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Home My WebLink About06-33362021964 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 FUSA 10625 Techwoods Circle Cincinnati, OH 45242 VS. KENNETH L KEINER 64 CHERRY LN CARLISLE PA 17013 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO NOTICE 0, -,3334 0, .t 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 "A" 5. All the credits to which the defendant(s)is entitled have been applied and there remains a balance due in the amount of $10,655.07. 6. Plaintiff has made demand upon the defendant(s)for payment of the balance due of $10,655.07 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 $10,655.07 at the rate of 27.99° from the date of April 10, 2003, together with costs and attorney fees. GORDON & WEINBERG, P.C. BY: FREDERIC I. EIN RG, ESQUIRE PAUL M. SCH IELD JR., ESQUIRE Attorney for aintiff 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. FREDERIC I. EINB RG, ESQUIRE 202.Iquy AFFIDAVIT OF INDEBTEDNESS State of Ohio ) County of Hamilton ) ss. Kim Kenney being sworn, deposes and says that she is Media Supervisor of Unifund 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 Kenneth L Keiner, Account Number 4266921015574310, the amount of $16503.90 (principal balance in the amount of $10655.07 plus interest up through 09/02/2005 in the amount of $5848.83). By the terms of the agreement between the defendant and the original creditor, interest is accruing from the aforesaid date at the rate of 27.99 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 FUSA. 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. DATED this September 2, 2005 KK UNIFUND CR PARTNERS y: Kim Kenney Media Supervisor 10625 Techwoods Circle Cincinnati, OH 45242 Address Subscribed and sworn to before me this 2 day of September, 2005 YISAr Notary Public My commission Expires N?? Client # 829 KAREN WILLIAMS NOTARY PUBLIC STATE OF OHIO Comm. Expires JUIy 19,201() 929 Balance as of: Payment Due Minimum Payment Account Number 09/0212005 Date Payment Enclosed Past Due 1 $16503.90 1$ 1 Make checks payable to: Unifund UNIFUND STATEMENT Kenneth L Keiner 84 Cherry Ln Carlisle PA 17013-7805 MESSAGE FROM UNIFUND Your account is past due $16503.90. 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: Transaction r-Ne-W -1 09/02/2005 Chase Manhattan Bank USA $16503.90 $16503.90 $0 $16503.90 NA's account was issued under the name of FUSA. 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. 2-011 Q C v l ? o a c N G, J r Q T1 T_ rn n SHERIFF'S RETURN - NOT FOUND CASE NO: 2006-03336 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND UNIFUND CCR PARTNERS VS KEINER KENNETH L 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 KEINER KENNETH L but was unable to locate Him in his bailiwick. He therefore returns the /' AffT T T TTTT C TT/1T T rL? the within named DEFENDANT KEINER KENNETH L 64 CHERRY LANE CARLISLE, PA 17013 DEFENDANT MOVED 5 YEARS AGO. Sheriff's Costs: So answers : ._.f . Docketing 18.00 Service 4.40 Not Found 5.00 R. T omas Kline Surcharge 10.00 Sheriff of erland County .00 37.40/ 7-Z 4-04 Sworn and Subscribed to before me this day of A. D. GORDON & WEINBERG 07/06/2006 NOT FOUND , as to Curtis R. Long Prothonotary Office of the Protbonotarp Cumberfaub Countp Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor nin 3.R,3 In_CVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 28TH DAY OF OCTOBER, 2009, AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R C P 230.2. BY THE COURT, CURTIS R. LONG PROTHONOTARY One Courthouse Square • Carlisle, Pennsylvania 17013 - (717) 240-6195 • Fax (717) 240-6573