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HomeMy WebLinkAbout06-1601 2024059 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 US BANK 10625 Techwoods Circle Cincinnati, OH 45242 COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. DOCKET NO. 01.:, - /G,0{ G0~~~ LYNNE M WOODS 724 N PITT ST CARLISLE FA 17013 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 Jl.FTER THIS COMPLAINT AND NOTICE ARE SERVED, BY ENTERING A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILING IN WRITING WITH THE COURT YOUF DEFENSES OF OBJE.CTIONS 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(sl 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 IIA'l. 4. All the credits to which the defendant(slis entitled have been applied and there remains a balance due in the amount of $4,418.17. 5. Flaintiff has made demand upon the defendant(s) for payment of the balance due of $4,418.17 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 $4,418.17 at the rate of 10% from the date of April 2, 2002, together with costs and attorney fees. GORDON & WEINBERG, F.C. BY: FREDERIC I. WEIN PAUL M. SCHOFI Attorney for P F01h , ESQUIRE J ., ESQUIRE iff VERIFICATION FREDERIC I. WEINBERG, ESQUIRE, hereby states that he is the attorney for the Flaintiff(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. EXHIBIT "Au ~~02L\C(-)Y AFFIDAVIT OF INDEBTEDNESS State of Ohio) County of Hamilton ) 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 Lynne M Woods, Account Number 4719211022483082, the amount of $5777.41 (principal balance in the amount of $44 I 8.17 plus interest up through 12/08/2005 in the amount of $1359,24). By the terms ofthe agreement between the defendant and the original creditor, interest is accruing from the aforesaid date at the rate of 10,00 percent per annum. This balance reflects any payments, credits or offsets made since the account was charged off US Bank National Association ND's account was issued under the name of US BANK Unifund CCR Partners purchased this account from US Bank National Association ND. Said account has been referred to Gordon & Weinberg PC. 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 December 8, 2005 ~ UNlFUND CCR PARTNERS By: Kim Kenney Media Supervisor 10625 Techwoods Circle Cincinnati, OH 45242 Address Subscribed and sworn to before me this ~ day of December, 2005 Year r\ . W lUl 0v'YV'i Notary Public My commission Expires Client # 829 ,\\\\\lllll//j/j/ ,'>' I "I ,.", ,,,-\1..AL .s "// c;" ~o\\ 1//:-<''1 %. ~:: :.,~" '0-~'.<' ~ ~~~~:~~~~ 1 ~;{;~~;I'I::':"". = ;./ '<:.'/;j~,:,~> .f ~/J'/;;;"':':\:':':...,:o ~ ///111 € OF 0'0\,\\'" Jltlilllll\\\\\\ KAREN WILLIAMS NOTARY PUBLIC STATE OF OHIO Comm, Expires July 19, 2010 Balance as of: Payment Due Minimum Payment Account Number 12/08/2005 Date Payment Enclosed I 4719211022483082 I $5777.41 I Past Due I $5777.41 1$ I Make checks payable 10: urnt'und UNIFUND STATEMENT Lynne M Woods 724 N Pitt 5t Carlisle PA 17013-1951 MESSAGE FROM UNIFUND Your account is past due $5777.41. 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 II Payments II New I Balance 12/08/2005 US Bank National Association $5777.41 $5777.41 $0 $5777.41 ND's account was issued under the name of US BANK, Unlfund CCR Partners purchased this account from US Bank National Association ND, 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 aller 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. L C 2- LJ C.sq 829' ~ -{g, 8 ;;cJ ~ it t ,..., 0 C1 C"':' '.,'.J " ~ C"~ ~-n -" ---- :c.. rllp --.{ :;:0 -ronl \'" -u r',' ~,'JO Uf ~ ~-' , CJ I,.-:~ (~) ...{ ~ -0 - :TJ '.:,) (") 0( Cv :.:r: .;:rn :e ~,) - c;? ---I :r_"" en "~J +- c::> :<. --.c.. .., 2024059 GORDO & WEINBERG, P.C. BY: REDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 PAUL M. SCHOFIELD, JR., ESQUIRE Identification No.: 81894 21 SO TH 21ST STREET PHIL DELPHIA, PA 19103 215/988-9600 UNIF OF U PARTNERS ASSIGNEE COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. DOCKET NO. 06-1601 LYNN M WOODS ORDER TO SETTLE. DISCONTINUE AND END TO T E PROTHONOTARY: Kindly mark the above-captioned matter settled, discontinued and nded upon payment of your costs only. P003 GORDON & WEINBERG, F.C. BY: G, ESQUIRE ESQUIRE --- ""~ c.:::J = (.:;,.... <- c: ::.::;:: t'-) 0' o -n -' :t:-n f1"1F: .",}t\~1; .] " j~~? - ---1' _.~ C) ""';-,fn 9\ -,..~ ~.!t -'-'" (~,? C) SHERIFF'S RETURN - NOT FOUND . CASE NO: 2006-01601 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND UNIFUND CCR PARTNERS VS WOODS LYNNE M 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 WOODS LYNNE M but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT & NOTICE , NOT FOUND , as to the within named DEFENDANT , WOODS LYNNE M 724 N PITT STREET CARLISLE, PA 17013 PER POST OFFICE, DEFENDANT'S ADDRESS IS 94 FRONT STREET OLD TOWN, ME 04468-1144. Sheriff's Costs: Docketing Service Not Found Surcharge 18.00 4.40 5.00 10.00 .00 37.404- so~.swers'. . ..~.. <,::.::/.......~~~ .. ... -. ..---: ...- -;/ ~...- ---- -~~~ R. Thomas Kli ,. Sheriff of Cumberland County GORDON & WEINBERG 03/27/2006 Sworn and subscribed to before me this /q f: day of M"'1 4...~L A.D. Prothonotary