HomeMy WebLinkAbout01-5943DESSEN, MOSES & SHEINOFF
BY: David S. Dessen, Esquire
IOENTIFICAT]ON NO. 17627
1814 CH ESTNUT STREET
PHILADELPHIA, PA 1910;3
(215) 564-5600
ATTORNEY FOR
Plaintiff
AMERICAN EXPRESS COMPANY
World Financial Center
New York, NY 10285
JO A. MCCLEAF
137 Bridge Street
New Cumberland, PA 17070
CUMBERLAND COUNTY
COURT OF COAI~fON PI3EA~
CIVIL DMSION
TERM,
CIVIL ACTION - COMPLAINT
NOTICE
lEGAL HELP.
AVIBO
Lawyer Referral Service ....
Cumberland County Bar Association
Two Liberty Avenue
Carlisle, PA 17013
Phone: 717-249-3166
DESSEN, MOSES& SHEINOFF
BY: David S. Dessen, Esquire
Attorney I.D. No. 17627
1814 Chestnut Street
Philadelphia, PA 19103
(215) 496-2910
American Express
World Financial Center
New York, NY, 10285-4411,
Plaintiff
VS.
Jo A Mccleaf
137 Bridge Street
New Cumberland PA 17070,
Defendant
Attorney for Plaintiff
COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL DIVISION
CIVIL ACTION - COMPLAINT
Plaintiff, American Express, is a corporation licensed to do business under the laws
located at World
5.
$13,583.40.
6.
Plaintiff avers that pursuant to Plaintiffs contract with Defendant, Plaintiffs attomeys
are to receive reasonable attorney's fees for filing suit.
of the Commonwealth of Pennsylvania, with a principle place of business
Financial Center, New York, NY, 10285-4411.
2. Defendant, Jo A Mccleaf, is an adult individual who resides at 137 Bridge Street,
New Cumberland PA 17070.
3. Plaintiff extended credit to Defendant under Account No. 3737-387328-12007,
pursuant to the terms of the contract attached hereto as Exhibit "A".
Plaimiff performed all its obligation in extending said credit.
Presently, there is due and owing from the Defendant to the Plaintiff the sum of
7. Plaintiff believes, and therefore avers, that an attorneys' fees rate of 20% of the debt
due, which is $2,716.68, is just and reasonable compensation for the services rendered by said
attorneys.
8. Although demand for payment has been frequently made by Plaintiff, Defendant
refuses and continues to refuse to pay same.
WHEREFORE, Plaintiff demands judgment against Defendant in the amount of
$16,300.08, plus interest from September 25, 2001 and costs of suit.
DATED:
Respectfully submitted,
DESSEN, MOSES & SHE1NOFF
David S. Dessen, Esquire
Attorney for Plaintiff
VERIFICATION
I, David S. Dessen, Esquire, attorney for the Plaintiff, am authorized to take this Affidavit
and hereby verify that the facts set forth in the foregoing Civil Action - Complaint are true and
correct to the best of my knowledge, information and belief. I understand that false statements made
herein are made subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to unsworn
falsifications to authorities.
David S. Dessen, Esquire
Attorney for Plaintiff
C
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