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HomeMy WebLinkAbout06-0303r 2022561 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 10625 Techwoods Circle Cincinnati, OH 45242 UNIFUND CCR PARTNERS ASSIGNEE OF PROVIDIAN VS. CONNIE KNOSKY 309 WALNUT LN CARLISLE PA 17013 o?A- 303 aiv l 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 11 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 merchandise and/or accepted services or cash advances through the use of the credit card issued by the Plaintiff. 4. All the credits to which the defendant(s)is entitled have been applied and there remains a balance due in the amount of $1,518.97. 5. Plaintiff has made demand upon the defendant(s)for payment of the balance due of $1,518.97 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 $1,518.97 at the rate of 6% from the date of January 11, 2002, together with costs and attorney fees. GORDON & WEINBERG, P.C. RG, ESQUIRE JR., ESQUIRE Attorney for Plaintiff BY: FREDERIC I. EIN F PAUL M. SC OFI I JR., ESQUIRE 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. WE N , ESQUIRE U r s SHERIFF'S RETURN - NOT FOUND K CASE NO: 2006-00303 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND UNIFUND CCR PARTNERS VS KNOSKY CONNIE R. Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT KNOSKY CONNIE unable to locate Her in his bailiwick COMPLAINT & NOTICE but was He therefore returns the the within named DEFENDANT 309 WALNUT LANE . KNOSKY CONNIE NOT FOUND , as to CARLISLE, PA 17013 ALTHOUGH NUMEROUS ATTEMPTS WERE MADE WE WERE NOT ABLE TO FIND DEFENDANT AT GIVEN ADDRESS. Sheriff's Costs: So answer.:, Docketing 18.0 ?z y c=""' ^ Service 17.660 Not Found 5.00 R. Thomas Kline Surcharge 10.00 Sheriff of Cumberland County .00 50.60 GORDON & WEINBERG 02/10/2006 Sworn and subscribed to before me this 15'? day of eQ w a , /Z Z Pr,6tho Curtis R. Long Prothonotary office of the Vrotbonotarp Cumberianb Countp Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor 6(o -- 3C) 3 CVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 28TH DAY OF OCTOBER, 2009, 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