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HomeMy WebLinkAbout06-34632023511 THIS IS AN ARBITRATION MATTER. 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 ASSESSMENT OF Atlantic Credit & Finance Inc Assignee from Household Bank 3353 Orange Avenue Roanoke, VA 24012 VS. MICHELLE KELLY 454 SHED RD NEWVILLE PA 17241-8759 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : ()(e -3qa C2, j ?'? 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 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 was the holder of a credit card, which at the request of the defendant was issued to the defendant by the plaintiff under the terms of which the plaintiff agreed to extend to defendant the use of plaintiff's credit facilities. 3. Defendant 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 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 "A" 5. All the credits to which the defendant is entitled have been applied and there remains a balance due in the amount of $2,552.57. 6. Plaintiff has made demand upon the defendant for payment of the balance due of $2,552.57 but the defendant has failed and refused and still refuses to pay the same or any part thereof. WHEREFORE, plaintiff claims of the defendant the sum of $2,552.57 at the rate of 22.24* from the date of March 10, 2003, together with costs and attorney fees. GORDON & WEINBERG, P.C. BY: FREDERIC I. EINBE G, ESQUIRE PAUL M. SCHO , JR., ESQUIRE Attorney for Plaintiff P01E.DB VERIFICATION FREDERIC I. WEINBERG, ESQUIRE, hereby states that he is the attorney for the Plaintiff 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. INBERG ESQUIRE HOUSEHOLD BANK GOLD MASTERCARD STATEMENT MICHELLE KELLY ACCOUNT SUMMARY ACCOUNT 5408-0100-0470-5600 NUMBER TOTAL CREDIT LIMIT $0 TOTAL CREDIT LIMIT $0 AVAILABLE Page 1 of 1 BALANCE SUMMARY PREVIOUS BALANCE $2,517.57 PAYMENTS/CREDITS - $0.00 PURCHASES/DEBITS + $35.00 FINANCE CHARGE + 60.00 *See reverse side for an ex- STATEMENT DATE 10/31/03 planation of these amounts. NEW BALANCE 62,552.57 TRANSACTION SUMMARY TRAM POST TRANSACTION REFERENCE AMOUNT DATE DATE DESCRIPTION NUMBER CHARGES CREDITS 10/2710/27 OVERLIMIT CHARGE ASSESSMENT 10000001030000000128360 $35.00 FINANCE CHARGE CALCULATION This is a grace account. Grace period information on back. Nominal ANNUAL Average Daily Days FINANCE CHARGE Annual PERCENTAGE Daily Periodl In Billing At PeriodicCash Advance Percentage RATE Balance Rate Cycle Rate Fees Rate PURCHASES 60.00 .06090%. 15 $0.00 $0.00 22.24%. 22.24%. CASH ADVANCES $0.00 .06090% 15 $0.00 $0.00 22.24% 22.24% MAIL PAYMENTS TO: QUESTIONS? MAIL INQUIRIES TO: HOUSEHOLD CREDIT SERVICES 2 4-HOUR CUSTOMER SERVICE HOUSEHO LD CREDIT SERVICES P.O. BOX 17051 1-800-477-6000 PO BOX 81622 BALTIMORE MD 21297-1051 OUTSIDE USA, COLLECT: 1-757-523 -3880 SALINAS CA 93912-1622 TOO HEARING IMPAIRED: 1-800-395-9020 Manage your account online at: www.householdbank.com 090550 Z 16 G STMTXX E PLEASE DETACH AND RETURN BOTTOM PORTION WITH YOUR PAYMENT: To Assure Proper Credit Please Write Your Account Number On Your Check MICHELLE KELLY 147 FARMERSVILLE RD SANDWICH MA 02563-2643 Now Balance 62,552.57 Payment Due Date 11/14/03 Current Payment Du$2,552.57 Make checks payable to HOUSEHOLD CREDIT SERVICES . Please write your account number on your check. Do not fold, staple or clip. Do not send cash. Please send your payment 7 days prior to the payment due date to ensure timely delivery. Amount Enclosed N E 6 PAYMENT SUMMARY OVERLIMIT AMOUNT $2,552.57 MINIMUM PAYMENTS $63.00 CURRENT PAYMENT DUE* 62,552.57 PAYMENT DUE DATE 11/14/03 PAST DUE AMOUNT $366.00 Account Number 5408-0100-0470-5600 HOUSEHOLD CREDIT SERVICES P.O. BOX 17051 BALTIMORE NO 21297-1051 540801000470560000255257002552571 r it rn,r NT ? G (S: SHERIFF'S RETURN - NOT FOUND CASE NO: 2006-03463 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ATLANTIC CREDIT & FINANCE INC VS KELLY MICHELLE 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 unable to locate Her in his bailiwick r'nt%)MT TTMM f_ Mnrr T("V but was He therefore returns the the within named DEFENDANT 454 SHED ROAD NEWVILLE, PA 17241 , KELLY MICHELLE NOT FOUND , as to NO LONGER AT THIS ADDRESS PER CURRENT OWNER. NO FORWARDING ADDRESS ON FILE AT POST OFFICE. Sheriff's Costs: So answers :. ,.-----? - ,-- Docketing 18.00 ?..- Service 8.80 Not Found 5.00 R. Thomas Kline Surcharge 10.00 Sheriff of Cumberland County .00 41.80, GORDON & WEINBERG 7, -7/2-,(104, 07/10/2006 Sworn and Subscribed to before me this day of , A. D. Curtis R. Long Prothonotary office of the Protbonotarp Culnberlanb Cuuntp Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor 61- 3Y1. 3 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