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Home My WebLink About06-4522 2017644 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 COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. DOCKET NO. 01. -.l.JSJ.2.. eto."tT~ JOAN R GOODLING 1113 APPLE DR-Apt 9 MECHANICSBURG PA 17055 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 r' 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 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 $3,241. 97 . 6. Plaintiff has made demand upon the defendant for payment of the balance due of $3,241.97 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 $3,241.97 plus interest from the date of October 7, 2002, together " with costs and attorney fees. GORDON & WEINBERG, P.C. BY: P01E.DB FREDERIC I. PAUL M. SCH Attorney for 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. WEI QUIRE , . . 2017644 Atlantic Credit & Finance Inc. Assignee from Household Bank JOAN R GOODLING 5499440911061906 AFFIDAVIT I, HEATHER CLARY, being duly served sworn according to law, depose and say that: 1. I am the agent for the Plaintiff herein and I have custody and control of the files relating to this account; 2. I have personal knowledge of the facts and circumstances in connection with this case; 3. Plaintiff's files are maintained in the usual and ordinary course of business; 4. This action is based on a claim for breach of contract and that damages are sought as a direct result of said breach; 5. After allowing for all offsets and credits, a balance remains on the subject acc&unt having account number 5499440911061906in the amount of $3,241.97; and 6. If called upon, affiant can testify at trial as to the facts pertaining to this matter. The above facts are true and correct to the best of my knowledge, information and belief. HEA~~,~;ant Director of Forwarding Atlantic Credit & Finance, Inc. Sworn to and Subscribed before me this ~ day of , 2006 ",'1111.1".... ........,~O~.~~/~", .:...~~..:~CNWf.:;..:t- ~ .: :_........' 7('0. ~ .. .~- ,.A.. ~ g :u OF :r.: :: :. ':. : = -; -i;'" vIRG\\\'-"'-':S> j '" 0" ......-... ,; )': .......,<0"..... """1 ~AY ~v \......... """111\"" AJ *- ~ (j ~ (';) -tl;\ t. ~ ~ (9 ~ -) - ~ ~ I;') ~ ~~ = ;~ ~ 0~ ~:R ~ ~ c:; -.lei ~("' .." =?-n ~gz ::J: 2:ii 't? '-'~ :<! U1 ~ SHERIFF'S RETURN - REGULAR CASE NO: 2006-04522 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ATLANTIC CREDIT & FINANCE INC VS GOODLING JOAN R GERALD WORTHINGTON , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon GOODLING JOAN R the DEFENDANT , at 1045:00 HOURS, on the 16th day of August , 2006 at 1113 APPLE DRIVE APT 9 MECHANICSBURG, PA 17055 by handing to PATTY ERNEY, DAUGHTER 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 9.68 .~~~ .00 10.00 R. Thomas Kline .00 37.68/08/17/2006 c;L q )2& I D (, GORDON & WE INBERG Sworn and Subscibed to before me this day By: A 0 L ) 17 k- /,,-L,~ tG~LyW; , Deputy Shtyiff of A.D. ~ 2017644 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. DOCKET NO. 06-4522 JOAN R GOODLING 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 $3,241.97. IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL GORDON & WEINBERG, P.C. AT 215/988-9600. GORDON & WEINBERG, P.C. FREDERIC I RG, ESQUIRE PAUL M. SC OFIEL , JR.,ESQUIRE Attorney fo BY: Dated: September 20, 2006 ~ ~ORDON & 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. DOCKET NO. 06-4522 JOAN R GOODLING PRAECIPE FOR JUDGMENT The Prothonotary will please enter Judgment in the above matter by default for want of an answer against the Defendant, JOAN R GOODLING, and assesses the damages as per statement below. Principal Interest from March 9, 2005 @O% Total: $3,241.97 $.00 $3,241.97 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 p ior to the date of the filing of this Praecipe. FREDERIC I. WEINBE G, E QUIRE PAUL M. SCHOFIELD, JR , ESQUIRE Attorney for Plaintiff Filed: By the Prothonotary: AND NOW, this 3~ day of Q-.J.,..J,9/l. , 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 , $3,241.97 as per the above certification. (J,.", ~h prothOn6ta~ ~ 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. DOCKET NO. 06-4522 JOAN R GOODLING 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, JOAN R GOODLING, 1113 APPLE DR-Apt 9, MECHANICSBURG PA 17055. GORDON & WEINBERG, P.C. BY: r ~ORDON & 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. DOCKET NO. 06-4522 JOAN R GOODLING 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, 1113 APPLE DR-Apt 9, 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 ~~ Day ~2006' -' ,~ otary Public OMMONWEA\..TH OF PENNSYLVA.NIA. C NOT AR\Al SEAL . HRISTINE M,GOl6N, Notary PubliC C City of Philadelphia, Phlla.:,2~u1n~y 2(\(\9 , ' E Ires Nl:wel. ..:L--:.- _ _ ~~n ~ __ ~ ..-..-..-~ FREDERIC I. W PAUL M. SCHOF LD JR. Attorney for Plaintiff 2017644 " 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 Atlantic Credit & Finance Inc. Assignee from Household Bank COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. DOCKET NO. 06-4522 JOAN R GOODLING NOTICE OF INTENTION TO TAKE DEFAULT TO/PARA JOAN R GOODLING 1113 APPLE DR-Apt 9 MECHANICSBURG PA 17055 DATE OF NOTICE/FECHA DEL AVISO: September 7, 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: / / /<2---"7 c' ~ e------------.----... P10D-2 /' /... ~/ FREDERIC I. WEINBERG, ESQUIRE PAUL M. SCHOFIELD, JR., ESQUIRE t ~ ~ ~ 0 f-.-.) ~ -0 C c,:) C_) C";:' ;;.~ 0-- -(1 . () t', C) --4 C") -r C> -; fil~ - I -nfl1 ~ """--- - ...- ;J~ :;~) ~ .J:: ~ ',:j !:.:) :r:;"~ ~. . '~') =,~~! - .'~ff; :-~:.;,. C~) ~ ..::5 t1 CO 25fTl l: ,--1 ~ ,-..., ~ ..... CJ\ -< ~ ---t