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HomeMy WebLinkAbout01-5950COMMONWEALTH OF PENNSYLVANIA COURT OF COMMON PLEAS JUOICIAL DISTRICT NOTICE OF APPEAL FROM /o ~ /(._ o / DISTRICT JUSTICE JUDGMENT NOTICE OF APPEAL Notice is given that the appellant has filed in the above Court of Commo~ Pleas an appeal from ¢ne judgment rendered by the District Justice on the date and in the case mentioned bela~ Julie Ivey Patterson, a/k/a JuIie Ivey Thomas A. Placey 744 Colonial Court, Mechanicsburg, PA 17050 9/20/01 Belmont Financial Services Group ~nlie Ivey-Patterson a/k/a Julie Ivey LT 19 ~ Elizabeth J. Goldstein, ~k ~k will ~ ~ ~LY ~ ~is r~lul;~ is ~uimd u~ P~ R~JR ~ ff ~l~t ~ CLAT~T (s~ ~. R.C. RJ.R NO. 1~8& This Notice of Appeal, when received by the District Justice, will opeeate as a SUPERSEDEAS to the judgment for possession in this cas~ Signature of Prothonotary or Deputy 1 O01 ( 6 ) in action bef~e District Justice, he MUST FILE A COMPLAINT within twenty (20) days after filing his NOTICE of APPEAL. PRAECIPE TO EN'.:K RULE TO FILE COMPLAINT AND RULE TO FILE (This section of form to be used ONLY when appellant was DEFENDANT (see Pa. R.C.P.J.P. No. 1001(7) in action before District Justice. IF NOT USED, detach from copy of notice of aPl3eal to be sen/ed upon appellee). PRAECIPE~ To Prothonotary Enter ruleupon Belmont Financial Services Group Name ~ ~c~eG~s) , appe#ee(s), to file a c~int in ~s ~ (C~~ O/- 3'9~0 ~ ~ )withint~y(20)~s~eofru~s~ofj~of~ RULE: To Belmont Financial Services Group Elizabeth J. Goldstein (1) You am notified that a rule is hereby enteeed upon you to file a complaint in thi~ apl:mai within h,~nty (20) doys aftra the dal~ of service of Ibis rule upon you by persaoal service or by cedified o~ registered mail (2) If you do not file a complaint within th~s time, a JUDGMENT OF NON PROS WILL BE ENTERED AGAINST YOU. (3) The date of service of this rule if service was by mail is the date of mailing. I~: October /g. ; I~200.1 ~ ~.. ~',L COURT FILE TO BE FILED WITH PROTHONOTARY J(ZLyli I'VEY.pA%,[,ERSON AKA JULIE IVEY ?44 COGONIAL COURT f~CI~2~CISBuRG, PA ~7050 FAX NO, 2388804 P, 02 NOTICE OF JUDGMENT/TRANSCRIPT PIAINTH:F: CIVIL CASE ~BELMONT FINANCIAL SERVICE8 GROUP /~ P.O. BOX 213 WYNNEWOOD, PA 19096 DEFENDANT: VS. -- ?44 cor,ONTAL COORT FIRCHANcISBGRG, PA 17050 L THIS IS TO NOTIFy YOU, THAT: Jadgmc-ni: --D-F-~A~I~ ,Ti31'jc,.j, tta~¢, ~T~F Judgment was enler~ Cot: (Name) ~,.,n~ ~Judgment was entered aga~nm: (Name) in the ~mount of $ .... ~,fieq (Date of Judgment) Defendants are jointly and Severally liable. (Date & Time) Damages will bo assessed on: This case dismissed without prejudice. Amount of Ju.~ ....... . uJC~H~rl[ ~UO oct tO AU~chment/Ac[ 5 of 1996 ~ Objection to levy has been [ilad and hearing will be held: I Dockoi N~.: C-'V- 0006'428 - 011 "J :LDate Fi'ed: e/~-Z/O:t l~ Amount of Judgment Judgment Costs $ ~.~._._~.~ Interest on Judg,'nent $ ~ Attorney Fees $$~..~· 05 Total 599.7~ Post Judgment Credits $~ Post Judgment Costs $ Cedified Judgment Total $..__.,,.~_.~ - .... ~---------------= .... -~-- -~..~, T~,e: ............ - ........ - ANY' PAR rY HAS THE RIGHT TO APPEAL WITHIN :0 DAYS ;~ Oi ~PPEA L WI I'H */HE PROTHONOTARY/C~=v ......... ~ER THE ENTRY OF JU~¢MENT "~ ~.CLU~.. copy O. ~.~s .o~- ~7 ?.?~.'-?~- ~°~ Co.~o. ~L~.~,'¢~WL ; ,, ..... ua~ ~ANSqRIPT FORM WI~H , f ; ,, ~ / ~/ , ~ ~, '~YOU ..... ,~e UP APPEAL. FI -_.:;Z~--- .~~- v ~ ~~, DJs(r,ct Justice l::::: ......... ! ......... ....... · ~,-a,,~a~, t 2004 SEAL PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FILE COMPLAINT (This proof of service MUST BE FILED WI THIN TEN (10) DA YS AFTER filing the notice of appeal Check applicable boxes) COMMONWEALTH OF PENNSYLVANIA COUNTY OF___ C~taber' ,~, ; ss AFFIDAVIT: ! hereby swear or affirm that I served [] a copy of the Notice of Appeal~Common Pleas No, · 0[-5950 __, upon the District Justice designated therein on (date of service) October [,I,,1~,. 200]. ......... [] by personal service [] by (certified) (registered) mail, sender's Kree~t~h. ed hereto, and upon the appellee, (name) Belmont Financial Services Group __ , on Shapiro, -~ , '1'~--2-001 [] by personal service [] by (certified) (registered) mail, sender's receipt attached hereto. [] and further that IservedtheRuleto Filea ComplaintaccompanyingtheaboveNoticeofAppeal upon theappellee(s)towhom the Rule was addressed on OotQber ],7 :; _:: __: ; 19 20.~0][] by personal service ~ by (certified) (registered) mail, sender's receipt attached hereto. SWORN (AFFIRMED) AND SUBSCRIBED BEFORE ME ," A'"."JC~ 2. OLYP...'~ ."F., .~.~ P~ic Title o! offimal I Har¢~ J~., ~ Com;L M Commission ~Ires Au~luSt 27, 2005 My commission expires oI~ I in, "eS?pnature of affiant PA Attorney ~ 73779 KEEFER WOOD ALLEN & RAHAL, LLP 415 FALLOWFIELD ROAD SUITE 102 CAMP HILL, PA 17011-4906 BELMONT FINANCIAL SER\ ICES GROUP, Plainliff J ULIE IVEY PATTERSON, A/K/A JULIE IVEY, Defendant : IN THE COURT OF COMMON PI. LAS, : CUMBI~,RLAND (.O[ NTX~, : PENNSYLVANIA : CIVIL TERM NO. 01-o9o0 ENTRY OF APPEARANCE Please enter my appearance on behalf of Defendanl, Julie Ivey Patterson, a/k/a Julie Ivey. KEEFER WOOD ALLEN & RAHAL, LLP Dated: 10/I ~ ]01 By: Elizabeth J. Goldstein, Esquire Attorney ID #73779 415 Fallowfield Road Suite 102 Camp Hill, PA 17011-4906 (717) 612-5803 Attorneys for Defendant CERTIFICATE OF SERVICE I, Elizabeth J. Goldstein, Esquire, attorney for Julie Ivey Patterson, a/k/a Julie Ivey, hereby certify that I have served a Entry of Appearance upon the following individual by depositing a true and correct copy of the same in the United States mail, certified mail, return receipt requested, postage prepaid, addressed as follows: Kenneth S. Shapiro, Esquire One Belmont Avenue Suite 202 Bala Cynwyd, PA 19004 KEEFER WOOD ALLEN & RAHAL, LLP By Ehzabeth'J. Goldstein, Esquire Attorney ID # 73779 415 Fallowfield Road Suite 102 Camp Hill, PA 17011-4906 (717) 612-5803 Attorneys for Defendant Dated: WILLIAM SHAPIRO, ESQ. P.C. BY: Kenneth S. Shapiro, Esq. Identification No. 26850 One Belmont Ave., Suite 202 Bala Cynwyd, PA 19004 610-668-0707 Belmont Financial Services Group, Inc. : P.O. Box 213 Wynnewood, PA 19096 : Plaintiff : VS. .' IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA Julie Ivey-Patterson AKA Julie Ivey 744 Colonial Court Mechanicsburg, PA 1995 Defendants : CASE NO. 01-5950 Civil Term NOTICE You have been sued in the Court of Common Pleas of Cumberland County, in the Commonwealth of Pennsylvania. 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 is served, by entering a written appearance personally or via attorney, by filing, in writing with the above captioned 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 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 2 Liberty Avenue Carlisle, PA 17013 717) 249-3166 800) 990-9108 WILLIAM SHAPIRO, ESQ. P.C. BY: Kenneth S. Shapiro, Esq. Identification No. 26850 One Belmont Ave., Suite ~.02 Bala Cynwyd, PA 19004 610-668-0707 Belmont Financial Services Group, Inc.: P.O. Box 213 Wynnewood, PA VS. 19096 : Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA Julie Ivey-Patterson AKA Julie Ivey 744 Colonial Court Mechanicsburg, PA 1995 Defendants : CASE NO. 01-5950 Civil Term COMPLAINT 1. Plaintiff, Belmom Financial Services Group, Inc., is a Pennsylvania corporation with its principal place of business at P.O. Box 213, Wynnewood, PA 19096. 2. Defendant(s), Julie Ivey-Patterson, AKA Julie Ivey is/are individual(s), whose last known address is 744 Colonial Court, Mechanicsburg, PA 1995. 3. On or about January 4, 1995, Defendant(s) originally contracted with Chevy Chase for a Visa Credit Card Account No. 4246171010346042 (the "Accounff). (See Exhibit "A', Affidavit of Indebtedness attached hereto and made a part hereof.) 4. The account was purchased from Chevy Chase by Unifund CCR Partners, and subsequently assigned to Belmont Financial Services Group, Inc. on or about November 16, 2000. (Exhibit ~A') 5. Defendant(s) defaulted under the terms of the agreement in that he has failed to make any payments on the balance due on the account since December 22, 1997. (Exhibit 'B~, Chevy Chase Visa Agreement, attached hereto and made a part hereof) 6. Plaintiff has duly made demand for payment from the Defendant(s), who has failed and refused to comply with said demand. 7. In accordance with the terms of the account and the underlying agreement with Chevy Chase, Defendant(s) is obligated to the Plaintiff in the amount of $4,481.27 (as of August 3, 2001), calculated as follows: Principal Balance due on Account $2,677.53 Interest and finance charges ~ 18.90 % APR from December 22, 1997 through August 3, 2001 $1,803.74 Total Amount Due $4,481.27 (See Exhibit "A~, Affidavit of Indebtedness) WHEREFORE, Plaintiff requests that this Court enter judgment in favor of Plaintiff and against the Defendant{s) in the amount of $4,481.27 plus interest and costs. WILLIAM SHAPIRO, ESQ. //~ Kenneth S. ~ ' .-- State of Ohio ) CoUnty of Hamilton) ss. AFFIDAVIT AND ASSIGNMENT Amy Sanders, being sworn, deposes and says that she is Media Supervisor of Unifund Corporation herein called assignor, which is doing business at 11802 Conrey Road, Suite 200, Cincinnati, OHIO 45249 and that she is authorized to make the statements and representations herein. At all times relevant hereto, all books and records of assignor pertaining to the account of the debtor were maintained under my direct custody and control. There is due and payable from Julie Ivey - Patterson account #4246171010346042, as of December 22, 1997, the amount of $2677.53. By the terms of the agreement between the defendant and the original creditor, interest is accruing at the rate of 18.90 pement per annum. This account originated with Chevy Chase. Unifund Corporation pumhased this account from Chevy Chase. Said agreement was hereby assigned, transferred and set over unto Belmont Financial Services Group, I on November 16, 2000, with full power and authority to do and perform all acts necessary for the collection, settiement, adjustment, compromise or satisfaction of said claim. The affiant states that to the best of the affiant's knowledge, information and belief there are no uncredited payments, just counterclaims or offsets against the said debt. Further, the undersigned acknowledges that in making this assignment, the assignor has made a complete assignment of said debt and that Belmont Financial Services Group, I is now the owner thereof, and they have complete authority to settle, adjust, compromise and satisfy said claim that all of the original credit grantors and their successors and assignees had, and that the assignor has no further interest in said debt for any purpose. DATED this 5th day oi7 December 2000. UNIFUND CCR PARTNERS NOTARY SEAL My commission expires: By: Amy Sanders Media Supervisor 11802 Conrey Rd., Suite 200, Cincinnati, OH 45249 Subscribed and sworn to before me this 5th day of December 2000. ~,$TIIqA~.$!' gl~ - Notary Public CH--VY CHA$-' BANK, l: g~ve~ me grea: ~iea.~uve to nre~en: .vou.- new Che~ Chase c~. You may ~m ~ u~ yo~- nmw :mm~&a~ly. ~ly ai~ ~e ba~ of ~5~ c~ for pr~viie~. You en. oy: Pa~ent Due ~ate each month. Simply eau toll-f~ t-~-9~7.~000 a~:~ s~ak :c Rep~nmev~ We'~ av~iabie 24 ' Gmamr ~opping. d~g, ~d ~mve~e i~:o~ ac~ the U.S, and ab~d-~ tJmee ~ ch~e ~vel ut~em ~ch vo~ Ch~ C~ · ?r~ additio~ ~ for ~ther ?~[iy or home,id · Conve~ent ~a arc,ability. A ~rowing number ol'cu.smmem are u~mg their Choy-., Ch.ase cards Lo obr.0.m cask. Simply present your =erd' a: any banjo er t~nancial ir~tltu~ion dia'~laying toe MasterCard or Vise s.wnbol· You can o~tain cnsn up to yo~- avaiiabie cash advance limi'- You can also obtain :,~h ny w~iung a cash ad~-anc~ check. You ~li receive an introductory supply et rash advance checks shortly, These checks work jest like oersona checks. You can ob:ain cash., make ourcnaae~, or ,nay bills. It,'~ like ~vritmg your,a-.Ifa i~an ~thou: gomg t~ the bank! An6 anty.vou know 'mu're your credit line, .'.'.'.'~e terms an.4 condl[iona of yOur Chevy Chase ~ a~ deK6~ in ~e encia~d a~menL ~i~ rea6 the a~emen: ~ly, as the~ ~y We ~ Your ~e of ~e ~ ~ m~m yo~- a~p~ o~ Once a~'ain, welcome to Chevy. Chase. We look £umvr~rci m m~eun.~ all afyour :redi: cam ne~. Denni~ C. Moraney ~ Senior Vice President YOUR B(LLING RIGHTS KEEP THIS NOTICE FOR FUTURE Special Promo{ional Offers STATE OF PENNSYLVANIA COUNTY OF MONTGOMERY Patricia Lieb, being duly sworn according to law, deposes and says that he/she is the Assistant Treasurer of Belmont Financial Services Group, Inc; that he/she is authorized to make this affidavit on its behalf; and that the facts set forth in the foregoing complaint are true and correct to the best of her knowledge, information and belief. Patricia Lieb, Assistant Treasurer Sworn to and subscribed before me this 2 q X-day of d)c T0 t3 e-r~ ,2001 Notary Public' ..... NOTAFIIAi,. ~EAL · ... ~__~_..~__.T~, ~o.~..,~ WILLIAM SHAPIKO, ESQ. P.C. BY: Kenneth S. Shapiro, Esq. Identification No. 26850 One Belmont Ave., Suite 202 Bala Cynwyd, PA 19004 610-668-0707 Belmont Financial Services Group, Inc.: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA Plaintiff : Vs: Julie Ivey Patterson AKA Julie Ivey : Defendant : CASE NO. 01-5950 Civil Term CERTIFICATE OF SERVICE Kenneth S. Shapiro, Esq., Attorney for Plaintiff, Belmont Financial Services Group, Inc., hereby certified that on ~x)eor~Occ ~..) ~.OOI ,Iserved Defendant with a true and correct copy of the Complaint filed in this matter by mailing it by first class mail, postage prepaid to Defendant's Attorney of Record: Elizabeth J. Goldstein, Esq. Attorney for Defendant Keefer Wood Allen & Rahal, LLP 415 Fallowfield Road, Suite 102 Camp Hill, PA 17011-4906 Respectfully submitted William Shapiro Esq., P.C. KEEFER WOOD ALLEN & RAHAL~ LLP 41 ~ FALLOWFIELD ROAD SUITE 102 CAMP HILL PA 17011-4~06 In the Court of Common Pleas Cumberland County, Pennsylvania Belmont Financial Services Group, Inc. · PO Box 213 Wynnewood, PA 19096 Plaintiff Case No. 01-5950 Civil Term Julie Ivey-Patterson aka Julie Ivey 744 Colonial Court Mechanicsburg, PA 19950 Defendant TO: Kenneth S. Shapiro, Esquire Attorneys for Plaintiff William Shapiro, Esquire, P.C. One Belmont Avenue, Suite 202 Bala Cynwyd, PA 19004 NOTICE TO PLEAD You are hereby notified that you are required to plead to the attached New Matter within 20 days of service of the attached Answer and New Matter. KEEFER WOOD ALLEN & RAHAL, LLP Elizabeth J. Goldstein PA Attorney ID# 73779 KEEFE Wood Allen & Rahal, LLP 415 Fallowfield Road, Suite 102 Camp Hill, PA 17011-4906 717-612-5803 Attorneys for Defendant Date: In the Court of Common Pleas Cumberland County, Pennsylvania Belmont Financial Services Group, Inc. : PO Box 213 Wynnewood, PA 19096 : Plaintiff Case No. 01-5950 Civil Term Julie Ivey-Patterson aka Julie Ivey 744 Colonial Court Mechanicsburg, PA 1995 Defendant DEFENDANT JULIE IVEY-PATTERSON AKA JULIE IVEY ANSWER WITH NEW MATTER Admitted. Denied. It is admitted that Defendant Julie Ivey-Patterson, aka Julie Ivey is an individual who lives at 744 Colonial Court; Mechanicsburg, Pennsylvania. It is denied that her zip code is 1995. Her zip code is 17055. Denied. It is admitted only that Defendant did contract with Chevy Case for a Visa credit card with account number 4246171010346042 (herein "Chevy Chase Visa"). After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as the remaining averments in Paragraph 3; thus, the remaining averments are denied and strict proof thereof is demanded at trial. Denied. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments of Paragraph 4; thus, they are denied with strict proof demanded at trial. Denied. The averments of Paragraph 5 are conclusion of law to which no responsive pleading is required. To the extent a responsive pleading is required, Defendant admits only that she has failed to make payments since October, 1996. After reasonable investigation, Defendant is without knowledge sufficient to form a belief as to the truth of the remaining averments and thus they are denied with strict proof thereof demanded at trial. Denied. It is admitted only that Plaintiff demanded payment from Defendant by filing a district justice action in 2001, and Defendant has not paid Plaintiff. Denied. Paragraph 7 is a conclusion of law to which no responsive pleading is required. To the extent a response is deemed required, after reasonable investigation, Defendant is without knowledge sufficient to form a belief as to the truth of the remaining averments and thus they are denied with strict proof thereof demanded at trial. WHEREFORE, Defendant respecffully requests that this Court enter judgment in favor of Defendant and against Plaintiff. 10. 11. 12. 13. New Matter Defendant incorporates by reference as though fully set forth herein the averments contained in Paragraphs 1 through 7 of the Answer above. Defendant incurred the debt on the Chevy Chase Visa no later than October of 1996. Defendant has refused to pay the debt incurred on the Chevy Chase Visa since at least November 1996. Plaintiff's claim is barred and/or limited by the statute of limitations. Plaintiff's claim is barred and/or limited by estoppel. Plaintiff's claim is barred and/or limited by waiver. 14. Plaintiff's claim is barred and/or limited by illegality. WHEREFORE, Defendant respectfully requests that this Court enter judgment in favor of Defendant and against Plaintiff. Respectfully submitted, KEEFE WOOD ALLEN & RAHAL, LLP Date: 1~-2.~-01 Elizal~eth J. Goldstein PA Attorney ID# 73779 KEEFE Wood Allen & Rahal, LLP 415 Fallowfield Road, Suite 102 Camp Hill, PA 17011-4906 717-612-5803 Attorneys for Defendant '11-1~-~00! OZ:~3PM FRO~KEEFER,WOOD,ALLEN_&_RkHAL 717612S80S T'I?? P.OO2/DO2 F-?88 VERIFICATION I, Julie Patterson, state subject to the penalties in 18 Pa. C.S.A. § 4904 relating to unswom falsification to authorities that the facts set forth herein are true and correct to the best of my knowledge, information and belief. Julie~j~erson - CERTIFICATE OF SERVICE I, Elizabeth J. Goidstein, Esquire, attorney for Defendant hereby certify that I have served this Answer with New Matter upon the following individuals by depositing a true and correct copy of the same in the United States mail, first-class postage prepaid, addressed as follows: Kenneth S. Shapiro, Esquire Attorneys for Plaintiff William Shapiro, Esquire, P.C. One Belmont Avenue, Suite 202 Bala Cynwyd, PA 19004 KEEFER WOOD ALLEN & RAHAL, LLP Eliza'~eth J. Goldstein PA Attorney ID # 73779 415 Fallowfield Road Suite 102 Camp Hill, PA 17011-4906 (717) 612-5803 Attorneys for Defendant Dated: WILLIAM SHAPIRO, ESQ. P.C. BY: Kenneth S. Shapiro, Esq. Identification No. 26850 One Belmont Ave., Suite 202 Bah Cynwyd, PA 19004 610-668-0707 BELMONT FINANCIAL SERVICES GROUP, INC. VS Plaintiff JULIE IVEY-PATTERSON Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CASE NO. 01-5950 Civil Term .PLAINTIFF, BELMONT FINANCIAL SERVICES GROUP, INC. ANSWER TO DEFENDANT, JULII~ IVEY-PATrERSON'S NEW MATi'EIt 9. Neither admitted nor denied, strict proof thereof is demanded at triai. 10. Denied. On the contrary, Defendant's last payment was made on or about December 22, 1997. 11. Denied. Paragraph 11 is a conclusion of law to which no responsive pleading is required. 12. Denied. Paragraph 12, is a conclusion of law to which no responsive pleading is required. 13. Denied. Paragraph 13 is a conclusion of law to which no responsive pleading is required. 14. Denied. Paragraph 14 is a conclusion of law to which no responsive pleading is required. WHEREFORE, Plaintiff respectfully asks that this Court enter judgment in favor of Plaintiff,, Belmont Financial Services Group, Inc. and against Defendant, Julie Ivey- Patterson. ./ Respectfully submitted, William Shapiro, Esq., P. C. CERTIFICATION OF SERVICE' I, Kenneth S. Shapiro, Esq., attorney for Plaintiff, hereby certify that I have served the within Plaintiff's Answer to Defendant's New Matter upon the following individual by depositing a true and correct copy of the same in the United States Mail postage prepaid to: Elizabeth J. Goldstein, Esq. Attorney for Defendant 415 Failowfield Road, Suite 102 Camp Hill, PA 17011-4906 DATED: hJ ~?e~c ~,~ t ~ C~o I WILLIAM SHAPIRO, ESQ. P.C. i.D. No. S ' _6~PL'~" Esq/ One Belmom Ave., Suite 202 Bala Cynwyd, PA 19004 (610) 668-0707 ' VERIFICATION I, Patricia M. Lieb, Assistant Treasurer of Belmom Financial Services Group, Inc., state subject to the penalties in 18 Pa. C.S.A. Sec. 4904 relating to unsworn falsification to authorities that she is authorized to make this verification on Plaintiff's behalf; and that the facts set forth here are true and correct to the best of her knowledge, information and belief. Date: Patricia M. Lieb IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA BELMONT FINANCIAL SERVICES GROUP, iNC. VS. JULIE IVEY PATTERSON CIVIL TERM NO. 01-5950 A/K/A JULIE IVEY PETITION FOR APPOINTMENT OF ARBITRATORS TO THE HONORABLE, THE JUDGES OF SAID COURT: Kenneth S. Shapiro, Esq., counsel for the plaintiffin the above action respectfully represents that: 1. The above-captioned action is at issue. 2. The claim of the plaintiffin the action is $4,481.27. There is no counterclaim. The following attorneys are interested in the case as counsel or are otherwise disqualified to set as arbitrators: Elizabeth J. Goldstein, Esq., Attorney for Defendant 610-668-0707 ORDER OF THE COURT ~ NOW, ~/~ ~g~// ~ ,2002, in c~onsidergion ofthe~foregoing petitigla, (~ ~_~ , Esq,, f~_/.Ox __o~.~_/~~... sq., and t/~'z~ff~ ~ ~/~fif/ ,Esq. are appo~'nted~arbitrators in the abOve-captioned acti~r[ a~ra~-d-f~. By' the~j. In The Court of Common Pleas of C~.berland County, Pennsylvania OATH We do soleaxmly swear (or affirm) chac we will supoort, obey and defend the Constitution of the United States and the Constitu~-%om of t~is wealth and that we wiii discharge the duties of our off ica We, the undersigned arbitrators, having been duly appointed and sworn (or affirmed), make the following award: (Note: If damages for delay are awarded, they shall be separately stated.) ' ' applicable.) Date of Hearing: Date of Award: · Arbitrator, dissents. IZ-9-oz_ (Insert name if c, NOTICE OF ~TRY OF AWARD award was en~ere~ Uoon par~ies or thei- ~L___ - -~c and notice ~hereof ~-'~'~',-~-'~Y.~ the above - - =-~urneys. o .... oM mazl ~o ~he Arbitrators' compensation to be paid upon appeal: DeoutY - ~--- WILLIAM SHAPIRO, ESQ. P.C. BY: Kenneth S. Shapiro, Esq. Identification No. 26850 One Belmont Ave., Suite 202 Bala Cynwyd, PA 19004 610-668-0707 IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PA BELMONT FINANCIAL SERVICES GROUP 1NC. Plaintiff VS Julie Ivey Patterson 100 Lakeside Drive Lewisberry, PA 17339 Defendant CIVIL ACTION NO. 01-5950 PRAECIPE TO SATISFY JUDGMENT TO THE PROTHONOTARY: Kindly mark the judgment in this case satisfied upon payment of your costs. Respectfully ~ ~Sh~r°'E"~orPlaintiff