The URL can be used to link to this page

Home My WebLink About06-4677BURTON 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 WORLDWIDE ASSET PURCHASING LLC IN THE COURT OF COMMON PLEAS 9911 Covington Cross Dr. Las Vegas NV 89144 Plaintiff CUMBERLAND COUNTY, PE~N}NSYLVANIA v. NO. ~o -'4~0~ l~ l U ~ ~~ JUDY MAINHART ~~ 2258 Ritner Highway, Shippensburg PA 17257-9754 Defendant CNIL 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 aze served, by entering a written appeazance personally or by attorney and filing in writing with the court your defenses or objections to the claim set forth against you. You aze 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 properly 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 Baz Assoc. 32 South Bedford Street Carlisle, PA 17013 Telephone No. 717-249-3166 or 800-990-9108 76652 III I IIIII IIII II I III IIIII III IIIII III II II I IIINI IIIII IIIII IIII II II II 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 WORLDWIDE ASSET PURCHASING LLC 9911 Covington Cross Dr. Las Vegas NV 89144 Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. /] ~Y~j NO. ~ - l..Gu~~~~ L JUDY MAINHART 2258 Ritner Highway, Shippensburg PA 17257-9754 Defendant CIVIL ACTION -LAW Complaint 1. The plaintiff is WORLDWIDE ASSET PURCHASING LLC, a business corporation, with place of business located at 9911 Covington Cross Dr., Las Vegas NV. 2. The defendant is Judy Mainhart, who resides at 2258 Ritner Highway, Shippensburg, Cumberland County, Pennsylvania. 3. At the defendant's request, Direct Merchants Bank furnished consumer credit to defendant bearing account number 5458000401564733 hereinafter referred to as the credit cazd account. 4. The defendant accepted the credit cazd account by making purchases, balance transfers and/or cash advances. 5. Monthly statements were sent to defendant each month which detailed the chazges and credits made to the credit cazd account for the prior month. 6. The balance due on the credit cazd account is $12,174.47. 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 cazd account. 8. Plaintiffpurchased the defendant's account from Direct Merchants Bank 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 $12,174.47, the defendant failed and refused to pay all or any part thereof. Wherefore, plaintiff demands judgment against the defendant in the sum of $12,174.47 and the costs of this action. BURTON NEiI) & ASSOCIATES, P.C. eil, Esquire for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt Verification Gayle Dixon is Attorney Relationship Manager for WORLDWIDE ASSET PURCHASING LLC, 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: ~J "~ ~1P -~ Name Judy Mainhart 5458000401564733 a n ~ ~~. P b ~- n Z'L1; T;(i ,. ~~ :. T~ C; b O CT a c ~, -~ ~~ rn ~~, ~~~ ~~o ~~~ l:J w ~.. Judy Mainhart 2258 Ritner Highway Shippensburg, PA 17257-9754 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA :NO.06-4677 ~~SW~ 70 C_O~~Q~q`~CIVIL ACTION-LAW 1. 1 was notified of this business transaction. 2. My address of 2258 Ritner Highway, Shippensburg PA 17257 is correct. 3. I disagree my account started with Fingerhut Corporation. 4. I disagree; there were no balance transfers. The cash advances were not deposited into my account. S. I have not received any monthly statements, as well as I can remember, since 2005. 6. I did not charge $12,174.47. 7. I could not afford to pay in full or required monthly payments. 8. I was notified of this transaction by mail. r~ Verification Judy Mainhart is the plaintiff in the civil action. No: 06-4677 ~~~ Da o Plaintiff ~" m ~ ~ ~ itt ~ _r~. ~ ~~-' ~ _. uC~ t--~~,i '~ ~_' -v -~, ~ ~~ ~ rn ~ ~ c~ cn ~ Cs -c SHERIFF'S RETURN - REGULAR CASE NO: 2006-04677 P COMMONWEALTH OF PENNSYLVANIA: COUNTY O:F CUMBERLAND WORLDWIDE ASSET PURCHASING LLC VS MAINHART JUDY ROBERT B:LTNER Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, thE~ within COMPLAINT & NOTICE was served upon MAINHART JUDY the DEFENDANT at 1250:00 HOURS, on the 17th day of August 2006 at 2258 RITNER HIGHWAY SHIPPENSBURG, PA 17257 MEGAN DECKER, DAUGHTER, by handing to ADULT IN CHARGE 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: So Answers: Docketing 18.00 ~,,~ Service 11.44 ' Af f idavlt . 00 Surcharge 10.00 R. Thomas Kline .00 39.44 / 08/17/2006 g jx 1~~ ~ BURTON NE I L Sworn and Subscibed to ( By: before me this day Deputy Sherif of A.D. Burton Neil & Associates, P.C. By: Burton Neil, Esquire ID. NO. 11348 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff WORLDWIDE ASSET PURCHASING LLC Plaintiff v. JUDY MAINHART Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA N0.06-4677 CNIL ACTION -LAW Praecipe to Discontinue To the Prothonotary: Kindly discontinue the above-captioned action without prejudice. Burton Neil & P.C. Burton Neil, Esquir Attorney for Plainti The law firm of Burton Neil & Associates is a debt collector. 76682 ~' ~.~ ~`~, ~ -n ~. -'- ~c, _- ~. _ L,; ) -'fit _ ., :~,; r-~ :-~. '~Y