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HomeMy WebLinkAbout06-2616 " 2025129 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 WACHOVIA NATL CONV 10625 Techwoods Circle Cincinnati, OH 45242 COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. DOCKET NO. : 0(". - .;),~I b CIU~C l~ CHRISTOPHER J HALL 99 MOUNTAIN LN NEWBURG PA 172 4 0 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 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) recei ved 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 $5,862.60. 5. Plaintiff has made demand upon the defendant(s)for payment of the balance due of $5,862.60 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 $5,862.60 at the rate of 17.24% from the date of March 10, 2003, together with costs and attorney fees. GORDON & WEINBERG, P.C. BY: FREDERIC I. WE PAUL M. SCHOF Attorney for 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. , ESQUIRE 20:2.5/,21 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 CHRISTOPHER J HALL, Account Number 4325159203369768, the amount of $8656,07 (principal balance in the amount of $5862.60 plus interest up through 01/20/2006 in the amount of$2793.47). By the terms of the agreement between the defendant and the original creditor, interest is accruing from the aforesaid date at the rate of 17.24 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 ofWACHOVIA NATL CONY. 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 January 20, 2006 V UNIFUND CCR PARTNERS By: Kim Kennev Media Supervisor 10625 Techwoods Circle Cincinnati. OH 45242 Address Subscribed and t 's 20 day ofJanuarv. 2006 Year Notary Public My commission Expires Client # 829 ~. , ~ J , ' !/ . ,'. "' ',/ JEi':'i:;:::< A. D~t,CAN ;,:::..'~ '~'J P'_~:.'~ SO', .. ,:,0 - C()rl.'~'; r~s -::- . .. :::' -'/ J' . .,,:. .~.- 0 ~ 'l/// ~i,i:" , 0\\' """, /1/; Or \\\' /1;/11111\\\\\\\ JULY' 05 2G07 p ;0.. 9 N \. lA (') ....., ~ \\:- U'l" = c: = :p: "" ~i;!! :;::lC lIl. -0 11~! :P" r'T'1{"1 .....c '-;7""" - ~ ;f~~' I OB~ - "0 ~ CD b ~ ~() -0 ~a 0 F 2:;: (~-~ ::x ~ .r::. .::.-c.' ~ 5'(:: w VJ ~ z w ~ 1""-0 ::2 w -4-- -L. A , 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 WACHOVIA NATL CONV COURT OF COMMON PLEAS CUMBERLAND COUNTY vs, DOCKET NO. 0626l6CIVILTERM CHRISTOPHER J HALL PRAECIPE FOR JUDGMENT The Prothonotary will please enter Judgment in the above matter by default for want of an answer against the ant, CHRISTOPHER J HALL, and assesses the damages as atement below. Pr' cipal terest from March 10, 2003 17.24% Total: $5,862.60 $3,339.50 $9,202.10 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 ( days prior to the date of the filing of this Praecipe. FRED IC I. WEINBERG, ESQUIRE PAU M. SCHOFIELD, JR., ESQUIRE At orney for Plaintiff Filed: By the Prothonotary: ~ AND NOW, this ~ day of , 2006 Judgment is entered in favor of the plaintiff(s) an against defendant, for want of an answer and damages assessed at he sum of , $9,202.10 as per the above certificatj)'n. . '":\ ~ L:LV'~J15. -_ Prothonotary . 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 WACHOVIA NATL CONV COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. DOCKET NO, 062616CIVILTERM CHRISTOPHER J HALL CERTIFICATION OF ADDRESS I hereby certify that the precise residence of the holder of the within judgment is; UNIFUND CCR PARTNERS ASSIGNEEOF WACHOVIA NATL CONV and that the last known address of defendant, CHRISTOPHER J HALL, 99 MOUNTAIN LN, NEWBURG PA 17240. GORDON & WEINBERG, P.C. DERIC I, WEINBERG, ESQUIRE PAUL M. SCHOFIELD, JR.,ESQUIRE Attorney for Plaintiff , . 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 WACHOVIA NATL CONV COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. DOCKET NO. 062616CIVILTERM CHRISTOPHER J HALL 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, 99 MOUNTAIN LN, NEWBURG PA 17240; 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 2~ TA Day Notary Public ONW&......TI'l OF PENNS\'L.v...NIA ,NOT ARIA\. SEAL Public CHRISTINE M. COLON, ~unty City bf Phll8dlllphls. PtII1I. 18 2009 M FREDERIC I. WEINBERG, ESQUIRE PAUL M. SCHOFIELD, JR. ESQUIRE Attorney for Plaintiff 2025129 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 WACHOVIA NATL CONV COURT OF COMMON PLEAS CUMBERLAND COUNTY VB. DOCKET NO, 062616CIVILTERM CHRISTOPHER J HALL NOTICE OF INTENTION TO TAKE DEFAULT TO/PARA CHRISTOPHER J HALL 99 MOUNTAIN ,LN NEWBURG PA 17240 DATE OF NOTICE/FECHA DEL AVISO: June 16, 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, ~ -FRED C I. WE ~B~~~, ~~QUIRE PAUL M. SCHOFIELD, JR" ESQUIRE P10D-2 (J~ \-1-~~ {!-~~ ~' ~ - t- ~ ~\ t ~ -1: r--- o ~~i ~4\ S:. :" :::;l ;' , (2:=: f\::" 1" C"- .." - v:o ...", ...,.;:.', r:-? (1"1 ''S2. o " e 2025129 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 COURT OF COMMON PLEAS CUMBERLAND COUNTY UNIFUND CCR PARTNERS ASSIGNEE OF WACHOVIA NATL CONV vs. DOCKET NO. 062616CIVILTERM CHRISTOPHER J HALL NOTICE 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 $9,202.10. IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL GORDON & WEINBERG, P.C, AT 215/988-9600. GORDON & WEINBERG, P.C, FREDERIC I. WEINBERG, ESQUIRE PAUL M. SCHOFIELD, JR.,ESQUIRE Attorney for Plaintiff Dated: June 28, 2006 SHERIFF'S RETURN - REGULAR CASE NO: 2006-02616 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND UNIFUND CCR PARTNERS VS HALL CHRISTOPHER J WILLIAM CLINE , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon HALL CHRISTOPHER J the DEFENDANT , at 1630:00 HOURS, on the 26th day of May , 2006 at 99 MOUNTAIN LANE NEWBURG, PA 17240 by handing to KATY MARSHALL, ROOMMATE, ADULT IN CHARGE 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 So Answers: 18.00 17.60 .00 10.00 .00 45.60-/ ~~~ R. Thomas Kline ~ Sworn and Subscibed to 05/30/2006 GORDON & WEINBERG 117 -04 By: ~\T~ ; eputy Sheriff before me this day of A.D.