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Home My WebLink About00-01041 ." ~ -1--- " ", --' -" '~l-~.1 ',,.;;. -,;., "J~; PEPPER, GORDON, BREEN, & WEINBERG, P.C. BY: DANIEL J. TANN, ESQUIRE & FREDERICK I. WEINBERG, ESQUIRE Identification No. 46046 & 41360 260 South Broad Street, Suite 1410 PlIiladelphia, PA 19102 (215) 546-3131 Attorney for Plaintiff THIS IS AN ARBITRATION MATTER ASSESSMENT OF DAMAGES HEARING IS NOT REQUIRED AMERICAN EXPRESS P.O. BOX 42010 PHILADELPHIA, P A 19162 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY VS. WILLIAM T. QUlDORT 1117 FLORmUNDA LANE MECHANICSBURG, PA 17402 NO. ~COO - lOW Cto~(C~: 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. COURT ADMINISTRATOR CUMBERLAND COUNTY COURTHOUSE, 4TH FLR. 1 COURTHOUSE SQUARE CARLISLE, PA 17013-3387 717-240-6200 ,,~~~ .~ . ~ . - .'~ I r':j:LI~~ PEPPER, GORDON, BREEN, & WEINBERG, P.C. BY: DANIEL J. TANN, ESQUIRE & FREDERICK I. WEINBERG, ESQUIRE Identification No. 46046 & 41360 260 South Broad Street, Suite 1410 Philadelphia, PA 19102 (215) 546-3131 Attorney for Plaintiff TillS IS AN ARBITRATION MATTER ASSESSMENT OF DAMAGES HEARING IS NOT REQUIRED AMERICAN EXPRESS P.O. BOX 42010 PHILADELPHIA, PA 19162 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY vs. WILLIAM T. QUlDORT 1117 FLORIBUNDA LANE MECHANICSBURG, PA 17402 NO. d.1tOtJ - /trf I ~ ~ COMPLAINT IN CIVIL ACTION 1. At the special instance and request of the defendant, the plaintiff extended credit to the defendant in the form of an American Express Credit Card. 2. At all times relevant hereto, the defendant was the holder of the American Express Card which he accepted and used same and by doing so agreed to perform the terms and conditions prescribed by the plaintiff for the use of said American Express Card. 3. One of the terms and conditions to which the defendant agreed is to pay promptly to the plaintiff, upon rendition of a statement of all charges incurred by the use of said American Express Card including a finance charge when applicable. 4. The defendant made credit purchases through the use of said American Express Credit Card and plaintiff's statement of account, rendered to the defendant, shows a balance due to plaintiff from defendant in the sum of $4,417.49. A copy of Plaintiff's statement of account is attached in Exhibit "A". II - ,,;-,1,,; , ~~,j 5. All payments previously received have been credited to debtor's account. 6. Plaintiff has made demand upon the defendant for payment of the balance due of $4,417.49 but the defendant has failed and refused and still refuses to pay the said sum or any part thereof. WHEREFORE, plaintiff claims of the defendant the sum of$4,417.49, plus interest, costs, and attorney's fees, all of which are justly due and owing from defendant to plaintiff. PEPPER, GORDON, BREEN, & WEINBERG, P.C. BY:~- (. D . IEL J. T , ESQUIRE Attorney for Plaintiff , ..'"'iiW VERIFICATION I, Daniel J. Tann, Esquire, hereby states that he is the Attorney for Plaintiff, American Express, that he is the Attorney authorized to make this verification, and that the statements made in the foregoing Complaint, are true and correct to the best of his knowledge, information and belief; and I very that the within facts are made subject to the penalties of 19 Pa. C.S.A. ~4909 relative to unsworn falsification to authorities, RESPECTFULLY SUBMITTED: PEPPER, GORDON, BREEN & WEINBERG, P.c. BY: D:{2 -;7 DANIEI::;J. TANN, ESQUIRE 260 South Broad Street Suite 1410 Philadelphia, Pennsylvania 19102 (215) 546-3131 Attorney for Plaintiff --- ~ ~ -~~ '.;" , . -- . C C''1U[-.~i amount of payment enclosed Activity Summary Payment Due Amount Due Date Balance Number 300.51 215.51 01/31/99 4,276.87 3734-935221-42005 $ WILLIAM T QUIDDRT 1117 FLORIBUNDA LN MECHANICSBURG PA 17055-5302 Make check payable to: AMERICAN EXPRESS CENTURION BANK SUITE 0002 CHICAGO IL 60679-0002 1,11"11""11"1,,,11,1,,11.,,11,,.11.,,,,1,11.1.,1,1,11.1,11 3493522142 000300510004276874 Catdmember You can now download your Qptima(R) Card account iniormation into Microsoft(R) Money or Quicken(R) absolutedy free of News charge. American Express updates your account information daily so the most recent activities on all eligible, enrolled accounts is a!your fingertips. Visit www.americanexpress.com/cardslmq.htmlto enroll today. <,. I Cardmemtier Name WILLIA~-T QUIDORT I Account Number 3734-935221-42005 Ipage I 1 of Am. Exp. IDate of IDate of ITransaction Refsrence No. Transaction Posting Description 431006-0 01/06 01/06 DELINQUENCY fEE ASSESSMENT MIN PAYMENT NOT RECEIVED BY DUE DATE 431006-0 01/06 01/06 OVERLIMIT FEE ASSESSMENT I Charges jCredits 25.00 25.00 ACCOUNT TOTAL ACCOUNT GRACE PERIOD=STANDARD GRACE (SEE STATEMENT BACK FOR DETAILS). FOR INQUIRIES ABOUT YOUR ACCOUNT, CALL 1-800-635-5955. FOR FASTER SERVICE, ENTER: - 1 FOR BALANCE, PAYMENT OR AVAIL. CREDIT - 2 FOR LOST, STOLEN OR DAMAGED CARD - 3 FOR CARD BENEFITS OR SERVICES 50.00 .00 Account Previous + New - Payments - Credits + FINANCE + Debit = New Summary Balance Charges CHARGE Adjustments Balance 4. 149 . 48 50.00 .00 .00 77 .39 .00 4;276.87 Bill Closing Payment Credit Available Amount Over Past Due Minimum Date Due Date Limit Credit Credit Limit Amount Payment Due 01/06/99 01/31/99 3.900 0 0 215.51 300.51 Number of Days x Daily x Average = FINANCE CURRENT ANNUAL Thank Finance this Billing Period Periodic Rate Daily Balance CHARGE PERCENTAGE RATE You Charge PURCHASES 31 .0596% 3,559.15 65.76 21.740% CASH ADVANCES 31 .0596% 629.26 11.63 21.740% Customer Service The OptimaSMCard ,'~-' ~ ".' (.'..""'" .c' , '~~~-~~-=I' ""lllillliiiliiiil:'-~ "0. ".~. ~-I<.' -' ,~ -l!;liIil~liir~~~ 'h ~.... >...;" . , ) ~ ~ ~ 0 Q C)' g h. c C) d ~~ :;::-- -n CB l~~r) -" -----I r'l ;--;' ..0 ~ ..::::... _u en '::::.-::; I 2i-- r'V ;"n ...... ...... I u,.> - , , ~ ~,c___, r ...... f:~ c=(::; c-, t C) -n j '~'-" -'-;" ~,~~"j 5;:8 ~, '-.-,--, --;-~" -" ry :~SIT! $ ? ':'-1 =< c:- .J.'- :0 -< .. . - "'"=-<- " - ---...~" SHERIFF'S RETURN - REGULAR CASE NO: 2000-01041 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND AMERICAN EXPRESS VS QUIDORT WILLIAM T KATHY CLARKE , Sheriff or Deputy Sheriff of Cumberland County, pensylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon QUIDORT WILLIAM T the DEFENDANT , at 0018:20 HOURS, on the 29th day of February, 2000 at 1117 FLORIBUNDA LANE MECHANICSBURG, PA 17055 by handing to CAROLYN QUIDORT (WIFE) 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: Docketing Service Affidavit Surcharge 18.00 8.06 .00 10.00 .00 36.06 sO;:~~t R. Thomas Kline me this ,1 </ ~ day of 03/01/2000 PEPPER, GORDON, BREEN DCPt: aE:t,/'/aJu- By: Sworn and Subscribed to before ~ 0Urzj-Q A.D. G,?, Q.~~ rothonotary , ". ~ n~ , .. . , '0 _ ~" .', '1,--" ~'- -'II!~'~; - Praecipe for Judgment IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY AMERICAN EXPRESS P.O. BOX 42010 PHILADELPHIA, PA 19162 vs. WILLIAM T. QUIDO~T 1117 FLORIBUNA LANE MECHANICSBURG, PA 17402 COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 2000-1041 CIVIL TERM The Prothonotary will please enter Judgment in the above matter by default for want of an answer against the Defendant and assess the dama er statem t below. . I I Ii II I ANIEL J. TA ,SQUIRE Attorney for Plaintiff Principal $4,417.49 Interest from 10/9/98 @ 22.24% $ 1,501.94 Total $ 5,919.43 I; I' I 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 days pn r to e daty praecipe. .~ D ELJ.T Attorney for PI l' I II II , I I I II il '! I hereby certify that the precise residence of the holder of the within judgment is P.O. BOX 42010, PHILADELPHIA, PA 19162, and that the last known address of the Defendant is 1117 FLORIBUNDA LANE, MECHANICSBURG't:J.;:t~ _ D IEL J. T N, ESQUIRE Attorney for Plaintiff Filed: By the Prothonotary: AND NOW this/.r+ day of f'Y/.:;Ji ,2000, Judgment is entered in favor of the Plaintiff and against the Defendant by Default for want of an answer and ages as sed t sum of $5,919.43. Ii -- , ( , .- ., I c .,-,no'.:_". '.~;';'i,:-,',. " _,'__,"-"__:;;_'__':_"".",,_, '.' I~, d~ ,- . ,-..- "' OFFICE OF THE PROTHONOTARY IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY AMERICAN EXPRESS P.O. BOX 42010 PHILADELPHIA, PA 19162 VS. WILLIAM T. QUIDORT 1117 FLORIBUNA LANE MECHANICSBURG, PA 17402 COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 2000-1041 CIVIL TERM 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. IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL DANIEL 1. TANN, ESQUIRE 215-546-3131. I !I " I i I II II II " i I' II Ii I II ; '4 . 'C-""V ,,_ ',,--:+ ~~<i ~~ - ~ . AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA :SS COUNTY OF CUMBERLAND DANIEL J. TANN, 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 Defendant is 1117 Floribunda Lane, Mechanicsburg, P A 17402, and 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. ~- . NIEL. TANN, ESQUIRE SWORN TO AND SUBSCRIBED flt BEFORE ME THIS /1 DAY OF ~ l, 2000. NO .BLIC rlotarial Seal Public Jotln V Mc:Bride III, Notary cou~ . eoro. MontgOmeIY :=rssion expires June IG. 2 Member, poonsylVanla I\SSOcia1iOn 01 o1arillS I I II , _'~~""'J~"""""""""""",,,_,,,,,,,, .""~~~~,~~ ~" '11"" , .1 A ~"-'t~~,,-.~ J PEPPER, GORDON, BREEN, & WEINBERG, P.C. BY: DANIEL J. TANN, ESQUIRE & FREDERICK I. WEINBERG, ESQUIRE Identification No. 46046 & 41360 260 South Broad Street, Suite 1410 Philadelphia, P A 19102 (215) 546-3131 Attorney for Plaintiff THIS IS AN ARBITRATION MA TIER ASSESSMENT OF DAMAGES HEARING IS NOT REQUIRED AMERICAN EXPRESS P.O. BOX 42010 PHILADELPHIA, PA 19162 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY VS. WILLIAM T. QUIDORT 1117 FLORIBUNDA LANE MECHANICSBURG , PA 17402 NO. 2000-1041 CIVIL TERM TO: WILLIAM T. QUIDORT DATED: March 31, 2000 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN THIS CASE. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAYBE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. COURT ADMINISTRATOR CUMBERLAND COUNTY COURTHOUSE, 4TH FLOOR 1 COURTHOUSE SQUARE CARLISLE, PA 17013-3387 \~. 7l~~~ ~~~ .~ DANIEL J, ANN, ESQUIRE I... !I~~~~AltW;j1lli:fiiiltij,~~'i;ldH!U~*~~i~W''0lI''''''~i!illiiif!i!l\EJ!llIll ,J_ -~ _ ~_ "_ H ~, , '"' ~,' ,~ ,'~ ~, -l'.iJlili1 f'~"'$Sr!^~'" .!lIl...AI .~"' .. t AJ (J ~ It. ~ 8 c..., C) , ~ p C' '--.J ..() ~ -cf:-~< '--" ~ 6"- U ;l~ ~- j ....... F ,J 0 6""- L ~~~,. f..J' .... ~ f~:': .~r'j - ..... :~. <- -, ~ ':.._( A )> c'~,~ i';? ~, :.n =< en , , , ~ . ~- _11