Pa. C.S. s4904, relating to unsworn falsification to authorities. 6 S i ature Position Date: , \ MV-)R i?`.s ? .g-y ?-.. ° :".} ,,,,. T ? t ?,) . ''f , ?' e ( N ? ? Y . _„ 4`? 2023175 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 CITIBANK VS. MARY S SOKOLOSKI and Bank of America Garnishee COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 05-6742CIVIL PRAECIPE TO DISSOLVE ATTACHMENT TO THE PROTHONOTARY: Kindly dissolve the attachment of the defendant's bank account with Bank of America, as Garnishee in the above entitled matter. GORDON & WEINBERG, P.C. BY: FREDERIC I. ERG, ESQUIRE JOEL M. FLINK, ESQUIRE Attorney for Plaintiff Poll r t Q7 p ? 0