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HomeMy WebLinkAbout06-4674 .. BURTON NEIL & ASSOCIATES, P.C. By: Burton Neil, Esquire Identification No. 11348 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS ATTENTION FUNDING & TRUST 9911 Convington Cross Rd Las Vegas, NY 89144 Plaintiff v. V ASHALI AGRAWAL 105 E Allen Street Apt 114, Mechanicsburg PA 17055 Defendant CUMBERLAND COUNTY, PENNSYLVANIA NO. 61. - J.it.'llf (!/U~L'--r-~ CIVIL ACTION. LAW COMPLAINT 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 (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 claim set forth against you. You are warned that if you fail to do so, the case may proceed without you and a judgment 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. 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. LAWYER REFERENCE AND INFORMATION SERVICE Cumberland County Bar Assoc. 32 South Bedford Street Carlisle, PA 17013 Telephone No. 717.249.3166 or 800.990.9108 76800 IIIIIIIIIIIIII~IIIIIIIIIIIIIIIIIII 111111 Iml 11111 1111111 111111 11111 11111 111111111 11111 111I111111 IIIIIIII~IIIIIIII~ 11111I1~11111111111~1I111..III~IIIII~I.~III.IIII~. ~ BURTON NEIL & ASSOCIATES, P.C. By: Burton Neil, Esquire Identification No. 11348 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 Attorney for Plaintiff ATTENTION FUNDING & TRUST 9911 Convington Cross Rd Las Vegas, NY 89144 Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V ASHALI AGRAWAL 105 E Allen Street Apt 114, Mechanicsburg PA 17055 Defendant NO. 01- -J./t. ~y (}.iCJ~L ~ ~ : CIVIL ACTION. LAW Complaint I. The plaintiff is ATTENTION FUNDING & TRUST, a business corporation, with place of business located at 9911 Convington Cross Rd, Las Vegas, Nevada. 2. The defendant is Vashali Agrawal, who resides at 105 E Allen Street Apt 114, Mechanicsburg, Cumberland County, Pennsylvania. 3. At the defendant's request, Bank of America furnished consumer credit to defendant bearing account number 4305500342380006 hereinafter referred to as the credit card account. 4. The defendant accepted the credit card account by making purchases, balance transfers and/or cash advances. 5. Monthly statements were sent to defendant each month which detailed the charges and credits made to the credit card account for the prior month. 6. The balance due on the credit card account is $18,186.51. 7. Defendant did not pay the balance due on the credit card account in full upon receipt of the monthly billing statements and also did not make the required minimum monthly payment set forth in the monthly billing statement. As such, defendant is in default on the credit card account. 8. Plaintiff purchased the defendant's account from Bank of America and is now the holder and owner of the account. 9. Although demand has been made by plaintiff upon defendant to pay the sum of $18, 186.51, the defendant failed and refused to pay all or any part thereof. Wherefore, plaintiff demands judgment against the defendant in the sum of $18,186.51 and the costs of this action. BURTON NEIL & ASSOCIATES, P.C. The law firm of Burton Neil & Associates, P.C. is a debt collector. . -," Verification Gayle Dixon is Attorney Relationship Manager for ATTENTION FUNDING & TRUST, the within Plaintiff, and makes this statement on its behalf as to the truthfulness of the facts set forth in the foregoing Complaint subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Date: ~~ [_~ufl- ame Vashali Agrawal 4305500342380006 '...... . ~ (:) iQ.. CIl ~ 1- \ 8- = ~ '(0 = U"t s:: c:r> -or ". ~Fl . rnt:: c: Crt 7'.'" '" '"".-. . -o~ '-.) zr.~ ::n - D (fl.: U1 C) ~ -<' . ~-l..? ~ ~ i::: :P- I -d ,~ " 0- \"' ZC-; ::J:: ~O W >0 om t5 c en -4 ~ Z ~ ::;! .r:- ~ U1 SHERIFF'S RETURN - REGULAR CASE NO: 2006-04674 P COMMONWEA.LTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ATTENTION FUNDING & TRUST VS AGRAWAL VASHALI 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 AGRAWAL VAS HAL I the DEFENDANT , at 1940:00 HOURS, on the 18th day of August , 2006 at 105 EAST ALLEN STREET APARTMENT 114 MECHANICSBURG, PA 17055 by handing to VASHALI AGRAWAL a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Additional Comments PER SHYAM, VASHAIL'S HUSBAND, THIS PAPER"WAS SERVED ON WRONG PERSON. SOCIAL SECURITY NUMBER DOES NOT MATCH. BOTH SETH AND ANTHONY AT ATTORNEY'S OFFICE ARE AWARE OF SITUATION. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 8.80 .00 10.00 R. Thomas Kline, .00 _/ 36.80 v 08/21/2006 'lJ...ulo~ 'Y BURTON NEIL & ASSOCIATES Subscibed to By: f d . ~ / < ~ .J /~_ this day , Deputy Sneriff So Answers: __-r/r?/ // ? ~r~..n:.';..~~t:,f' ~ Sworn and before me of A.D. . ~, Burton Neil & Associates, P.C. By: Burton Neil, Esquire ill. NO. 11348 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff ATTENTION FUNDING & TRUST : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 06-4674 V ASHALI AGRAWAL Defendant : CNILACTION -LAW Praecipe to Discontinue To the Prothonotary: Kindly discontinue the above-captioned action without prejudice. By: Burton Neil, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates is a debt collector. 76800 11111111011111111111I1111I11111111 111111111111111111111111111111111111111111111I11111I11111111111111I111111111111111111111111I11111111111111I111111I1111 m I11I 0 r--) ~ = c = <"" ~ ""tl r:n <- -t dIn :z;aa :r: 0.:0 2:'[.' % -oj;; ,'r" (n':r' -J :ny :.?~ 0 ~(~~': _..je.> '-('" I-~ z.Q ::::>' ...1._ -n ::r: ;)('5 ,:pc.,.! - 6rn . c - ~ -'-I .s::- ?i5 -... ...0 ~