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Home My WebLink About06-4622 . 2024449 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 Velocity Investments, LLC as Successor in Interest to CitiFinancial PO Box 788 Wall, NJ 07719 COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. DOCKET NO. oc. -'-/1").,, Ciu~CT€IUr1 JASON S FAILOR 573 MOUNT ROCK RD NEWVILLE PA 17241 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 YOU~ 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 COUNT~ BAR ASSOCIATION 32 S. BEDtORD STREET CARLISLEJ PA 17013 (717) 149-3166 ! . COMPLAINT IN CIVIL-ACTION 1. Plaintiff is a debt b~yer 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 $6,524.61. 6. Plaintiff has made demand upon the defendant(s)for payment of the balance due of $6,524.61 but the defendant(s)has failed and refused and still reJuses to pay the same or any part ! thereof. , WHEREFORE, plaintiff claims of the defendant(s) the sum of $6,524.61 at the rate of 6% from the date of July 29, 2003, together with costs and attorney fees. GORDON & WEINBERG, P.C. BY: FREDERIC I. WEIN ERG, ESQUIRE PAUL M. SC D, JR., ESQUIRE Attorney for Plaintiff P01E.DB 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 ERG, ESQUIRE 2024449 Velocity Investments, LLC as Successor in Interest to CitiFinancial JASON S FAILOR 09080389443 I, sworn according {!~ , being duly served 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 o~fsets and credits, a balance remains on the subject account having account number 09080389443in the amount of $6,524.61; and 6. If called upon, affiant can testify at trial as to the facts pertaining to this matter. The above facts are true information and belief. (Name USA A. SCIIWNGER NOTARY P\J8UC OF NEW oERSEY MY CO_OIl EXPIRES JULY 22, 11110 ~ ~ - v, ~ () ~ l.J w - ~ .(Q. ~ "1 ()- ~ J:: ~ ~ -00) ~~E, !}) '~_.' '2\:' J?;C"; ~-._~ ~'c ~ t ~'" Q G"' ~fij c; ~s ~ %~ t.W "" ;.:, ! c:> SHERIFF'S RETURN - REGULAR CASE NO: 2006-04622 P COMMONWEI~.LTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND VELOCITY INVESTMENTS LLC VS FAILOR JASON S HAROLD WEARY , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon FAILOR J.l~SON S the DEFENDANT , at 1135:00 HOURS, on the 30th day of August , 2006 at 573 MOUNT ROCK ROAD NEWVILLE.. PA 17241 by handing to GARY FAILOR, UNCLE, ADULT IN CHARGE 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 Service Affidavit Surcharge So Answers: Sworn and 18.00 7.04 .00 10.00 .00 35.04v ~ q/.2~' ()~ Subscibed to r"~.d~ R. Thomas Kline 08/30/2006 GORDON & WEINBERG By: /U,/'-J~ Deputy Sneriff before me this day of A.D. .. GORDON & WEINBERG, P.C. J 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 Velocity Investments, LLC as Successor in Interest to CitiFinancia1 COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. DOCKET NO. 06-4622 JASON S FAILOR PRAECIPE FOR JUDGMENT The Prothonotary will please enter Judgment in the above matter by default for want of an answer against the Defendant, JASON S FAILOR, and assesses the damages as statement below. UIRE SQUIRE Principal Interest from March 23, 2004 @6% Total: $6,524.61 $998.55 $7,523.16 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. Filed: By the Prothonotary: AND NOW, this ~JoJ~day of Ajry).. is entered in favor of the plaintiff(s) and against defendant, for want of an answer and damages assessed at the sum of , $7,523.16 as per the above certification. ~~~.~ ~A prothon{;tar~ /. , 2006 Judgment GORDON & WEINBERG, P.C. f 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 Velocity Investments, LLC as Successor in Interest to CitiFinancial COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. DOCKET NO. 06-4622 JASON S FAILOR CERTIFICATION OF ADDRESS I hereby certify that the precise residence of the holder of the within judgment is; Velocity Investments, LLC asSuccessor in Interest to CitiFinancia1 and that the last known address of defendant, JASON S FAILOR, 573 MOUNT ROCK RD, NEWVILLE PA 17241. GORDON & WEINBERG, P.C. FREDERIC I. PAUL M. SCH Attorney fo BY: GORDON & WEINBERG, P.C. 1 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 Velocity Investments, LLC as Successor in Interest to CitiFinancial vs. DOCKET NO. 06-4622 JASON S FAILOR 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, 573 MOUNT ROCK RD, NEWVILLE PA 17241; 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 ~ FREDERIC I. WE NBE , ESQUIRE PAUL M. SCHOFI , JR. ESQUIRE Attorney for Plaintiff 2024449 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 Velocity Investments, LLC as Successor in Interest to CitiFinancial COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. DOCKET NO. 06-4622 JASON S FAILOR NOTICE OF INTENTION TO TAKE DEFAULT TO/PARA JASON S FAILOR 573 MOUNT ROCK RD NEWVILLE PA 1724l DATE OF NOTICE/FECHA DEL AVIS0: September 27, 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 DON & WEINBERG, P.C. BY: / / / L FREDERIC I. WEINBERG, ESQUIRE PAUL M. SCHOFIELD, JR., ESQUIRE P10D-2 t~ ~ - - ~ ~ ~ ..t:- ~~l p ~ ~ ~ ~ ~ .0 . C> ~ ?=- 1- 6~ 0 ~ -n C1"' .-l C5 :r;. -n ~rC: f1 t F' -r:1~\ \ :nc' '; ~~(~ '-:? 9\ J:::>- N. ~ --' 2024449 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 Velocity Investments, LLC as Successor in Interest to CitiFinancial COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. DOCKET NO. 06-4622 JASON S FAILOR 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 $7,523.16. IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL GORDON & WEINBERG, P.C. AT 215/988-9600. GORDON & WEINBERG, P.C. FREDERIC I PAUL M. S Attorney BY: Dated: October 11, 2006 GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 Velocity Investments, LLC as Successor in Interest to CitiFinancial VS. JASON S FAILOR 2024449 2810 FEB -3 PM 12= 44 aNBERLMD COLM . PENNSYLVANIA COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 06-4622 ORDER TO SATISFY JUDCNT TO THE PROTHONOTARY: Kindly mark the judgment entered November 2, 2006 in the above-captioned matter satisfied upon payment of your costs only. GORDON & WEINBERG, P.C. BY: FREDERIC I. OS? ERG, ESQ UIRE JOEL M. FL NUIRE Attorney f ntiff P005