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Home My WebLink About06-3333 . 2024788 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 CARD CONV 10625 Techwoods Circle Cincinnati, OH 45242 COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. DOCKET NO. Dla -33.13 c?LuJ T~ BARBARA D/MS HOFFMAN 1402 BRADLEY DR APT 113 CARLISLE PA 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 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, 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 COMPLAINT IN CIVIL-ACTION 1. Plaintiff, Unifund CCR Partners is a debt buyer and successor in interest to the original creditor as set forth in the caption of this Complaint. 2. 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. 3. 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. 4. The defendant (s) received 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 nAn. 5. All the credits to which the defendant(s)is entitled have been applied and there remains a balance due in the amount of $6,177.76. 6. Plaintiff has made demand upon the defendant(s)for payment of the balance due of $6,177.76 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 $6,177.76 at the rate of 19.49% from the date of October 30, 2002, together with costs and attorney fees. P01h GORDON & WEINBERG, P.C. BY: FREDERIC I. PAUL M. SCH Attorney fo ERG, ESQUIRE ESQUIRE 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. FREDERIC I. UJJl(7PJ? 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 BARBARAD/MS HOFFMAN, Account Number 4366133037190526, the amount of $9728.43 (principal balance in the amount of $6177.76 plus interest up through 01/09/2006 in the amount of$3550.67). By the tenns of the agreement between the defendant and the original creditor, interest is accruing from the aforesaid date at the rate of 19.49 percent per annum. This balance reflects any payments, credits or offsets made since the account was charged off. Chase Manhattan Bank USA NA's account was issued under the name of FIRST CARD CONY Unifund CCR Partners purchased this account from Chase Manhattan Bank USA NA. Said account has been referred to Gordon & Weinberg P.C. with full power and authority to do and perform all acts necessary for the collection, settlement, adjustment, compromise or satisfaction of said claim. L~"'9'2006 CCR PARTNERS By: Kim Kennev Media Supervisor 10625 Techwoods Circle Cincinnati. OH 45242 Address _OOd~--~rw:ili~ Notary Public My commission Expires Client # 829 ..j)llIilf/( ~,\\\\"p..RIAL 111/1/ ~' 0' ...........,se // f ~/~\II/~:f/\ ~ :'~ ~-" ~ - . ' - = : : ~ \~:..;., . ....$= ~I ~~ ......... 0 ~ II; ~~ OF oy..1\. ,\:\ 1111///,11111\1\\\\\\\\ KAREN WILLIAMS NOTARY PUBLIC STATE OF OHIO Comm. Expires July 19, 2010 829 ;(0,,2Y7cPf Balance as of: Payment Due Minimum Payment Account Number 01/09/2006 Date Payment Enclosed I 4366133037190526 I $9728.43 I Past Due I $9728.43 1$ I Make checks payab. to: Unifund UNIFUND STATEMENT BARBARA DIMS HOFFMAN 1402 BRADLEY DR APT 113 CARLISLE PA 17013 MESSAGE FROM UNIFUND Your account is past due $9728.43. 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 01/0912006 Chase Manhattan Bank USA $9728.43 $9728.43 $0 $9728.43 NA's account was issued under the name of FIRST CARD CONY. Unifund CCR Partners purchased this account from Chase Manhattan Bank USA 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. ~\ -l,O.. llI. tn. '1.J U"\ -- ~ ...~ ~ ~ C> \) ~ ""'" C> G" 12 -1: n c: .-> c;::? C,'l 0'" ,- , - - r-' -r:> --:f" -""~ S{; /~ ~-CI rn--'~ r:::, <J\~\ ~,~~ -C ',-'I.."> ) '1'\ _ -,'I () -r-:;... ~rn . , ~4 p ?l c.>? c" (.), " 2024788 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 FIRST CARD CONV vs. DOCKET NO. 06-3333 BARBARA DIMS HOFFMAN NonCE 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 $10,677.26. IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL GORDON & WEINBERG, P.C. AT 215/988-9600. GORDON & WEINBERG, P.C. BY: FREDERIC . WEI ERG, ESQUIRE PAUL M. S LD, JR.,ESQUIRE Attorney for Plaintiff Dated: July 26, 2006 . . 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 CARD CONV COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. DOCKET NO. 06-3333 BARBARA D/MS HOFFMAN PRAECIPE FOR JUDGMENT The Prothonotary will please enter Judgment in the above matter by default for want of an answer against the Defendant, BARBARA D/MS HOFFMAN, and assesses the damages as per statement below. FREDERIC I. WEI ESQUIRE PAUL M. SCHOFIE ,JR., ESQUIRE Attorney for Plaintiff principal Interest from October 30, 2002 @19.49% Total: $6,177.76 $4,499.50 $10,677.26 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. FREDERIC I. WE , ESQUIRE PAUL M. SCHOFIELD, JR., ESQUIRE Attorney for Plaintiff Filed: By the Prothonotary: AND NOW, this crt"- day of /J(~%~rf- , 2006 Judgment is entered in favor of the p1aintiff(s) a against defendant, for want of an answer and damages assessed at the sum of , $10,677.26 as per the above certificat. n. ~ Prothonotary t 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 FIRST CARD CONV vs. DOCKET NO. 06-3333 BARBARA D/MS HOFFMAN CERTIFICATION OF ADDRESS I hereby certify that the precise residence of the holder of the within judgment is; UNIFUND CCR PARTNERS ASSIGNEEOF FIRST CARD CONV and that the last known address of defendant, BARBARA D/MS HOFFMAN, 1402 BRADLEY DR APT 113, CARLISLE PA 17013. GORDON & WEINBERG, P.C. BY: FREDERIC I W BERG, 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 FIRST CARD CONV COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. DOCKET NO. 06-3333 BARBARA D/MS HOFFMAN 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, 1402 BRADLEY DR APT 113, CARLISLE PA 17013; 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 ~ ' 2006.. - . ?n.t1/~ Notary Public MONWI: LTH OF PENNSYLVANIA NOT ARIA~ SEAL CHRISTINE M. COLON, Notary Public City of Phlladelphle. Phlle. Count}' ',. (';2r;n1l11. i N mm 18 2~~ FREDERIC I. EI PAUL M. SCHOFI Attorney for Pl , . 2024788 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 CARD CONV COURT OF COMMON PLEAS CUMBERLAND COUNTY VB. DOCKET NO. 06-3333 BARBARA D/MS HOFFMAN TO/PARA NOTICE OF INTENTION TO TAKE DEFAULT BARBARA D/MS HOFFMAN 1402 BRADLEY DR APT 113 CARLISLE PA 17013 DATE OF NOTICE/FECHA DEL AVISO: July 12, 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 PAUL M. BY: P10D-2 , t ;x:J i .IQ. ... --0 . ~ 0 ~ - = ~ r C> c. = s: cro - ~ f! -ocn > :i!::o cprn c: ~ )J _".:.1'1 ~ ZSZ. en mlTi ~ .c: I ~6 ~7 \D ..... ('J 4:: L ,J '< . .)>c ..., :t!-,. .. Z1 - ,{ ~ ~ )'>0 :x ~~ c ~ ~ to) ~ (J'I Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon HOFFMAN BARBARA D/MS the .... DEFENDANT at 1215:00 HOURS, the 20th day of June 2006 ..... , on I SHERIFF'S RETURN - REGULAR CASE NO: 2006-03333 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND UNIFUND CCR PARTNERS VS HOFFMAN BARBARA D/MS STEPHEN BENDER , Sheriff or Deputy Sheriff of at 1402 BRADLEY DRIVE APT 113 CARLISLE, PA 17013 by handing to BARBARA HOFFMAN 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 4.40 .00 10.00 .00 32.40/ ?/I'l/Ol, r~~~~~ R. Thomas Kline 06/21/2006 GORDON & WEINBERG By, ~d;U D pu y Sheriff ~ Sworn and Subscibed to before me this day of A.D. ,- - - - - .- - - ,-