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HomeMy WebLinkAbout06-2704 . , 2019712 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 Genesis Financial Solutions, Inc. as Successor in Interest to Conseco Finance d/b/a Dick's Sporting Goods 8405 Sw Nimbus Ave. Suit Beaverton, OR 97008--718 COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. DOCKET NO. : 01., - ~ 'ldf C;(); L'T'OVi Tiffany S Brorsen 3 Buffalo Drive Shippensburg PA 17257-9776 COMPLAINT IN ASSUMPSIT 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 , 1. The defendant, for valuable consideration received, executed and delivered to plaintiff a promissory note under the terms of which the defendant promised to pay to the plaintiff consecutive monthly payments under the terms and conditions set forth in the promissory note. A true and correct copy of the aforesaid promissory note is attached hereto, made a part of this complaint and marked Exhibit "A". 2. Contrary to the terms of the aforesaid promissory note, the defendant failed to make the required payments when due as a result of which the unpaid balance of $1,978.72 became due and payable. 3. As a result of defendant's default, defendant is indebted to plaintiff in the amount of $1,978.72 plus interest thereon and attorney's fees as provided for in the promissory note. 4. Plaintiff has made demand upon the defendant for payment of the amount due but the defendant has failed and refused and still refuses to pay the said sum or any part thereof. WHEREFORE, plaintiff claims of the defendant the sum of $1,978.72 plus interest and attorney's fees as provided for in the promissory note. GORDON & WEINBERG, P.C. FREDERIC I. PAUL M. SCHO Attorney for G, ESQUIRE , JR., ESQUIRE Plaintiff BY: P01C , VERIFICATION FREDERIC I. WEINBERG, ESQUIRE, hereby states that he is the attorney for the Plaintiff(s) in this action and verifies that the statements made in the foregoing pleading are true and correct to the best of his knowledge, information and belief. The undersigned understands that the statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities. , ESQUIRE , EXHIBIT "A" I . . From: 612664 8222 Page: 57/61 lilROON FNl IllEINBERG, PC Fax; 2159889602 P.1I Date: 4/1 g/2006 9:58:32 AM Rpr 10 2006 10:27 20111'712 GeMSj,8 l'iDlU'lC'~.' Sc:iJ.llt:.i.DJlIl, znc. .. Succ...OI: 'u Inter..t ''toC=-eo~s.nqoe d/bla tl~alc' 8 SportiJ2g Goods 'Ufhfty S Bl:OUWI gg06012$D36015D4463 '.HTn>aV%~ I, ~J. ~. ~~ sworn according ~o law, depose and .a~ that: 1. ! am the aqent for the Plaintiff here~n 'end 1 have cu.tody and con~rol of the ~iles relating to thia account; , bej,ng duiy aerveo 2. Iha~'e personal ~now.l.edqe of the beta anClcir=stanoesin connection with this caeel '3. PJ.a.i.r,tiff's files aramaintaineCl in the usual lInd ord.1nuy course of businessl 4 . '1'1118 action 1stlased cma cloiim forllreach of oont.ract and that damaga. ar~ sought as a direct result of said breaeh, 5. After allOWing for all offsets.tlel credits, A tI&lanoe remains on the subject acco~nt bavin~ acoount number 00060125036015C4H31n the amount of n,978.72; lln6 6. If called \.Ipon. llffiant can testify a as tCl thefllcts pertllining to t,hi. matter. The above facts are information and belief. est of mknowledr;lI, 5warn eo and S~b.oribed ;;z -r-I> l>efore "Tl\e this -2..- day Of ~_, :20~ IJ~,^.~ Notary:>w,l.i.= Jmald .Jensoo ~u::=~ t . Ol'FIC/AI.,ftAI.. ,:.- ' DONNA M aoNOEMA '.~'" NOrARYPlJ~~ COMMIsSIOI1I M) ~ .~ ", COMMISSQij'EXPIRES FEB. 3, 2fXIIi This fax was received by GFt FAXmaker '. fax server. For more Information viSit. http'I"..uuf' , . . Iwyvw.g l.eom 2t'l~( , . \ IV (.) ~ (Z . t. U";, '\+.. U{ f -- (,1. (J ,..., j "- C = ~ ..0 "'" .... Q" -.. () r..,,:!>.~ ?,: ~:!! 8 ~ n,_,',' V) '7 - ~ ~_.~ ...J', -< ~ :~;:. j- t;; ilP ~~ r"- ~r'''1 ~,~.' -0 '- . :::t:> ~;,-~ :x i":;>:n P't: 2:0 .t...... <.? om --:... -I...... 2~ ~ -i W -~ U1 '-< ~- . - ... 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 Genesis Financial Solutions, Inc. as Successor in Interest to Conseco Finance d/b/a Dick's Sporting Goods COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. DOCKET NO. 062704CIVILTERM Tiffany S Brorsen PRAECIPE FOR JUDGMENT The Prothonotary will please enter Judgment in the above matter by default for want of an ans gainst the Defendant, Tiffany S Brorsen, and assesses the mage per statement below. REDERIC I. WEINBERG, ESQUIRE L M. SCHOFIELD, JR., ESQUIRE Attorney for Plaintiff Principal Interest from April 8, 2005 @O% Total: $1,978.72 $.00 $1,978.72 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 leas n (10) days prior to the date of the filing of this Praecipe. ~REDERIC I. WEINBERG, ESQUIRE PAUL M. SCHOFIELD, JR., ESQUIRE Attorney for Plaintiff Filed: By the Prothonotary: AND NOW, this I ]R day of .J... ':-t ' 2006 Judgment is entered in favor of the p1aintiff(s) and gainst defendant, for want of an answer and damages assessed at the sum of , $1,978.72 as per the above certificat' n. ~ ~ '- .. 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 Genesis Financial Solutions, Inc. as Successor in Interest to Conseco Finance d/b/a Dick's Sporting Goods COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. DOCKET NO. 062704CIVILTERM Tiffany S Brorsen CERTIFICATION OF ADDRESS I hereby certify that the precise residence of the holder of the within judgment is; Genesis Financial Solutions,Inc. as Successor in Interest to Conseco Finance d/b/a Dick's Sporting Goods and that the last known address of defendant, Tiffany S Brorsen, 3 Buffalo Drive, Shippensburg PA 17257-9776. GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE 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 Genesis Financial Solutions, Inc. as Successor in Interest to Conseco Finance d/b/a Dick's Sporting Goods COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. DOCKET NO. 062704CIVILTERM Tiffany S Brorsen 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, 3 Buffalo Drive, Shippensburg PA 17257-9776; 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 Before me this ~~Day ~~ -~~ ( tary Public ..._AI.THOF PENN!l'rI.VANIA COMMO...~~ NOTARIAl. SEAL . CHRISTINE M. COLON, Notary PublIC City Ilf PhUadelphla, Phlla. Cour~ 2009 i nExnires Novemb!!r 1 FR DERIC I. WEINBERG, ESQUIRE PAUL M. SCHOFIELD, JR. ESQUIRE Attorney for Plaintiff 1.._ _"'-.. .. 2019712 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 Genesis Financial Solutions, Inc. as Successor in Interest to Conseco Finance d/b/a Dick's Sporting Goods COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. DOCKET NO. 062704CIVILTERM Tiffany S Brorsen NOTICE OF INTENTION TO TAKE DEFAUI.T TO/PARA Tiffany S Brorsen aka Tiffany Bartha10w 3 Buffalo Drive Shippensburg PA 17257-9776 DATE OF NOTICE/FECHA DEL AVISO: June 14, 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 PIOD-2 GORDON & WEINBERG, P.C. ." ~.,," :.:::u""'HM PAUL M. SCHOFIELD, JR., ESQUIRE ...--' - . (:;7V ~ ~ ~il<'l 0 _ _ \l- t: ~ ~ ~ \' 0- ...c tL: ~ )oJ ~ r- -:1 ~ ~ -L ~ <) <::"J --1" .;:;,.1'-' -..... -r~ :T: n I C" - t.>J --n r;-? u' - ......... . 2019712 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 Genesis Financial Solutions, Inc. as Successor in Interest to Conseco Finance d/b/a Dick's Sporting Goods COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. DOCKET NO. 062704CIVILTERM Tiffany S Brorsen 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 $1,978.72. IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL GORDON & WEINBERG, P.C. AT 215/988-9600. GORDON & WEINBERG, P.C. FREDE C I. WEINBERG, ESQUIRE PAUL M. SCHOFIELD, JR. ,ESQUIRE Attorney for Plaintiff Dated: June 28, 2006 ,..... SHERIFF'S RETURN - REGULAR CASE NO: 2006-02704 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND GENESIS FINANCIAL SOLUTIONS VS BRORSEN TIFFANY S ROBERT BITNER , Sheriff or Deputy Sheriff of Cumberland CouBty, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - ASSUMPSIT was served upon BRORSEN TIFFANY S the DEFENDANT , at 1840:00 HOURS, on the 22nd day of May at 3 BUFFALO DRIVE , 2006 SHIPPENSBURG, PA 17257-9776 by handing to FRANK BARALOW, HUSBAND a true and attested copy of COMPLAINT - ASSUMPSIT together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: ~ Sworn and Subscibed to 18.00 17.60 .00 10.00 .00 45. 60 ~ 7/11/01.. R.C~~ OS/25/2006 GORDON & WEINBERG before me this day of A.D.