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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
Atlantic Credit & Finance Inc
Assignee from Household Bank
3353 Orange Avenue
Roanoke, VA 24012
VS.
WILLIAM CRAMER
6 MIMOSA DRIVE
MECHANICSBURG PA 17055
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
DOCKET NO. : 0(0- qsA f l;tUit7_80-1
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 an
affidavit of debt and verified bill of particulars 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
$2,382.17.
6. Plaintiff has made demand upon the defendant for payment
of the balance due of $2,382.17 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
$2,382.17 plus interest from the date of June 27, 2003, together
with costs and attorney fees.
GORDON & WEINBERG, P.C.
BY:
FREDERIC I. INBER3, ESQUIRE
PAUL M. SCH FIELD JR., ESQUIRE
Attorney for aintiff
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. EINB RG, ESQUIRE
Oo'2681y
ATLANTIC CREDIT & FINANCE, INC.
V.
WILLIAM J CRAMER
AFFIDAVIT OF DEBT AND VERIFIED BILL OF PARTICULARS
The undersigned being first duly sworn according to law, deposes and says that she is familiar with
the policies and practices, as well as the books and records of the Plaintiff with respect to the matters
stated herein, and based on information and belief states as follows:
1. Plaintiff's principal business consists of purchasing charged off receivables.
2. The Defendant defaulted on Household Bank Account No. 5480420015112566. Said Account
was charged off on March 31, 2004 in the amount of $2,382.17.
3. Plaintiff purchased or was otherwise assigned this charged off account along with other debts. As
a result of the foregoing sale and assignment, the Plaintiff succeeded to all right, title and interest
in the charged off account, and it now owns the account.
4. Plaintiff conducted a due diligence investigation to determine, among other things, the accuracy of
the account information provided to ascertain whether the statute of limitations was a bar to
demand or institution of suit. Further, Plaintiff and/or its predecessor entered into a contract where
the predecessor made representations and warranties that 1) it had clear right, title and interest in
the account; 2) the account was free and clear of all liens and encumbrances; and 3) it had the
power, authority, and full right to sell and convey its interest in the account.
5. According to Plaintiff s records, the last payment date on this charged off account was
June 27, 2003 and after application of all payments, credits, adjustments, and lawful offsets, if any,
there is still a balance due and owing on this indebtedness of $2,382.17.
6. The internal Account Statement of Plaintiff is attached hereto as Exhibit A and displays the
account information that was provided to Plaintiff at the time of purchase and assignment.
The foregoing is true and correct to the best of my knowledge and belief.
By: C/?cGf l t/.t/l?.?
Heather Clary
Assistant Director of Forwarding
Subscribed and sworn before me on May 11, 2006.
Notary Public: Dawn Cowan
My Commission Expires: 6/30/2008
THIS COMMUNICATION IS FROM A DEBT COLLECTOR
Gordon & Weinberg, P.C.: DAFCOF- 738160
Our Account ID: 738160
Account Number: 5480420015112566
Atlantic Credit & Finance Inc.
Status: LEG
Reoort Date
5/11/2006 8:34AM
$2,382.17
$0.00
$2,382.17
Name
OtherName
Streatt
Street2
m
Closed:
Interest Rate:
Lest Int Date:
CRAMER, WILLIAM I
6 MIMOSA DR
MECHANICSBURG,PA 17055
pffitt 3lJRI !Matched Cheek No Invoiced
Payment Type PU','PA','PC' - Payment
Payment Type PUR', ?AR!,'PCR' - Returned Payment NSF
0.00
4/26/2004
Returned:
SSN - Last 4 Diails 9795 DOS
HomePhone 7177909424
WorkPhone
Confidential Property of Atlantic Credit & Finance Inc.
Page 1 of 1
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SHERIFF'S RETURN - REGULAR
CASE NO: 2006-04521 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
ATLANTIC CREDIT & FINANCE INC
VS
CRAMER WILLIAM
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
CRAMER WILLIAM the
DEFENDANT , at 1852:00 HOURS, on the 18th day of August 2006
at 6 MIMOSA DRIVE
MECHANICSBURG, PA 17055
WILLIAM CRAMER
by handing to
a true and attested copy of COMPLAINT & NOTICE together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing 18.00
Service 8.80
Affidavit .00
So Answers:
Surcharge 10.00 R. Thomas Kline
.00
36.80 ? 08/21/2006
GORDON & WEINBERG
L?- Sworn and Subscibed to By:
before me this day Deputy Sheriff
of A. D.
t k
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
2026814
Atlantic Credit & Finance Inc
Assignee from Household Bank
Vs.
WILLIAM CRAMER
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
DOCKET NO. : 06-4521
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 $2,382.17. IF YOU HAVE
ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL GORDON & WEINBERG,
P.C. AT 215/988-9600.
GORDON & WEINBERG, P.C.
BY:
FREDERIC I. WEI BERG, ESQUIRE
PAUL M. CHOFI D, JR.,ESQUIRE
Attorney for Plaintiff
Dated: September 20, 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
Atlantic Credit & Finance Inc.
Assignee from Household Bank
VS.
WILLIAM CRAMER
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
DOCKET NO. : 06-4521
PRAECIPE FOR JUDGMENT
The Prothonotary will please enter Judgment in the above matter
by default for want of an answer against the Defendant, WILLIAM
CRAMER, and assesses the damages as per statement below.
FREDERIC I. WE G, ESQUIRE
PAUL M. SCHOF ELD, JR., ESQUIRE
Attorney for ' tiff
Principal $2,382.17
Interest from March 31, 2004
@0% $.00
Total: $2,382.17
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. WEI BERG ESQUIRE
PAUL M. SCHOFIEL , JR., ESQUIRE
Attorney for Plaintiff
Filed:
By the Prothonotary:
AND NOW, this day of 2006 Judgment
is entered in favor of the plaintiff(s) and against defendant, for
want of an answer and damages assessed at the sum of , $2,382.17 as
per the above certification.
Prot onotary
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
Atlantic Credit & Finance Inc.
Assignee from Household Bank
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
Vs.
WILLIAM CRAMER
DOCKET NO. : 06-4521
CERTIFICATION OF ADDRESS
I hereby certify that the precise residence of the holder of the
within judgment is; Atlantic Credit & Finance Inc.Assignee from
Household Bank and that the last known address of defendant,
WILLIAM CRAMER, 6 MIMOSA DRIVE, MECHANICSBURG PA 17055.
GORDON & WEINBERG, P.C.
BY:
FREDERIC I WEIN ERG, ESQUIRE
PAUL M. SC OFI 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
Atlantic Credit & Finance Inc.
Assignee from Household Bank
VS.
WILLIAM CRAMER
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
DOCKET NO. : 06-4521
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, 6 MIMOSA
DRIVE, MECHANICSBURG PA 17055; 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 -2,-6?? Day
o / 2006.
Notary Public
FREDERIC I. W NB RG, ESQUIRE
Co'gA=CHRISTINE 4oNWEALTHOFPENNSYLVANIA PAUL M. SCHO ELD JR. ESQUIRE
IALSEAL Public Attorney for intiff
OL6N, Notary phia, Phila. County
iree NvVf)"r' `+f , 2019
2026814
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
Atlantic Credit & Finance Inc.
Assignee from Household Bank
vs.
WILLIAM CRAMER
TO/PARA
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
DOCKET NO. : 06-4521
NOTICE OF INTENTION TO TAKE DEFAULT
WILLIAM CRAMER
6 MIMOSA DRIVE
MECHANICSBURG PA 17055
DATE OF NOTICE/FECHA DEL AVISO: September 8, 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.
BY: "r
FR ERIC I. WEINBERG, ESQUIRE
PAUL M. SCHOFIELD, JR., ESQUIRE
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2026814
GORDON & WEINBERG, P.C.
BY: FREDERIC I. WEINBERG, ESQUIRE
Identification No.: 41360
JOEL M. FLINK, ESQUIRE
Identification No.: 81894
1001 E. Hector Street, Ste 220
Conshohocken, PA 19428
484/351-0500
Atlantic Credit & Finance Inc. COURT OF COMMON PLEAS
Assignee from Household Bank CUMBERLAND COUNTY
VS. DOCKET NO. : 06-4521
WILLIAM CRAMER
SUGGESTION OF BANKRUPTCY OF DEFENDANT
TO THE PROTHONOTARY:
AND NOW, this November 25, 2008, it is suggested of record
that Defendant, WILLIAM CRAMER, filed a petition in bankruptcy
under Chapter 13 of the Bankruptcy Code on or about November 17,
2008, in the United States Bankruptcy Court for the Western
District of Pennsylvania, docket number 08-70941. Therefore,
this matter should be stayed until further notice.
GORDON & WEINBERG, P.C.
BY:
FREDERIC I. BERG, ESQUIRE
JOEL M. FLINK, ESQUIRE
Attorney for Plaintiff
r.; i