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Home My WebLink About06-0378 2021779 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 FIRST USA BANK 10625 Techwoods Circle Cincinnati, OH 45242 COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. DOCKET NO. :Ol..,-.3~P /J ./~". CiUll /fk_~ DARLEE D ANSEL 65 SILVER CROWN DR MECHANICSBURG PA 17050 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 ANO A JUDGEMENT MAY BE ENTERED AGAINST YOU BY THE COURT WITHOUT FURTHER NOTICE FOR ANY MCNEY 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 YCU. 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 T~E 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 merchandise 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 $2,229.33. 5. Plaintiff has made demand upon the defendant(s) for payment of the balance due of $2,229.33 but the defendant (s)has failed and refused and still refuses to pay the same or any part thereof. WHEREFORE, plaintiff claims of the defendan~(s) the sum of $2,229.33 at the rate of 21.24% from the date of February 1, 2002, together with costs and attorney fees. GORDON & WEINBERG, P.C. BY: FREDERIC I~~' ESQUIRE PAUL M. SCHOFIELD, JR., ESQUIRE Attorney for Plaintiff POlh VERIFICATION FREDERIC I. WEINBERG, ESQUIRE, herety 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~::: ESQUIRE EXHIBIT "An '2D2XllQ AFFIDAVIT OF INDEBTEDNESS State of Ohio) County ofRamilton ) ss. Kim Kenney being sworn, deposes and says that she is Media Supervisor ofUnifund 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 Darlee D Ansel, Account Number 5417122442395404, the amount of $4066.93 (principal balance in the amount of $2229.33 plus interest up through 09/02/2005 in the amount of$1837.60). By the terms of the agreement between the defendant and the original creditor, interest is accruing from the aforesaid date at the rate of21.24 percent per annum. This balance reflects any payments, credits or offsets made since the account was charged off. Bank One Delaware NA's account was issued under the name of FIRST USA BANK. Unifund CCR Partners purchased this account from Bank One Delaware NA. 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. DATED this September 2, 2005 ~RPARTNERS By: Kim Kennev Media Supervisor 10625 Techwoods Circle Cincinnati. OR 45242 Address Subscribed and sworn to before me this ~ day of September, 2005 Year ~~bliC My commission Expires Client # 829 \\\\\\\illlll!/II \\\. I" II; -,,\ -( f.."R ~'\L ~ 1// ., 0\ "" "'. "/.' /. .,....":-.. .....\ '//"::<''''! /--/~ i~, ~~ ,~t '/~,:Allt: ""_"" ,:,...\0 ,,~' 'II'" 0'1- QT' \,\ II/!/II!/I\i\\\'\\\\ CHERYL COLE NOTARY PUBLIC STATE OF OHIO Comm. Expires July 19, 201 0 707111 Balance as of: Payment Due Minimum Payment Account Number 09/0212005 Date Payment Enclosed I 5417122442395404 I $4066.93 I Past Due I $4066.93 1$ I Make checks payable to: Unifund UNIFUND STATEMENT Darlee D Ansel 65 Silver Crown Dr Mechanicsburg PA 17050-1638 MESSAGE FROM UNIFUND Your account is past due $4066.93. 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: I Date II Transaction II Balance II Due IL Payments II New I Balance 09/0212005 Bank One Delaware NA's $4066.93 $4066.93 $0 $4066.93 account was issued under the name of FIRST USA BANK. Un/fund CCR Partners purchased this account from Bank One Delaware NA. 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. q 829 ~ -4q. 8 ;;v lf1 U\ t- tn - ~ \J '> :~1 c_ -. ~ ~ " 4 . -'> )v ..- ltJ W l..-,...~, - -,' - ~ . II'; - . . \.... .r'- ::.<.: SHERIFF'S RETURN - REGULAR CASE NO: 2006-00378 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND UNIFUND CCR PARTNERS VS ANSEL DARLEE D SHARON LANTZ Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon the ANSEL DARLEE D DEFENDANT , at 1210:00 HOURS, on the 23rd day of January 2006 at 65 SILVER CROWN DRIVE MECHANICSBURG, PA 17050 DEBORAH WEARY, DAUGHTER by handing to 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 Service Affidavit Surcharge 18.00 8.80 .00 10.00 .00 36.80 Sworn and Subscribed to before me this .... ).l,~ day of \ A.D. y So Answers: .rgk;'~;;,t"':: ~~J R. Thomas Kline 01/24/2006 GORDON & WEINBERG BY:~ .{ ..1/ / eputy , 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 FIRST USA BANK COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. DOCKET NO. C 6- 3 7 8CIVIL DARLEE D ANSEL PRAECIPE FOR JUDGMENT The Prothonotary will please enter Judgment in the above matter by default for want of an answer against the Defenda~t, DARLEE D ANSEL, and assesses the damages as per statement below. FREDERIC I. WEI PAUL M. SCHOFIE Attorney for Plaintiff Principal Interest from February 1, 2002 @21.24% Total: $2,229.33 $1,930.36 $4,159.69 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. ESQUIRE Filed: By the Prothonotary: AND NOW, this f~ day of (YJ';::uJ c h , 2005 Judgment is entered in favor of the plaintiff(s) and against defendant, for want of an answer and damages assessed at the sum of , $4,159.69 as per the above certification. Protho . I 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 FIRST USA BANK vs. DARLEE D ANSEL COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. 06- 37 8CIVIL CERTIFICATION OF ADDRESS I hereby certify that the precise residence of the holder of the within judgment is; UNIFUND CCR PARTNERS ASSIGNEEOF FIRST USA BANK SILVER CROWN DR, MECHANICSBURG PA 17050. and that the last known address of defendant, DARLEE D ANSEL, 65 GORDON & WEINBERG, P.C. BY: FREDERIC PAUL M. S Attorney < 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 FIRST USA BANK COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. DOCKET NO. 06- 37 8CIVIL DARLEE D ANSEL 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 af=idavit 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, 65 SILVER CROWN DR, MECHANICSBURG PA 17050; 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 d Before me this / Day , ot~A , 20~6. {~{'J4~<!~.a~ Notary Public CO'MMONWEAL"TH OF' PENNS1fLVANI.A NOTARIAL SEAL CHRISTINE M. COL6N, Notary PubliC City of Philadelphia. Phila County 009 .' "November 18. 2 FREDERIC I. WE NBE ,ESQUIRE PAUL M. SCHOFIE , JR. ESQUIRE Attorney for Plaintiff 2021779 GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, Identification No.: PAUL M. SCHOFIELD, JR., Identification No.: 21 SOUTH 21ST STREET PHILADELPHIA, PA 19103 215/988-9600 ESQUIRE 41360 ESQUIRE 81894 UNIFUND CCR PARTNERS ASSIGNEE OF FIRST USA BANK COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. DOCKET NO. 06-378CIVIL DARLEE D ANSEL NOTICE OF INTENTION TO TAKE DEFAULT TO/PARA DARLEE D ANSEL 65 SILVER CROWN DR MECHANICSBURG PA 17050 DATE OF NOTICE/FECHA DEL AVISO: February 15, 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. FREDERIC I. PAUL M. SCH , ESQUIRE JR., ESQUIRE BY: P10D-2 t 70 X --'4- -4J t=- :It:- \) S \) - - -~ ~ \"' . . ?V ?-- \ ~ ~ ~ co: t- ~ ...c: ~ R:: ---. .. -:-",,) ~ c,' - 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 2021779 UNIFUND CCR PARTNERS ASSIGNEE OF FIRST USA BANK COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. DARLEE D ANSEL NOTICE DOCKET NO. 06-378CIVIL 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 $4,159.69. IF YOU HAVE P.C. AT 215/988-9600. ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL GOFDON & WEINBERG, GORDON & WEINBERG, F.C. BY: Dated: February 28, 2006 ~ G, ESQUIRE JR. ,ESQUIRE ntiff