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HomeMy WebLinkAbout03-4050NCO03445 THIS IS AN ARBITRATION MATTER. ASSESSMENT OF DAMAGES HEARING REQUIRED. GORDON & WEINBERG, P.C. BY: PAUL M. SCHOFIELD, JR.,ESQUIRE Identification No.: 81894 21 SOUTH 21ST STREET PHILADELPHIA, PA 19103 215/988-9600 DISCOVER BANK 3311 MILL MEADOW DRIVE HILLIARD OH 43026 VB. Deb Moore 476 Berkshire Lane Mechanicsburg PA 17050 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO.: 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 APPE/kP3kNCE 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. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. BEDFORD STREET CARLISLE, PA 17013 (717) 24903166 NCO03445 THIS IS AN ARBITRATION MATTER. ASSESSMENT OF DAMAGES HEARING REQUIRED. GORDON & WEINBERG, P.C. BY: PAUL M. SCHOFIELD, JR.,ESQUIRE Identification No.: 81894 21 SOUTH 21ST STREET PHILADELPHIA, PA 19103 215/988-9600 DISCOVER BANK 3311 MILL MEADOW DRIVE HILLIARD OH 43026 Deb Moore 476 Berkshire Lane Mechanicsburg PA 17050 COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: COMPLAINT IN CIVIL-ACTION 1. At all times relevant hereto, the defendant(s) was the holder of a credit card, which at the request of the defendant(s) was issued to the defendant(s) by the plaintiff under the terms of which the plaintiff agreed to extend to defendant(s)the use of plaintiff's credit facilities. 2. Defendant(s) accepted and used the aforesaid credit card so issued and by so doing agreed to perform the terms and conditions prescribed by the plaintiff for the use of said credit card. 3. The defendant(s)received and accepted goods and merchand- ise and/or accepted services or cash advances through the use of the credit card issued by the Plaintiff. 4. Ail the credits to which the defendant(s)is entitled have been applied and there remains a balance due in the amount of $3,170.21. 5. Plaintiff has made demand upon the defendant(s)for payment of the balance due of $3,170.21 but the defendant(s)has failed and refused and still refuses to pay the same or any part thereof. WHEREFORE, plaintiff claims of the defendant(s)the sum of $3,170.21 plus 6% interest from 2/2/2001 plus court costs, and attorney's fees all of which is justly due and owing from defend- ant(s) to plaintiff. P01A GORDON & WEINBERG, P.C. ~SLUIRE Attorney for Plaintiff VERIFICATION PAUL M. SCHOFIELD, JR.,ESQUIRE, hereby states that he is the attorney for the Plaintiff(s) in this action 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.A. Section 4904 relating to unsworn falsification to authorities. Date: August 12, 2003 OFIELD, JR. ,ESQUIRE SHERIFF'S RETURN - CASE NO: 2003-04050 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DISCOVER BANK MOORE DEB VS REGULAR RICHARD SMITH Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to says, the within COMPLAINT & NOTICE was served upon MOORE DEB DEFENDANT , at 1740:00 HOURS, on the 19th day of August at 476 BERKSHIRE LANE MECHAiqICSBURG, PA 17050 by handing to DEB MOORE a true law, the , 2003 and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 7.59 Affidavit .00 Surcharge 10.00 .00 35.59 Sworn and Subscribed to before me this 2~ day of ~3- ~ A.D. t t~rot honot ary R. Thomas Kline 08/20/2003 GORDON & ~~ By: elSuty Sheriff GORDON & WEINBERG, P.C. By: PAUL M. SCHOFIELD, JR.,ESQUIRE Identification No.: 81894 21 SOUTH 21ST STREET PHILADELPHIA, PA 19103 215/988-9600 DISCOVER BANK : : VS. : : Deb Moore : COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO.: 03-4050 civil PRAECIPE TO WITHDRAW C(H~PLAINT TO THE PROTHONOTARY: Kindly withdraw the above-captioned action, prejudice. without Attorney for Plaintiff P006