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HomeMy WebLinkAbout06-71702030924 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 MRC Receivables Corporation as Assignee of Household- Arbor 6851 Jericho Turnpike, St Syosset, NY 11791 vs. COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. Q(„ - ~~70 C ~~,~~~ CHRISTIAN GREENLUND 2408 WARREN WAY MECHANICSBURG PA 17050-7266 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 t 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 indebtedness 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 $2,980.43. 6. Plaintiff has made demand upon the defendant for payment of the balance due of $2,980.43 but the defendant has failed and refused and still refuses to pay the same or any part thereof. 7. Defendant's last payment on account was made on March 29, . ., 2006. WHEREFORE, plaintiff claims of the defendant the sum of $2,980.43 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDERIC I. W INB RG, ESQUIRE PAUL M. SOHO E JR., ESQUIRE Attorney for P aintiff POlA.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. WEIN ERG, QUIRE v( ~~ 1 N ~ « N ~ ~_ ~ - ~:; ~ ~ c~ -{ ? Y ~ ~ _ -,~- ~ - =~ -~ ~.- ~-~, ~~ _,i .~- tifJ -G ' SHERIFF'S RETURN - NOT FOUND CASE NO: 2006-07170 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MRC RECEIVABLES CORPORATION VS GREENLUND CHRISTIAN R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT GREENLUND CHRISTIAN but was unable to locate Him in his bailiwick. COMPLAINT & NOTICE , He therefore returns the the within named DEFENDANT NOT FOUND as to GREENLUND CHRISTIAN 2408 WARREN WAY MECHANICSBURG, PA 17050-7266 Posa~ PER ~.~ OFFICE, DEFENDANT MOVED AND LEFT NO FORWARDING ADDRESS. Sheriff's Costs: So answe Docketing 18.00 -- Service 8.80 Not Found 5.00 R. Thomas Kli e Surcharge 10.00 Sheriff of Cumberland County .00 1 /~ ~f~b 7 ~"` / 41.8 0 GORDON & WE I NBERG ! 01/05/2007 Sworn and Subscribed to before me this day of A.D.