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Home My WebLink About00-01043 .,j , .' >',j' ,',j '--'.-; PEPPER, GORDON, BREEN, & WEINBERG, P.c. JASONM. BLATT, ESQUIRE Identification No. 79492 260 South Broad Street, Suite 1410 Philadelphia, PA 19102 (215) 546-3131 THIS IS AN ARBITRATION MATTER ASSESSMENT OF DAMAGES; HEARING IS NOT REQUIRED. ATTORNEY FOR PLAINTIFF AMERICAN EXPRESS CENTURION BANK P,O. BOX 1407 NEWARK, NJ 07101-1407 COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. ~OOC> - 101./.3 C(lJ~L '-,~ Plaintiff, vs, JOHN S, SHILLINGSFORD 29 CENTRAL BOULEVARD CAMP HILL, PA 17011-4210 Defendant. 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 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 ALAWYER 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 FLOOR 1 COURTHOUSE SQUARE CARLISLE, PA 17013-3387 717-240-6200 i II I. -'--<' , PEPPER, GORDON, BREEN, & WEINBERG, P.C. JASON M, BLATT, ESQUIRE Identification No, 79492 260 South Broad Street, Suite 1410 Philadelphia, PA 19102 (215) 546-3131 THIS IS AN ARBITRATION MATTER ASSESSMENT OF DAMAGES; HEARING IS NOT REQUIRED. ATTORNEY FOR PLAINTIFF AMERICAN EXPRESS CENTURION BANK P.O. BOX 1407 NEWARK, NJ 07101-1407 COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintifl: NO. vs. JOHN S. SHILLINGSFORD 29 CENTRAL BOULEVARD CAMP HILL, PA 17011-4210 Defendant. COMPLAINT IN CIVIL ACTION 1, At the special instance and request of the Defendant, the l'laintiff extended credit to the Defendant in the form of an American Express 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 Plaintiffs statement of account, rendered to the Defendant, shows a balance due to Plaintiff from Defendant in the sum of$1,869 .70. A copy of Plaintiffs statement of account is attached in Exhibit "A". :1 " Ii I. 5. Plaintiff has made demand upon the Defendant for payment of the balance due of $1,869.70, but the Defendant has failed and refused and still refuses to pay the said sum or any part thereof. 6. Plaintiff has applied all credits to the total amount owed by Defendant. WHEREFORE, Plaintiff claims of the Defendant the sum of$1,869.70, 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, \\1 ~. . B SON M. BLATT, ES ttorney for Plaintiff ~ , .-, li"H ... VERIFICA TION JASON M. BLATT, hereby states that he is the attorney for the Plaintiffin this action and that he is authorized to make this verification, 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, Section 4904 relating to unsworn falsification to authorities, Dated: 'L(lV(OV ~/0~/ JA N M. BLATT, ESQ 000710008 so '"- "AI..!.- , Statement MINIMUM PAYMENT DUE BY PAYMENT DUE DATE. Monthly Activity Suml11ary Minumum Payment Due Past Due Amount Payment Due Date New Balance Account Number Please write in amount of payment enclosed 37.00 .00 01/28/98 1 .869.70 3737-482130-22000 $ JOHN S SHILLINGSFDRD 29 CENTRAL BLVD CAMP HILL PA 17011-4210 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,,,,I,ll 3748213026 000037000001869707 Cardmember You can use your Optirna(R) Card to buy furniture at Value City Furniture, prescriptions and other necessities at Rite Aid, and News even stamps at the U.S. Post Office. And every two minutes, another merchant begins accepting the Card so you can use it every day! I Cardmember Name I Account Number [page JOHN S SHILLINGSFORD 3737-482130-22000 I of 2 Am. Exp. IDate of IDate of rransactjon I Charges 1 Credits Reference No. Transaction Posting Description 835360-0 12/26 12/26 PAYMENT RECEIVED - THANK YOU 12/26 35.00 501353-0 12/17 12/19 SIERRA MADRE SALOON CAMP HILL PA 69356002 FOOD-BEV 12/17/97 35.36 501357-0 12/21 12/23 SIERRA MADRE SALOON CAMP HILL PA 69356003 FOOD-BE V 12121/97 19.00 501002-0 12/31 01/02 SIERRA MADRE SALOON CAMP HILL PA 69356001 FOOO-BEV 12/31/97 6.25 501002-0 12/31 01/02 SIERRA MADRE SALOON CAMP HILL PA 69356002 FOOD-BEV 12/31/97 24.36 ACCOUNT TOTAL 84.97 35.00 Accounl Previous + New - Payments -Credits + FINANCE + Debit = New Summary Balance Charges CHARGE Adjustments Balance 1,784.89 B4.97 35.00 .00 34.84 .00 1 . 869 . 70 Bill Closing Payment Credit Available Amount Over Past Due Minimum Date Due Date Limit Credit Credit Limit Amount Payment Due 01/03/98 01/28/98 13,300 11,430 0 .00 37.00 Finance Number of Days x Daily x Average = FINANCE CURRENT ANNUAL Thank this Billing Period Periodic Rate Daily Balance CHARGE PERCENTAGE RATE You Charge PURCHASES 31 .0616% 1 , B24 . 50 34.84 22.490% CASH AOVANCES 31 .0616% .00 .00 22.490% Customer Service The OptimaSMCard illill\illjilll8lrmttilhlNi.-v' 'i- ~;JI~;,r~!lmiM~ .~'''-lliIIiilillililll!l R - ^~"ii"""- ,1;..-, , -_ ~- I -~ r." ?'J~ ~ ~ 1t. fl:. .1Ii h C> B () ~ '-0 CY " ....... ~ ~ ( I ft~~ j , () 'e: -o0--~ ~~~{ ...'-:::',1.,,_, t.]>,.:: GtJ <~ ~~~~ ~ -<- " -'0': (-" C.) " Iq OJ "-, .r:-- C) 'n ~:;::! --',.;-n ",'~ ,- ;:-") -;' ~ --r) ....i_ ~ ~'1 8 ::'7. -.. .~ ~, ~, ,.~- ~ .= L. *', SHERIFF'S RETURN - REGULAR CASE NO: 2000-01043 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND AMERICAN EXPRESS VS SHILLINGS FORD JOHN S SHANNON SUNDAY , Sheriff or Deputy Sheriff of Cumberland County, Pensylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon SHILLINGSFORD JOHN S the DEFENDANT , at 0018:30 HOURS, on the 1st day of March , 2000 at 29 CENTRAL BOULEVARD CAMP HILL, PA 17011-4210 by handing to JOHN SHILLINGS FORD a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 9.30 .00 10.00 .00 37.30 So ;;~~I R. Thomas Kline 03/02/2000 PEPPER, GORDON, BREEN Sworn and Subscribed to before By: . 4AflMAVhI "pt. Jl1hlA/JJ7 Deputy Sheriff me tnis ~L{.... day of -c:s:: A.D. Q.~,~ rothonotary :fu". .J.1lII If -~_ ~"-- , ^,~,I '. > ~~" , , TIDS IS AN ARBITRATION MATTER ASSESSMENT OF DAMAGES; HEARING IS NOT REQUIRED AMERICAN EXPRESS CENTURION BANK, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff VS. : NO. 2000-1043 CIVIL TERM JOHN S. SHILLINGSFORD, Defendant ANSWER 1. Denied. Defendant lacks information upon which to formulate an Answer. Strict proof is demanded. 2. Denied. Defendant lacks information upon which to formulate an Answer. Strict proof is demanded. 3. Denied. Defendant lacks information upon which to formulate an Answer. Strict proof is demanded. 4. Admitted in part and denied in part. It is admitted Defendant made some credit purchases. It is denied Defendant owes the sums calculated as finance charges, Strict proof is demanded. I - ~,. " - - ~"' I. -L~~'~ 5. Denied. It is denied Plaintiff made demand for payment upon Defendant. Strict proof is demanded. 6. Denied. Defendant lacks sufficient information upon which to formulate an answer. Strict proof is demanded. WHEREFORE, Defendant demands judgment be entered in favor of Defendant and against Plaintiff. Dated: f1/1f 2., 2 t1tJo 2 '_~~l[ 'H~~"_"",......1b~_~~ ;, ~, .~ "" _. - . VERDlCATION The facts set forth in the foregoing are true and correct to the best of the undersigned's knowledge. information and belief and are verified subject to the penalties for unsworn falsification to authorities under 18 Pa. C.S.A. M904. Dated: nn~ '2 ')11J1i I Jt, I)j~J JO S. SHIL GSFORD ~c,~. !l~i>. $!1.",. - .. " ,,, ~ -~~llil'i",,' . CERTIFICATE OF SERVICE I, John S. Shillingsford, hereby certify that true copies of the Answer have been served upon the below-referenced individuals by sending the same by first class mail, postage prepaid, addressed as follows: Jason M. Blatt, Esquire Pepper, Gordon, Breen & Weinberg, P.C. 260 South Broad Street, Suite 1410 Philadelphia, PA 19102 Dated: 1111,,2 2101 I . 3 !JjL' ~~~"~ "' ~~~""'''''il!illlillllllM~~ -" ~~"l ~Jll~-D![ j,..;'" ''-0''-'' .... " - "1.; .. 0 0 ~ c: Cl S. ::!: .-1 -0 OJ ~ ?1':;:1~ rnrn Z:IJ , ~;,~ ZC;:- CP",::~ (;.1 {:) .::<..:e:. :2:H r::O ;0' '< )>'0 -'- ~-t~ Z6 '-P. 0 )>C .'-1 -7 .-:;::> ~ :-'1 ~ -< (Xl' _u."""'_ - . PEPPER, GORDON, BREEN & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE I.D. #41360 260 SOUTH BROAD STREET SUITE 1410 PHILADELPHIA, PA 19102 (215) 546-3131 ATTORNEYS FOR PLAINTIFF AMERICAN EXPRESS CENTURION BANK P.O. BOX 1407 NEWARK, NJ 07101-1407 VS. JOHN S. SHILLINGSFORD 29 CENTRAL BOULEVARD CAMP HILL, PA 17011-4210 : COURT OF COMMON PLEAS : CUMBERLAND COUNTY : NO: 2000-1043 ORDER TO MARK ACTION SETTLED. DISCONTINUED AND ENDED TO THE PROTHONOTARY: Please mark the above action settled, discontinued and ended. DATED: I If. M- &1r -~ ,"'ciI<<i" Il\III!jlliWiilll. 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