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