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JOEL STEINMAN, ESQUIRE
Attorney I.D. #62042
MELVYN S MANTZ & ASSOCIATES, P.C.
25 E. State Street
P.O. Box 2284
Doylestown, PA 18901
(215) 348-5200
ATTORNEY FOR PLAINTIFF
AMERICAN EXPRESS TRAVEL RELATED
SERVICES, INC.
JURY/ / NON-JURY/ /
ARBITRATION/X/
ASSESSMENT OF DAMAGES NOT
REQUIRED
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
VS.
DOUGLAS P. MORRIS
NO. ~ft; . 5&&1 tJU;.I \JJ-r"1
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 (201 days after this Complaint and Notice are served.
by entering a written appearance personally or by an 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 judgment may l.e
entered against you by the Court without further notice for anr
money claimed in the Complaint or for other claims or relitcr;
requested by the Plaintiff. You may lose money or property r <
other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU [N
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO, OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FINO OUT WHERE YOU CAN GET LEGAL HELP.
Lawyer Referral Service
Court Administrator
CUmberland County Courthouse
4th Floor
Carlisle. PA 17013
(7171 240-6200
TIll! III AN AftIMI>t TO COLUC:T A DD'I'. AllY DIlOJDTtOM OM'ADIID WILL
81 USa) POll ftAT PUUOII.
.
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JOEL STEINMAN, ESQUIRE
Attorney I.D. #62042
MELVYN S MANTZ & ASSOCIATES, P.C.
25 E. State Street
Doylestown, PA 18901
(215 348-5200
ATTORNEY FOR PLAINTIFF
AMERICAN EXPRESS TRAVEL RELATED
SERVICES CO., INC.
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
Plaintiff
VS.
OOUGLAS P. MORRIS
Defendant
Q~. .n,!./ CWJ r;--
NO.
CIVIL ACTION
1. The Plaintiff, American Express Travel Related Services
Co., Inc. (herein after referred to as American Express I is a
corporation with a place of business located at the World Trade
Center, New York, New York.
2. The Defendant is Douglas P. Morris, an individual with a
place of residence located at 17 Timber Road, Mechanicsburg, PA
17055.
4. At the request of the Defendant, American Express issued
to the Defendant an American Express Gold credit card. and at all
times relevant hereto. the Defendant was the holder of said credit
card issued through the credit facilities of American Express.
5. At the request of the Defendant, American Express
established and issued in the name of the Defendant an American
Express credit card bearing nu~r 3728-766382-61001. pursuant to
a written contract entitled "Agreement Between Gold Card Member and
American Express Travel Related Services Company, Inc.-. A true
and correct copy of which is attached hereto, made a part hereof.
and marked Exhibit -A-.
.
6. As of December 8, 1993, the Defendant used the credit card
and incurred charges in the sum of $2,099,13 no part of which has
been paid, although duly demanded.
7. In accordance with the provisions and terms of Exhibit
"A", the Defendant agreed to pay American Express a finance/service
charge on all sums past due at a monthly percentage rate of 2 1/2%
and American Express is entitled to additional finance/service
charges from December 8, 1993.
8. As an American Express cardholder, Defendant had a
separate account called the "Sign and Travel Account" established
by Centurion Bank pursuant to a written contract entitled .Sign and
Travel Account Agreement". A true and correct copy of which is
attached hereto as a part of Exhibit "A".
9. Pursuant to the Sign and Travel Account Agreement, the
Defendant could elect to extend payment for certain purchases by
charging them to the Defendants Sign and Travel Account and that
the Defendant would pay American Express as agent for Centurion
Bank for all charges made on the Sign and Travel Account in
connection wi th the American Express card issued on the Defendant's
Sign and Travel Account.
10. As of December 8, 1993 the Defendant incurred charges on
the Sign and Travel Account in the sum of $747.85. no part of which
has been paid, although duly demanded.
11. In accordance with the terms of the Sign and Travel
Agreement, the Defendant agreed to pay a finance/service charge on
all sums due at the contract rate of 15.9'. Plaintiff is entitled
to additional finance/service charges from December 8. 1993.
12. In accordance with the terms of Exhibit's "A". Defendant
agreed to pay American Express and Centurion Bank a fifteen percent
(15'1 attorneys fee if the account was referred to an attorney for
collection. The Plaintiff's will jointly incur and attorney's fee
in the sum of $4a7.00.
".
WHEREFORE, Plaintiffs, American Express and Centurion Bank
demand judgment be entered against the Defendant in the sum of
$3,273.98 plus interest at the contract rate from December 8, 1993
and costs of this action.
~:~~ATES' '.C.
BY: JOEL STEINMAN, ESQUIRE
THIS IS AN A'l'TBIIPT TO COLLECT A DEBT. ANY IHPORKA'l'IOH OBTAIHBD WILL
BS USBD FOR 'l'BAT PtJRPOSB.
,
AGREEMENT BETWEEN GOLD CARD MEMBER
AND AMERICAN EXPRESS
TRAVEL RELATED SERVICES COMPANY, INC.
WELCOME TO ^~lJ]lIC^N EXI'IlI'$$'
GOLD C^RI> MEMIIEIl$IIII'
Ple:ase re:d IhJs Agreement Ihoroughly, bocause when you kffp, sign or use the
encICIIl'd Amerlan EJpn5s Gold Can! you agree to the tmns of dlis Agreemenl 1/
you do noll>1sh 10 be bound by !his Agnm1tl1l cut the Can! In half. Since you
askeJ us 10 Issue !he Can!. you an! the Basic Cardmcmber and you ha.. an
aa:ounl wt!h us. You may requesI!h:ll "" Issue a CanJ on your aa:ounl to anod.
'" rerson, and II v.e do,!hal rem Is caJlcsl an Addldon:tl Cardmcmbcr on
your acrount. The lenn Card refers 10 the Amerlcan Expll5S Gold Can! Issued to
you and all oth", Cards Issued on your actounl
USING l11E C^RIl
We v.e1come you to use lhe Card to putthase goods and services from esl:lblish.
ments aa:t'l'Ung the Card. You are responsible for paying:1ll :unounls charged
10 your actounl by either you or any AddiUonal CanImeml>ers, which Irrlude.
wtthoul IImll:lllon, pun:hases, amounts gua~ by use of the Card. and all
ft'l5. You are re>ponsible for paying for any putthase.hm you or an
AddlUonal Caldmember shooM.>d an Intenl to 100111 charge. C\'Cl1lf you hm
nel slgne:! a charge fonn or pl".lellllrl the Can!.
You may net permit any olher pmon 10 use the Card Issued to you. 1f00000,
you are responsible for paymenl of all charges made with Canls Issued on your
aa:ounl t\-en II you h3YC lei someone else use the Card. You agree 10 notify us
al om II the Card Is lost or stolen or you suspect your actOUl\lls being used
without your pennlsslon.
You agrtC to use the Can! only for IegJllnule pun:hzes of goods or services and
not for lhe purpose 01 obtainIng ash from an esublishment. We will not be
responsJblelf any esubliWnent refuses 10 honor the Canl or for any Olher
problen1 you may ha.. with such esubllshJner,l You nuy not nsell any goods
or services obtained with the Card. Tou may relum I pun:1we to an establIsh.
ment ampUng the Canl for credil to your aa:aunlll that establishment per.
mlts such relUms, but not for a ash refund. Rl!f11en1ber dlat outside the
Uolted Stales. returns m usually IIlOI! restrided.
The Ametican Exi'n5S Canl has IW pr!.SOl spmlinglimil Each charr-Is mI-
u11<d In IIgld of your l{"e1lling and plyment patterns on all your aa:ounts with
us and cur alTillales. J'lIIf rxperienct with other cndilOlS, InI your pmonal
"""Ulm known to us. We I!Stnt the rfahlto deny any "'IUf5l lor authorlza.
lion lor a chl'lC lor Iny IUIOft. Wt may abo requesI addiUonallnformatlon
lrom you It 1111 Ume.
MJUmON.\1. C\RtJS
Wtlooal Calm.embers do noc ha>e IlXllUI1lS with us. Any AddiuonaI Card
m., be C1llC!lJ<d by you or us. Wllona1 Can!llssued on your lCtllunl must
be \l'l'd In 1 manner consJslrnl 'Irilh this Agt!CItlCIIl You abo authonzt \IS 10
""-ulS I~ aa:ount witl. M1iUonal CWnemben In the Clll!1Sf of m.alnlJi:tlng
~~,r .('count or, m~,. at our di~'lrtl(l/l, purnle M1itional Cardrnernbers fill
r"~nl Nlh"" own ch"v-s ~ you 1;\1110 rl' tl_ cha,l"'!-
.,~oo,;l"llll'
n.. 1M"oJ P"j( c.ro roe ~ I1S nit 1nnu~1 roe !or t>ch ....htklnal CaI1! on
"",' 1rr~\H'II! It \ n.. ."",,AI r.e for ""II CM1I Is I.......,..] h 1\ J lilt
~,,!.,,<< ..It''''' rI '~1. Pt<>< f.JMnmllwr is outsidt It.. I' S .
i\f:-.fI"C\t (ll ( \Tn r\, \~,n t ,,\Nt U 1.'\ t t1 \\.,
r.~ Cl--i.":! "'" \ ,!..l.~+~', 1~ hnlf' fV't'H'.1 "t~"",\'QlIof nn thfo elm 'tf' \\,,'1
,",,'~ ~~"H j\'r,,-~ '! ,.: '~1' \, '''1''!:t l~~~ ~.f.'T? lh.. u'~q l'.vd "'.1~""'5 11',tl ;\t
. .
will conl/nue 10 do so unul your aa:ount Is canalled. We will bill rwewal
ft'l5 for lhe 3ttllunt annu:1lly at the ralelthcn In dfect.
The Canl remains our propel1y and we may moke your right to use It at any
Ume. We can do IhIs whether or not you have breached the A~ and
~;Ihout giving you nollce. If we I'eYOke the Card and you h... not bre3ched
lilt Ag""""""l ~ will munt! I portlon 01 your annual Canl fee upon mJUCsl.
We may advlse establishments acapIIng the Canl that the Canllssued to you
hllS been cancelled. If ~~ cancel the Canl or 116plres, you may IW longer use
II and you musl relUm 1110 us or,lI we reque5llo an establishment that
aa:rpls the Card.
If you ask us to cancel your aa:oun~ but you conUnue to use the Card. we will
consider such use as your request for ml\llalement of )'Our aa:ounl II ~~
.gree to relnslate your accounllhls AgreemenI or any amended or new
Ag_ "" send you will govern your mnsbled aa:ounl When "" mn.
st.,le your aa:ounlwc may mnslate any Mlillonal Canls Issued In connec-
Uon with your accounl and bill you the awllcab1e annual feels).
1',\ nlENTS
Paymenl far all charges Is due lnunedlalely upon l'CC!fpl of the billing stale-
ment "" mall 10 you. You must notI/y us lnunedlalely of any change In your
billing UIrm Tau must pay us In US. turm1CJ, with a drafl or a ch<<k
drawn on a US. bank and payable In US. dollars. or lrith I negotiable Instru-
ment payable In U.5. doI121$ and demble through the U.S. banking system.
If ~ d<<ide to acapl paymenI made In some other form, !'OUr papnenl will
not be credited until It Is conmted Into one 01 the fonns described in the pre-
Yious senICIlCC. We may charge !'OU any C05ls "" Incur In ClllMlllng your
paymenl If any paymenl made on your aa:ount Is not honored for Its full
amount. "" may charr- your accountSI S to cover collll:tJon costs on that
rarrnenI. unless otherwise p/1l\'idrd by the law of )'Our ,unsdkllon.
lI'e may acapelale paymen~ partlal payrntnts or any payments marlted IS
being paymenlln full or as belnllel1lement of any dis!>ute without losing any
01 our rfghts under this Agreement or under the law. 11 "" aa:epl such Jl2Y'
men!$, this dce noc mean we Igree to change this A&reement In any way.
You agree to pay all court C05ls plus lII\omey's fee oflS'll 01 the then Ul1JWd
blll.nee If we must ..M ,...r ICtOUfllIo an IUomer who Is nol our entdoyoe.
subjta 10 the law 01 your IurisdldJon.
UTE tITS
Wt wtIlllnd pou I billI"lllllrmtSlt _the lid 01 ncIt bllllPl DGlod (lllI!r'
nIs 01 ~ one -"). EaclI biDlnl slalI!mat Will kImlIIy I
"thln& Dale', which Is the cul4 dale we delemdue lor IlI:Iuolna dtar1e
and paymrn' lor 1haI billing pmcd. II charg!s on I billln& staIemeIIt
mnain unpaid. tit may _ . bit k Tbe amount 01 the 1ar.1lt ~
on the Irtll'h 1I UIllt your KOlIIlIl has remalne:! ul'4'-'id and the atinss to
""iihJ'lllfbtlllssmt
A If ,.. ",,,,,,,m lel:\11inll!lOP.!hJll110 Is U'1'3id lor roo bUllng pert.
ods.Ii"! lale roe.." be the Ctnltr oIlZO or t S\ of all amounts
u'1'>id for 11 lr:\llont billing pmod
~ 1/.., ,"",,1m ~~ tIl,., mll1t th.., 110 Is u'1'aid lor mlft or ""-'"!
h.ih"H"n\h. II,. b:. r.e..,1I ~ lhf l"'Ut'f n1111 (If : \... 01 all
,\jn(w\;) HlT:!iJ (I" .lIlt~t mw ~Hifll ~\1
r l'";,~,,,,! -.1':.. f,..... l'~'-ll;' . v~t f1 ,ff~"~. t!W' rnH\~"ftt ~ "..,:1 r...
r"'.......1 -., ". ,_:,,1-., "1'( to! \"'\'~ m !h~ hl\'\\T2 \: ll~ ,~!,
2/1'f amounts unpaid for I'M> or mOil! Mllng perlcdl: 10W3-1.61r.;
LouIsI:\Ila-l%; MJdllg3l1, Ta:lS-1.5%; MisI~(11l-~ter d II or
2.5" (150 nux.); North D3kDu-1.75%; V1rglnJa-2.IX Mmadlll5Clts
and Wlscomln Canl3CCO\Jnts wiD be ~ 1.5" and IX, ~veIy,
only on :unounts unpaid for \Me or ~ billlng~
D. If any amount Is unpaid for one billing period and remains unpaJd for
mOil! than 19 days 3fler the ClosIng Dale oIlhal billIng period bulls
paJd befoll! the nat C105lng Dale, the lale fee will be $12, and lhe fees
descrlbed above do no! apply. This $12 lale fee does not :ll'l'ly to
ucounts In Califoml:l, lOW:!, Louls13l1:1, Mass:achu:setts. Michigan.
MJsslSSll1'I, North Dakol:l, Tws, Virginia and WIsconsin.
Once "" ha>!! added alale fee to your billIng stalernmt. "" may conUnue
10 do so for :IS long as your account remains unpaid.
USE UI' (,:,\SII ,\NIl TIlAVEll:RS U lI't~11E
IJISI'I'NSIN(; MM.IIINES
We oncouragt you 10 enroll In our Eq>ress Cash Program, and ~~ ~ill send
you 1 spedal agreemenl concerning use of the Canlln connettlon with thaI
ProVOJ1l. The fee for using the CanlleI obtain ash from 1 dJsrenslng
mxhJn.ts the gJnler 01 12.50 or ~ 01 the Ir1ns1c\Ion amount. "" to 1
muJrnum fee of $10.00. A 1% commfsslon Is dwged for Travelers 01eque
purch:lS<S.
CIlAI\( ac' MAllE IN rOltl'I(;N C;l'IUUNc.II~S
If you locur a ch'fie In a fomgn curmlC)', "wiD be conm1e! Inlo u.s. dol.
1m on the dale Ills processed br us or our agtllts d I rale set br II! bad on
an Interomk. Iourisl or (.ttm 1I!Q\I1n!d br law) offictal rate,lncrezed In
each InsUnce br I~ This rate lIl2ydllfer from rate In eBa:t on Ihedate of
your charge. Chuges comerted br establ1shments (such 1l airlines) wiD be
billed 31 the rates such establishments use.
nENITns ANn SUI\'ICT.s
Subject 10 lhe law d your Jurisdlctlon. we II!!efYl! the rtghl to add. modify or
delete any benefll or seMa! oamd with the Canldlny Ume without notice
to you.
INSIIItAN(:(,
If you use lhe Canlto pay II1SUfUlCe ~ums, you &i" us permJl.1lon 10 pay
those pll!R1lums lor you when due. You I~ lei '"l'lY us xcordInglo the
terms of this AlIft'I11elll You Il1USllfll us In wrlUnglf you no Ionr-r wish us
to pay any pmnJums for you. If your aa:ount Is amlled. 1Il! will !lOp pay.
Ing those ~ums for you.
PRIVACY
c-wn.r Rt(>crls
You IUthort:ze III and our afIlli3ll5 to make ..hateoerCll!dltlnl't5llg~lons '"
doom lIl'fq'f1ate and 10 obtain and 6dw1gt any InlomwJan '" may
ruf..lrom Clll'l\\IIlIer II!plIIS and Olher IDUIl!S.
ll'e may ask CllrlIUlller "I'O'1lng qendes lilt tml\\IITI!f rq>aIU of your adl
hismty. Upon mpll5l. 1Il! IIID l!lI you whether I CIlIIIUI!ll!r "110ft..
~ and the nant and dhsa oflht lIftlCT Nt fumlslled ..
l~atIon r:onctmlnl your lCt'llUIlI may be Iumbhed br 11I10 ~
"t""'Jngl~ ~I:s or other CII!lllton. If '" &.r..",drlt dill yollI
lCtt!\J1l11S past due. adwmt mdit INonnatlon may II't'flI on your __
t"umff ""","Ind the C'Jl"SUllIe "'I"'fb '" any M1iUonal CWloto,.!>.n 11ft
~ltl:t'\Jnt
I-;{"..,,,IW. f'tmu.J 111 ~....
'It ""Y e",lun<<t Iny lnforn\3!J"" '" rm1\'f ohmd !l'U Wlth cur 3/!,Il~
"..h.t~. "" ClI'<tt Of other Inflll1l1$lon '" nut oI-IlIn '""" """ '4TI~'
!ii'" Ofi't.1f\U.tl!lf'f"-'f"Cft1
;~.J.c,,-t j~'l'tltf~'!f
r ~ f;f!" !~ lifn" ...,. m]\' t'!lN\ltf'f tfflt'"'fW t-lib ~ l"'U .,., \M'tl"'" ~l
(l1"l'~~;t'"'!J..~ ,1''': \~, 1;1 .l'.~'t!'!' !Itf' '~1111!'i '..{;"\d (w.(''f'l.,- c.rn'l"
Mailing lislS
We may use Infonnallon you have provided 10 II! on your InlUaI awllcallon
and In surveys.lnformallon derlY1Xl from how you use the Caroand Infrirma.
lion from extern21 scun:es. Including consumer reports. for m:uketJng actJyj.
lies (Including mailing 11s1s), br us and our :Ulillales. We may also use Infor.
matlon derlved from how you use the canI :and non-cll!dlllnfonnallon avail.
able from publIc soul'C15lo develop mailing lists ..hlch :Ire US<d br comP:uUes
..nh whom ~ work 10 delllop offen you may recehe throul!h the mall. If al
any time you wish 10 have your name and :addn5s removed lrom such Ibis,
please call 1.800.321.2111. .
( II.\N(;IN(; .IIIIS Al:JIEF.\IENT-ASSIGNMENT
We ha>!! Ihe rlghllO ch;&flgt this AgII!l!Illel1l.1 any Urne. We will notify you of
;&flY ch:lJ1ges. We consider Ihal you have ample! the ch;&flgel If you keep or
use Ihe Canl :after ~e send our noUce.
If you do no! aa:eplthe changes, you m." tennlnate this Agreement br cuttJng
the Canlln hall :slid nolifylng II!. We will then refund a portion 01 your ;&flnual
CanI fee. You will sUII be I'e5pOnsible for all fees and charges rule before you
IennInalro lhe Agm:menl
W. mlY assign this Agreenent :at any lime To1thout nO\kle. .. ..,. ,i... .
Al'rUCA.BLB lAW
this Agreemenlls governed by the 12" or the Stale orNe... York
ud "l'pllable rederalla....
AMERICAN EXPRESS
TRAI'EL RElATED SERllCES COMPANY, INC.
~Skillem :r I II J~
ConsumerCWGroup /' ~ ~
SIGN & TRAVEL ~ 1\
ACCOUNT AGREEMENT
IIIE W;N ,\ TIt.\\Tl ACCOUNT'S NOr AVAIUIlLE
(IN.III.~11 I'll n IllltECl'lVE NUnrlCATlON FROM
ll~. AFllR YOII RECl'IVESUClI NtTI1FlCA\10N
IROM \I~, .'III~ M;!tEEMENT A"I't.lE'l 10 YOUR USE
\ 'rllll' AI .COIINT. l' iii Tl'IL\I~ ^Nll CONDITIONS GOV.
I.IWIN\; IIIL SI\;N 3< .II(,\HL ALI.:UUNT A1U; SET rOIlTII
IN .\1115 ,\(;RITMI:NT, AND UY nECI1NG TO USETlIE
Slt;N ,,, "IIIAHI. ACCUUNT, YOU ^GR1:E10 DE DOUNO
IIY IIlIS ,\(;nl'l'.\lrNT. I'Lr,ASl: RE.\U IT C^RUUllY.
1>1'Stltll'nON UI' 11 IE Sn;N A: 1 ItA va ^CCOUI'IT
The SIp a TrMI Aa:ounlll aIrored br Inot\atloII only h III deImed
paymtnllICtOUftI cffftd br Anwrlan F.I;ms ClnturtoR Bank (the
-e.nn h pennUs you to defer ~ lor alrllllt llckels. cruise ship
Ikkrts. Pnt'1Id lour packares and Illy OIher lrllU.11rol delgntted ~
lhe 8~n\. To rlfdlll defer pl)'!lltnl toy uslnl the Sign A Travel.lcrcunt,
'fllU must :l\lIobf l~ Irmllgtnt. alrill1\'. and other mmh.nts L~.I 'fllU
""-~ 10 do so .hffl Ii.;n. l"ur 1I:tmlnl nun*" [or r.>mmt II I~ Ilmf
cllhe pun:h.\ll'. or h 1oll0000I other pm:f\1um prmlln.d l>, the BJnl
AllY rhlfO"5 ..hlrh Iht ~.\Ilk d,'I'l "'" i"""lllo bt ,ltftlTfll unOO tht
~'l" .\ TI ".l \-':OImt Of '0, Ol,,","tv t1lclNe rh.,l"S ~hkh l"u h "f
r," "i~"'tf'\t l(l tM.-r ",'~I tv t-l::.,i t:!'\i-T thf t-r'ntti ......'t"t!Hn<< ~Hf
"j'~f1n f.....~!. f 1m ."l'':''\)111 Hl'f -r,t..'d ,":n~.ffit-)
, I' ,. ,I. . -I __'" ..r f, ..~, ., "..,..1
, ''I I'? ~r'-:~' :' ,to. t i"'\~"( 1" 1.;'''''''''5: 'J~;'--'-':l" t- .1, "} ,"' I. ",'
t - '>"('! .. i., " ' .!.. "_,,",, ' ,..",,,,. t, "....<Ii \.>,1 ,~,Lf"! ',..'lIt; It Wi
'\ ", ".-.; .>.. T ,", "'" .........
as amounts charged 10 your Sign & Tr;\Vcl.lccounl by any AddIllonal
Cardmember on your Canl.leeounL
You agrre 10 use the Sign & Tr.wd krounl only for leglUrMle purchm 01
eligible goods or SCJVItl5 and nol lor the pulf'l5e 01 oblalnlng cash or Indl-
glble gooh or ltMtl5. You also agrre to use the Sign & Tmello:ount for
~onal, lamily or household purptlll5 only. You may not resell or return
for a ash refurxl any gOOlh Of SCJVIa5 chargulto the Sign & Tr:lI"el
lo:ounL You may return a pUltha 10 an esl3bI~lunent IOf credit, ~ thaI
establishment permits such retums.
2. OTIII'1l ^rI'UC^lllE TFIlMS ^NIJ (.( INI JlIIl IN~
The Card .Iccounlls ~ by the pI<\1ous agreement which Is lnJed
"Agreement Bet.le!n Gold card Member and Amerlt:lll Ex/'re!S TmeI
Relaled Services Comvany,Inc." Some proYlslons In thai a~1 also
awly 10 lhe Sign &. Travel krounl The provisions which awly 10 Ihls
Agreement an! he3ded: Using 11M am~ Paj'mtnts, OJarges MatH in
Foreign Currmoes, Prit'l1cy. Please refet to those provisions as you
re3d this Agreemenl
3. DIlliNG SHHMENT-MINIMtlM 1'^nIENT
fou will receIve SIgn &. Travello:ounl statements from the Bank when
you receive your bllllng statements (or the Card Account American
Express Tr.lvel Related ServIces Company, Ine. ("TRS") or lis allillates
~;n act :IS the Bank's agent for purposes 01 billing. Strvidng arxl collect.
ing your Sign &. TmeI Account am wtll act as your ag<nl for purposes of
rectfving your Sign &. Travel Ao:ounl paymenl
Each Sign &. TmeI Accounl sblemmt wtll show lhe Minimum Payment
due upon your receipt 01 that statement The MInimum Paymenl
&p.nds on the amounl Ii the "New BalancI!" shown on your stalemenl
Generally. your MInimum Paymenlon illY stalemenl 'IIl1l be the greater
of $20 Of 1/36 of the New Balance shown on your staten1tnl, plus any
previously billed Minimum Payments tIut lm1aln unpaid on the Cklslng
Date of the stalemenl If your New Balance Is less than '20, your
Minimum Prfllltnl v.1D be JOUr enUre New Balance. 01 CQU1';e, you
a1W3~ haY! the I1ght to pay any amount gre2ter man the MInimum
Payment, up 10 and Inclllllng the WtaI New Balance on your stalemenL
at any lime.
4. COST 01' CREUIT
.... fln= charges begin to aa:rue for neb charge as of the cble the
charge Is Om posted 10 :~~ & TmeI Accounl ~,no
Onance cIw1es wiD be In any blllln<< perlod In whkb you
lJt&In the billinl period wlth an outslandlnl Sign & TmeI bal.
II1tt, Incur no new d\ari! and you fuDy pay any outstandlnc
charge before the C10slnl Date.
txcepllS proYtded In 5<<1lon D below. \he dally peI10dlc rate for
Sign & Tme c:harlfSls bad on an ANNUA.L PERCI.'rrAGI
IlATI which may be lllIustsI semI.annuall,. The A."fN\W.
PUClNTAGIIlATlIor all bllllnc pertods endlnC duMl any
aImdJr half Is MIl"'"" by aGllnc ,,, 10 the "I'rime Rail" Clft
the last buslll5 d2y Ii llle lhkd llIOlolh pnad\nc!hl! almbr
half. The daily pertodk rail! fur erl !limn& period b Il36S1h of
lhe A."iN\JAI. PEICENTAGIIlATI for that billlnc period.
rounded to the nurl5l one I!n~ of a pen:mtace poInl
The !!iecl 01 an In<mse In lhe A.'lNU.\1. rElcro.'GIIl'l'I
may be ~~ hKrf':lSe the amounl of the Minimum payment due.
fer the r"lf\'S'5 oIlha AI...emrnt.lhe -rr\ll1e RIll.' Is b"" me cI
I"l~t P'll'hd'.a.,""'-"'<l'Il1S lhe ~.~ '* on ~ IIlw 11
11,.. US...,.,..,. C!l'1I'f {OO\fl1f1rl'll banb, as put'lWwd In iN
>rlil ~ "Nndi If Il1<!I'I! than _ rrtll'of Rate Is "" ('\Jblts.~
..... m;tv ~."" h!gNst of "..h r,lm, R_ I. t~ I'l'nt l'cll
71>of' lr.',,! ~~---~'f~,*,:.~J ('t]....,'5~' t.fl4>!b~t N l~ h' ruH-!\h
lhe Prime Rale, .~ may refer 10 Ihe Prime Rate published In any
other nMpaper 01 general drculaUon In New York, New York, or
~ may subsUlule a slmllar reference rale at our sole discmJon.
B. If your bilUng :dltess Is In CO, IA, NC or PR the monthly per100ic
rale '>ill be calculated as described In Soctlon A above but wW nol
exam I.Sx, which Is a corre;pondJng ANNUAL PERCENTAGB
RATE of 18% for Sign & Travel charges.
C. If as of 6/3011l8 the credllor lor )'Our Sign & Travel krount was
TRS and you have nottherealter reduced your Sign & TmeI
.leeounl balance 10 ll!nl, your account v.11l be handled In actOr.
dance with the special rules previously provided to you. .
~. ^\TIlM;E "^ILY 1I,\IANCE ~u;ntOI1 rOR
eM.r :\lIX!"lON OF nN^NCE CllARGE~
The dally peI1od1c r.ltes listed above an! applied to the "Average Dally
Balance"ln lhe Sign & Tr.lvel Account during the blOlnc C)'Cle covered
by the Sign &. TmeI Account statemenl .
The Averag< Dally Balance Is delermlned by taking the lJt&Innln& bal.
ance of lhe Sign &. Travel Account uch d:ry. subtncllnl any p."".,."
or aedJts and adding any new SIgn <1 Tr.I..J charges and unpaid
On= charges (except Ihat Onance charges ~;II not be Included for lI5-
idents oIeo,lA, NC, and PR). ThIs Is the dally balance. Then, the dall,
balances for the billing peI10d an! added and the total Is dtvide! by the
number of days In lhe billing period. ThIs Is the "Average Dally
Balara." To calculale the OnatlCt charges for a bl\llngperlod. 'Iol: mulU.
ply the dally perlOOic rale by the A~L Dally Balance durin, the billing
peI10d and mulUply the resulUng n by the number of days In the
billing period. This mdhod of aJculadng lhe Avenge Dally
Ba1:uKe mults In compounded Interest, DCept In lhe states
referred to libel... .
(, AI'I'UC^'ION OF 1'^ YMENrS
Your payment wtD be awlled In the followin& W2f. OISl, TRS will awl,
JOUr payment to any Slgn & Travel Ao:ounl MInimum Pa}'ll1ents
(Finance CharlfS Om and then prlndpal amounts), and then to any
balance on the Card Ao:ount If your paymenlS an! past due. TRS may
awlY them dlIJerently from the manner lust desaibid. If there an! any
amounts left <M!f a&r aroIyIn& your p2JIIllel1l. TRS wiD assume 1hat you
w:l!llto ~ the outstandIn& balara (~ any) on the Sign & Travel .
Ac:oont and TRS will awIY any e:ust payment annllndy. If 1"" do nol
w:I!II TRS to awIY an e:ust payment to ~ the outstanding balara on
the SIgn & Tme!<xounl, you must IelI TRS In -.nUng.
Cndil balances an! trearal dtlferently from payments If you hm a
aedJt balance on the 51&0 &. Trmt Ao:ounL TRS will mume that you
WllnllO hm Olat aedJl balance transfemd 10 the Card Acrounl and tIIll
any cndit balance on the Card Account should be used to pay 51&0 &.
TmeI Accounl Minimum Pqmma aM balance on the Card Accnunl
IS they beallIle due In the ~ decribed a- In l!lIs sedJon. II
you wart TRS U UII! a aedII balara to pay !llOl! than the MJnJmum
I'1ymeIlI U Clft 11111! SlI" & Tme Accnunl, you musllell TRS In "riling.
Fer ICtllUIIlS wttlIa dlnr:t dSJil ~ the SIp' & Tme Accounl
Mintmum payment and the balara on the Card Accounl ,,;11 be auto-
matlc1l1y transftmd neb monlh from your bani accounl If you wtsh
to p~ !11M! than ~~b amount you shou~j COlll.1d m
. ""'" """ "H,\~.(-lll....lItY'oj
In illlien hJ lOr othe, actions ~ mar 13;.e undrr this A~~t. IlIt
S'l" a rmel "'--ceunt mar be ~ '" uncellal at ~~e 83.ok's llll,
"fllon. for ,.. ....on, sulliocl '" ~kJhle 11... Jl anr Ull1l' '"~~ or
....rMld caU'll! 1I1d ,..;lhOln Ill'inl "'" rmlb.... My sudI act!en en the
h"kl r"' ",:llIlft rJOC1'i~... rNil1Unn lo r.\Y ,"" rnn.-w:d ~:U>ln.
h-Ur,.,"f d\.\fj"S If\l.t t~htr l~JfJ""S du~ on ~tj.r S'~l\.\ Tr Ivtt ,",,-'("I.lnl
tit,," IN trf!p,\ ,i tNo'~~'flI'>nt iO ~~Y11t tilf tilTlf t'llht t.t:~H.t!it'"
:'f ~;I'l"'"!';"'1;'rt:,1 r-'1if l\y,;..;nt
In addIUon, ~ your Sign '" TrM! Aa:oun~ your CanI Aa:oun~ or any
other :account you may have wtth the Bank, TRS or any 01 their alIllI.
ates Is cancelled or Is not paid In :accordance wtth applicable tenns, or ~
you are Insolvent or unable or unwilling 10 pay your debts, lhe Bank
may requl~ InunedJale payment 01 any charges JllU may have elecled
10 charge 10 the Sign '" TrM! Aa:ounl
fl. lINt\UIIIOIll7.U> CIlt\R(;E.~
Any Sign '" Travel Charges mu by a Canlmemberwho Is not mUlled
10 U!e the Sign'" TrM! Account will be transferred 10 the Card Accounl
and lhe Cardmember will be required to pay thaI Charge In lull when
due under the terms and condlUons 01 the Card Accountagreemml
9. No-IICFS
An, notice glYtn by the Bank shall be deemed 10 be glYtn wlmt cJer.osil-
ed In Ihe United Stales Mall, postage pl!pald, :IlIdmsed 10 you at Ihe
latest billing address shown on the Bank'sltCOllls.
to. CIJANr.E UI' TERMS-ASSIGNMENT
The Bank may assign Sign '" TmeI Accounls to any other Gnand21
InsIlluUon 1II any time and may change the terms at this Agreemmt at
an, Ume. sublett to II'PIIabIe law, IndudlnC chanl'" which olIett
wsllng b21ances or Onance charge r:ates. The Bank will notify you 01
any changes.
II. c;OVl'ltNING lAW
This Agreement Is go..med by Delaware Jaw.
nm roUOWlNG NOnCES AIUl REQUlRED BY lAW
WAR."lING: nlll TER.\IS Of TIllS AGRU.'IlENT MAY BI
CI","lGED, 'filmIER Oil NOT AUTlIOIUZED BY AGIlUMENT.
IN ACCORDANCE W1TI1 A1'I'UWU lAW.
NonCE: Any Irlldtr 01 this conlumer credit conlral1lssubject 10 aD daims
and Menses the dII:olor CllUId assert qaJnst 1he. 01 pds or Iel\m
obcaIned pursu.1fII hemo or w1lh the pRXI!!IIIlmoI. RtI:lMrf hereunder by the
ddllor shall rn eJaIId amounts paid by the deblor hereunder.
IJI.ERJr:JJI OPRFSS cnmJRlOH BNlll." I. IJ .
~~PJ~ -'~ ~
To AMERICAN EXPRESS
CARDMEMBERS
IN THE U.S. AND
ITS TERRITORIES
YOl"R DlLUNG IUGlm-KEEP TIllS
NOTICE roR Fut JRI! USE
Thb nctkt conUlns I~ lnfomur1on aIiIlut)'OUt naha and ollr
!e{"ftSl!1tllUes U11drr the f Jlr Credit BIlling Ad.
NOTIFY 1.!5 IN CASE OF FRRO~ Oil
QI.!F~ll(lNS .\OO\';'I' \Ot"R Dill
If "'" 11~"k ""'" 1>1111$ ''"'OJ. Of f "". nftd '""'" infOlm3i~!Il """'II
trin!J(tlf'" ('11 r'\llf ht .,n" ~ ('n J ~V1f' \M-t nf r1f"'f It rttf' 1l\~
!N !-,,,;.,& t"~.r\lfh"S li<l...t 1"n f"'lur ~in Wntf t!J 11'\ 15 H\IM 1! rt"".Sll'!1'" 1"~
must hear from JllU no IalCr than 60 d.1}'S aller WI! Ieflt you the Ont bill on
which Ihe enor or problem appeamI. You can telqlhone us, but dolng so wtll
not preserve your nghll.
In ycur leller, give US lhe lollowlng InlormaUon:
. Your name and ao:ount number.
. The dollar amount 01 the ruspected error.
. Describe the enor and explain, ~ you can, why you beReof the~ Is an error.
II you need mo~ InlormaUon, describe the lIem you ll1! rn su~ aboul
II you have authorized us 10 pay your Amertcan Eap~ biD Iutomatlcally
lrom youmvtngs, checking or other accoun~ you can stop the payment on
anr amount by noUlylng us orally or In writing at any time up to three busI.
ness da~ belo~ the aulomatlc p:tymenlls scheduled to occur.
YOUR R1Glm AND OUR Rt:SPONSIDIUTIES AFTER WE
RECEIVE YOUR WRJlTEN NOnCE
We must acknowledge your Ieuer w1lhln 30 days, unless we hm corrected the
mor by then. 'rUhln 90 dal'S, .... must either correct the error or espIaln why
we belieoe the bill W2I CDm!d
Aller.-e recehe""" 1d1er" cannO\ try 10 collect any amount you question Of
~ you as delinquent. We can continue 10 bill you lor \be amount you
quetion, Including finance charges. and we can apply any unpaid IIflOIlnl
against your credit Ilmil You do not ha..1o pay any questioned amount wbIle
we are InoesUptlng. but you are Il!Il OOIlpted 10 pay \he parts 01 your bill that
are not In qut5l1on.
If WI! find that " male a mlst2ke on """ biD, you will not hm 10 pay any
Onance charges rebted to anr questioned amount. If we dlcInl make a mis-
take, you may hm 10 pay Gnance charges. and you wtll hm \0 make up any
missed payments on the questioned 1fIlOUnt. In either ase. we w1111ef1d you a
>tdb...-nt 01 the amount you _ and \be date UulIIs due.
If you lailto pay the amounlthat we Ihlnk you owe, we may ~ J'OU as
delinquent. noo-r,' our explanation does not AtIsfy you and you wrfle 10
us withln ten days telling US that you 11I11 refuse 10 pay, we must teI1 anyone we
n;>ol\ you to that you hm a question about your bill. And, we must tell you
the name 01 anyone '" n;>omd you to. We must I!II ~ we r!pOlt you 10
Uw the maIIfJ Ius hem ll!IlIed bit-.- US when II 8na11f Is.
If '" don't Iollow these rule. we canl collect \be 11m J50 01 the cp5l1oned
1I1\OUnl. tftfl ~ )'OUt bill Is comet.
SPEClAl. RUlE FOR CREDIT CAJlD PUROIASES
If you hm aprOOlem with thequallly oIprll1lff1yorllr'licfs that you pur.
chased wllh a mdI1 card. and you hm tried In good bI1h 10 comd the pni>-
!em with the merthant. you may hm the ncht not to pay the renalnlng
amount due en ~ or rmlca '\1ler-e 111M IimltalIons 10 lhIs ncht
(a) You nut hm madr 1he purdlet In your lane... or f not wItIU
your lane ... wllhIn 100 mils 01 rour CUfftflI maIIna Iddns. and
(h) The purchase pm must hm blI!IIllIOft thta .so.
Thee 1lmItatIom" not Qly f", _ or aplnIt 1he ".... b...... or f we
II\IlIed you the ..t...tbdI...t for the prllIlffIy Dr......
IloCt for OWe anl4CllII
The OhIo 1M IpInst ckr1rnlnlUon ftqUIre \Nt III CftlkwI mW mdl
tqual!r PtlIJbIe to all mdi-"'r tIIStomftS. and 1haI cndt ft'tlOf\Ina a1"".
de nulntaln wranlt cd hfslorie on radllrdvtdual uron ~ Tht
ct.1o CMl Rlaha CornmlslIlfI alrnlntsttn toqlllll'd wllh Ihb law
I'loIt lor herttt ake Carll I I."
If "'" tilslllIl '"\"t the u.<i,,",tft ,\penl'nI1nd the Sill' A Trm!
.\..rnllnl ~ In ~_h. r/nwCllflUd III
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SHERIFF'S RETURN - REGULAR
CAS~ NOI \~96-0~66\ P
COftftONWEALTH OF PENNSYLVANIA I
COUNTY 0..' CUftBERLAND
~~~~IC~~ EXPRESS TRAVf,LRf,~~T~
VS.
ftORRIS Q.OUG!.~..!>.. ~_...
.J.IIlOTHY REITZ ._____.._._.._.....___J Sheriff or Deputy Sh.riff of
CUftBERLAND County, P.nn.ylvania. who b.ing duly .worn according
to law, .ay., th. within COftPLAINT AND NOTtCE wa. ..rv.d
upon _I1QRBj~UGLAS P th.
def.ndant, at 2038100 HOURS, on th. -!1h day of Nov..ber
\922 at 17 TlftBER ROAD
!J~CH.t.JU.!!..~G. PA 17'~~ . CUIlBERLAND
County, Penn.ylvania. by handing to RICHARD 1I0RRIS. FATHER
a true and att..t.d copy of th. COIIPLAINT AND NOTICE
and at the .... ti.. dir.cting "ia attention to th. cont.nt. th.r.of.
.
.
.
Sh.riff'. CO.t.,
Dock.ting
S.rvic.
Affidavit
Surcharg.
11J.00
3.72
.00
2."
So an.w~ .'
r:~ l~Ce;~
H. ThO... In., er
.~.7~ nELVYN S IIANTZ
11/06/1996
by
or
Sworn .nd .ub.crlbwd to '.for. ..
th\. ._"" ~ _ d.y of 7.~.....J....__~
1'J'IL A.D.
{ \
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,
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~ry~t,...
the filing of this Praecipe, A true and corre
pursuant to Pennsylvania Rule of Civil
attached hereto and marked Exhibit "A".
JOEL STEINMAN, ESQUIRE
Attorney for the Plaintiff
ANDNOW," 'latJ4,~ /3 ,/qt;k, , Judgment is
entered in favor of the PIa nt ff and against the Defendant by
Default for want of an Answer and damages as~e se at the sum of
$5,717.87 plus costs as per the above ertific ti
~
AR
THIS IS AN ATTEMPT TO COLLECT A D
BE USID FOR THAT PUJU'OSE.
JOEL STEINMAN, ESQUIRE
Attorney I.D. #62042
MELVYN S MANTZ & ASSOCIATES, P.C.
25 E. State Street
Doylestown, PA 18901
(215 348-5200
ATTORNEY FOR PLAINTIFF
AMERICAN EXPRESS TRAVEL RELATED
SERVICES, INC.
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
Plaintiff
VS.
DOUGLAS P. MORRIS
Defendant
NO. 96-5661 CIVIL
CDTIPICATB 01' SnVICB
Joel Steinman, Esquire certifies that he is the attorney for
the above named Plaintiff in the instant action and that on January
17, 1997 he served a true and correct copy of Plaintiff's
Interrogatories in Aid of Execution and Resquest for Production of
Documents by mailing the same by regular mail, postage paid, to the
person(s) and at the addressees) set forth below:
Douglas P. Norris
17 TiJlber Road
Keoh.fttc~, PA 17055
, P.C.
BY.
JO rUNMAN, Esqu re
Attorney for Plaintiff
,
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O~ . fllED-OFFlCE
, T,.I:" f~;')TH:'N,)TNlY
97 API? -2 PH 2: 38
CUMi-i::hLi. '0 .... '"
FcNNSYr.VJ~\,~IY
J/.} '17 &,/. ~~ .IH~~ 4. ~
V';J f? ~' ~ ~ df!'
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&- "\..."n"lr.
.
APR () B 199711Y
~
.. .'
.
JOEL STEINMAN, ESQUIRE
Attorney I.D. #62042
MELVYN S MANTZ & ASSOCIATES, P.C.
25 East State Street
(215) 348-5200
Doylestown, PA 18901
ATTORNEY FOR PLAINTIFF
AMERICAN EXPRESS TRAVEL RELATED
SERVICES, IN:. Plaintiff
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
VS
DOUGLAS P. MORRIS
Defendant
:
NO. 96-5661 CIVIL
ORDBR
AND NOW, this 9'" day of A...." ,1996, upon
consideration of the Plaintiff's Motion 'to Compel Answers to
Discovery in Aid of Execution, pursuant to Pennsylvania Rule of
Civil Procedure No. 4019, it is hereby ORDERED and DECREED that
DOUGLAS P. MORRIS serve upon Plaintiff full and complete answers
to Plaintiff's Interrogatories in Aid of Execution and
Plaintiff's Request for Production of Documents in Aid of
Execution within twenty (20) days of the date of this Order or
suffer a sanction Order as may be entered by the Court.
BY THE COURT:
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND :
Joel Steinman, Esquire, being duly sworn according to law
deposes and says that he is the attorney for the Plaintiff in the
foregoing matter; that he is authorized to take this affidavit on
its behalf; and that the facts contained in the foregoing
Petition are true and correct to the best of his knowledge,
information
and
belief.
Joel
Steinman,
Esquire further
understands that false statements made herein are subject to the
penalties of 18 Pa.C.S., Section 4904. relating to unsworn
falsification to .uthoriti..'~
~
k
JOEL STEINMAN, ESQUIRE
.J
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3. TRANSFERRED ASSETS AND GIFTS: If, in the preceding six
years, the Defendant has transferred any assets (real property,
personal property, chose in action), not covered by the immediate
preceding interrogatory, to any person. an/or, if the Defendant has
given any gift valued at more than $250.00, of any asset, including
money, to any person; set forth, in detail, a description of the
property, the type of transaction, and the name and address of the
transferee or recipient.
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t. AGREEMENTS: State whether the Defendant has any agreements
involving the purchase of any real estate anywhere in the United
States. If so, state with whom this agreement is made, and state
whether or not any persons are joined with the Defendant in the
agreement. Supply full names and addresses of all parties
concerned. If the said agreement is recorded, provide the state
and county of recordation. wlth volume and page numbers.
j
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f
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S. ACCOti::"!'S &:::BI'IADLJ:. DEBTS, NOTES "Jt1OGA:::~'J1 Stat~ tt1e names
and addresses of any and all persons whom the Defendant believes
owes the Defendant money and set Eorth in detail the amount of
money owed. the terms of payment and whether or not the Defendant
has written evidence of this indebtedness, and if so, the location
thereof. Also state if the matter is in litigation, and if so give
full details. If the Defendant holds Mortgages or Judgments as
security for any of these debts. state where and when such was
recorded or entered; and the Cou~ty, Book, Page number and term
where recorded. If the Defendant holds this Judgment or Mortgage
jointly with any other person or persons, give their name and
addresses.
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12. :RENTED PROPERTY: Is any of the property of the Defendant
rented to, leased to or otherwise in possession of a third person?
if so, state full description of the property; the name and address
of the person, firm or other entity who has possession of the
property; the circumstances and reason why the property is in
possession of the third person; the consideration or payment
received by the Defendant; the name and address of the person who
receives the rents or other consideration on behalf of the
Defendant.
13. MOTOR VEHICLES: State whether or not the Defendant owns or
has any rights in any motor vehicles. Include a full description
of each such motor vehicle. including color. model, title number.
serial number and registration plate number. Also show the name or
names in which each motor vehicle is registered. the present value
of each motor vehicle and their plC..\!~t. location and place of
regular storage. garaging or parking. ~tate also whether or not
there ore any E:l;c.~~,UJrancc." on tho'3e motor vE:.hi-::le!! and if so, the
name and address ':"~ tl:.e E:~cu~bl'"ance hold!!r, >:h!! "ate of the
encumbrance. the original amount of that encumbrance, the present
balance of the encumbrance. and the -transaction which gave rise to
the existence of the encumbrance. If not owned, state the extent
of the Defendant's rights in and to such vehicles.
14. ACCOtlNTS PAYABLE, LOANS PAYABLE, DOTS. NOnS WHICH THE
DEFalDANT OWBS TO SOMEon ILSII State the names and address of any
and all persons who claim that the Defendant owes them money for
any r..lon. Set forth in detail the amount claimed and, if there
are any suits. actions, or legal proceedings of any kind against
the Defendant pending and undetermined. that the full particulars
as to each. However, it 1S nc~ necessary to duplicate the Mortgage
information given in respon:3o!! to Interrogatory #1 (REA:. ESTATE)
~
and/or the encumbrance information required by Interrogatory #11
(PERSONAL PROPERTY) or Interrogatory #13 (MOTOR VEHICLE) .
IS. Are there any Judgments on record against the Defendant?
a. What amount and where?
b. Have payments been made on account thereof by the
Defendant or by any third party for the Defendant?
c. By what person?
d. Was satisfaction recorded?
e. If answer to item a. is "In the negative", explain why.
~.E. ,'u"c s'lpflementary proceedings: ;., aid -:-'= exe~ution now a>(,'1~ing
on any of these Judgments?
.1
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17. Hal any Judgment creditor's execution (enforcement) action
been commenced?
11. Where doe. the Defendant live?
a. How long has the Defendant live there?
b. How much does the Defendant pay for rent, board.
services, etc.?
"
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19. Is the Defendant a member of any club?
a. What are the dues?
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b, Are they paid?
:30. What salary or income has the Defendant?
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21. What is the occupation of the Defendant?
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::.( . Is the Defendant married?
a. IIAS the Defendant a faruily?
b. How large?
c. How lUny are dependent on the Defendant?
d, With whom does the Defendant live?
?
23. What lIIOney haa the Defendant reed ved within the last sixty
days from any aource, and what has the Defendant done with it?
24. Does the Defendant have a bank account?
a. When did the Defendant laat make a depo~it?
b. When did the Defendant last drawl. check?
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25. Has the Defendant anything in pawn? If so, give all details.
26. Has the Defendant made a Will?
a. When?
b. Describe all property devised in that Will.
27. OTHER ASSBTS I If the Defendant has any assets which was not
disclosed in the preceding Interrogatories, including but not
limited to rights and copy rights, patents and confidential and
secret processes, please set forth all details concerning those
assets including all recorded filings and proofs of ownership.
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'8. ~av~ ~fOlI in the pas~ tw~ (2) years submitted t.o a fin.ncial
institution/stock broker/banking institution either a personal or
confidential statement? .
a.
If the answer is in the
personal/confidential/financial
state:
affirmative
statement
for each
submitted,
1. With whom it was submitted to.
2. The date it was submitted.
3. Attach a copy of said personal/ financial statement.
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e. The name and address of each mortgagor:
f. The mortgage book and page number in the Office of the
Recorder of Deeds or the Office of the Deed Registry in
the County and State where the mortgage is recorded:
g. The name and addresses of each person/entity including
yourself listed as mortgagee:
h. Attach a copy of the mortgage:
31. Have you made any claim un~:, ~ny policy of insurance
within the last three years?
.
If so, as to each claim. state:
a. The name and addresses of the insurer:
b. The policy number:
c. The facts giving rise to such claim:
d. Whether or m,t $..:~h cl,li~ hu been paid:
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the purview of any of these requests which are obtained after the
time of their production presently, the materials should also be
furnished in accordance with this request.
If any document required to be produced is claimed. then (1)
the items to be produced for inspection and photocopying are:
1. Any and all documents. records. evidence and everything
which you reviewed or referred to in answering the
Interrogatories in Aid of Execution which accompanied
the Request for Production of Documents.
2. Deeds of all real estate owned by you either solely or
jointly with others.
3. Documents of title for all automobiles owned by you
either solely or jointly with others.
4. Your United States and Pennsylvania Income Tax
Re~~,~~ which you filed solely or with spouse including
all w-~ ~o~s issued to you and IRS 1099 Forms issued
to you either jointly or with otherl:l for the (ollowiug
~ars: lS93, ~9~4, lSj5
S. Bank statements covering all demand deposit accounts in
which you have an ownership inte~est of any kind.
6. Balance sheets and statements of profits for losses for
the last two (~l years showing all aSlets owned by you
during the said periods as well as the res~ltl of the
operations during said period,
7. A schedule of all of your accounts receivable and note.
receivable: Such lilt shall include the name and address
each debtor, the amount of the debt. and the terms of
payment.
8. A schedule showing ln detail all it.~~ of inventory held
by'{ou. such schedule slull i~clu:ie " des::rlptlOn of the
typ@ of In'...entorv, th~ c':-~t 0: :r_e lr....entc:'v, :.ts present
location and its pr~sent val~e. .
9. A list of all safe deposit boxes which is held either in
your name or jointly with others: Such lists shall
include the name of the box, exact total, the number of
the box and the name and address of the institution in
which it is located.
10. A list of all of your assets pledged as collateral for
loans or other obligations owned by you. either solely or
jointly with others: Such list shall include a
description of the collateral, its value, the name and
address of the institution or person with whom such
collateral is pledged, and the amount of the obligations
secured by said obligation.
11. A list of all equipment owned or possessed by you either
solely or jointly with others: Such lists shall include
a description of each item of equipment, its present
location, its cost, and its present value.
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12. A list of all yo~' ~;abilities, whether trade debt or
otherwise. including the name and address of the party to
whom such deb: is owed. th~ amount of such debt. 3nd
tt.e ten.." c,f paynent.
13. A list of all of your assets owned either solely or
jointly with others, other then inventory, transferred
by you within one (11 year from the date hereof including
a description of such assets. its cost, its value. and
the name and address of the party who received such
assets. and the consideration received by you for such
transfer.
14. Copies of all confidential/personal/corporate financial
statements issued by you to any financial institution
within the last three ()) years of the date which was
served with thlS Request for Production of Cocuments.
15. Complete copies of all insurance policies issued to you
eith~~ ~s 3 hc~e~~ert t~~3~~, C~ c~siness lncludi~g :~~
net li.!!u~ed :'0 :'ift! i~~su:'lr.:e pol~c:..e:s. policies for
.utomcb11~ i~s~~~~C~j h~~~ow~er5 ~lr~ lnsuran=e pC:l~les
f'~r ~~..."\ ;'.13": .'IIi~ y,..'l,\rs t:..,::~ ~h~ --:!,l-:e \"..)U were ser":ed
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