The URL can be used to link to this page

Home My WebLink About07-4667 2034673 THIS IS AN ARBITRATION MATTER. ASSESSMENT OF DAMAGES HEARING REQUIRED. GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 PAUL M. SCHOFIELD, JR., ESQUIRE Identification No.: 81894 21 SOUTH 21ST STREET PHILADELPHIA, PA 19103 215/988-9600 BANK OF AMERICA, N.A., (USA) 275 S Valencia Ave CA7-70 Brea, CA 92823 vs. AMY E HAUF 6213 STANFORD CT MECHANICSBURG PA 17050-5245 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO . ~`~- ~(y(y7 Civ~ ( Term 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. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 r COMPLAINT IN CIVIL-ACTION 1. At all times relevant hereto, the defendant was the holder of a credit card, which at the request of the defendant was issued to the defendant by the plaintiff under the terms of which the plaintiff agreed to extend to defendant the use of plaintiff's credit facilities. 2. Defendant 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 received and accepted goods and merchandise and/or accepted services or cash advances through the use of the credit card issued by the Plaintiff. A true and correct copy of an Affidavit of Account is attached hereto as Exhibit "A". 4. All the credits to which the defendant is entitled have been applied and there remains a balance due in the amount of $3,682.91. 5. Plaintiff has made demand upon the defendant for payment of the balance due of $3,682.91 but the defendant has failed and refused and still refuses to pay the same or any part thereof. 6. Defendant's last payment on account was made on April 30, 2006. WHEREFORE, plaintiff claims of the defendant the sum of $3,682.91 plus applicable costs, interest and attorney's fees. CORDON & WEINBERG, P.C. BY: FREDERIC I. WEI ERG, ESQUIRE PAUL M. SCH ELD, JR., ESQUIRE Attorney for Plaintiff POlA r VERIFICATION FREDERIC I. WEINBERG, ESQUIRE, hereby states that he is the attorney for the Plaintiff 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. FREDERIC I. I RG, ESQUIRE EXHIBIT "A" _~ J~ _ STATE OF Georgia ) AFFIDAVIT OF ACCOUNT COUNTY OF Cobb ) BANK OF AMERICA, N.A., (USA) Y. AMY E HAUF COMES NOW, Nicole Gum~ell, and after being duly sworn before the below person authorized to administer oaths states the following: 1. 1 am over 18 years old and su' 'uri . 2, i am agent for Bank of America, N.A. (USA). 3. [ am familiar with the books and records of the Plaintiff. 4. These books and records are kept in the ordinary course of business. 5. The agreement attached hereto is true and correct. 6. The Defendant (s) owe (s) the principal sum of $3,007.47. 7. The Defendant (s) owe (s) past due interest of $675.44 through September 5, 2006. 8. I know no liability insurance, bond or other security which may be available to pay this debt. 9. The Defendant (s) account number for which he owes the debt is 4888890999300588. I0. The Defendant (s) is/are not a minor nor an incompetent person. 1 1. Affiant has no knowledge of whether the Defendant (s) is/are on active duty in the military. l2. The Defendant (s) is/are past due on this account and in breach of the contracriial agreement to pay as agreed. Agent Nicole Gumiell Bank of America, N.A. (USA) Sworn to and subscribed before me this L~f ~, 200 ' TARY PUB My CommissionExpires~`l~ ~(~"~ Ci(1RDONlii WF.MBF.RG. P.C 061:0228 ,/`~~~ROT,r~,, ~F~ -'GE~ Res ''kE Z 20 p j. ~LIC -~ O~ ,-:!i~~~,,r: BANK OF AMERICA, N.A. (USA) nnr a xnur 6]13 STANtORD CI' M6CXJW ICSa~'M1G PA i~050-S:~s ACCUI'NT NL`MBER BALANCE AS OF DUE DATE PAYMENT GN OS D 4080090999300500 January 11, 2007 PAST DUE $3,682.91 EHaks Chacb t.y'ble to But M Nnerka. YA (DSA) g9YL0~ 1801[ MIR Ot AIORIOA. M.l. (09A7 YOUR ACCOUNT WITH BANK OF AMERICA, N.A. (USA) IS PAST DUE $3,682.91. THE PAST DUE PRONCIPAL BALANCE OF $3, OOE.47IAND IINTEREST ON THAT BALANCEUOF $67049 THAT DNAS ACCRUEDISINCE September 5, 2006. PLEASE REMIT IMMEDIATELY. IF YOU HAVE ALREADY SENT A PAYMENT FOR THE ABOVE AMOUNT, THANK YOU. ~ ~ -O ~ "~ ~ ~ oho O b D ~~ ~ v -,-' - „ ~ ~,, ~( ~ 1: .~ ~a ;; ~.- ~~ .' 4 J 7 ~ 'n r=._ f 1V~' ~.:, ~;.r•. ~ ~ c ~_ T~ - ~ c.. ~, y~ `~ ~ _~ .~- ' ~ tom ~ 'K SHERIFF'S RETURN - REGULAR CASE NO: 2007-04667 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BANK OF AMERICA NA VS HAUF AMY E KENNETH GOSSERT Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon HAUF AMY E the DEFENDANT at 1924:00 HOURS, on the 29th day of August 2007 at 6204 STANFORD CT MECHANICSBURG, PA 17050-5245 by handing to KEITH BELL (HUSBAND) 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 4~ i~-jb ~ `-/rte So Answers: 18 .0 0 .~~~ 21.12 .00 10.00 R. Thomas Kline .00 r 49.12 08/30/2007 GORDON & WEINBERG Sworn and Subscibed to before me this day By: of A.D. GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 81894 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 BANK OF AMERICA, N.A., (USA) COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. AMY E HAUF DOCKET NO. 07-4667 PRAECIPE FOR JUDGMENT The Prothonotary will please enter Judgment in the above matter by default for want of an answer against the Defendant, AMY E HAUF, and assesse the damages as per statement below. FREDERIC I. WEIN ER ESQUIRE JOEL M. FLINK, E IRE Attorney for Plaintiff Principal $3,682.91 Costs (Complaint & Service) $127.62 Total: $3,810.53 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 (10) days prior to the date of the filing of this Praecipe. FREDERIC I. WEI ESQUIRE JOEL M. FLINK, ESQUIRE Attorney for Plaintiff Filed: By the Prothonotary: AND NOW, this '~' day of ~har 2007 Judgment is entered in favor of the plaintiff(s) and against defendant, for want of an answer and damages assessed at the sum of $3,810.53 as per the above certification. 5 ~, othonotary 0~8 ~- GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 81894 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 BANK OF AMERICA, N.A., (USA) COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. AMY E HAUF DOCKET NO. 07-4667 CERTIFICATION OF ADDRESS I hereby certify that the precise residence of the holder of the within judgment is; BANK OF AMERICA, N.A., (USA) and that the last known address of defendant, AMY E HAUF, 6213 STANFORD CT, MECHANICSBURG PA 17050-5245. GORDON & WEINBERG, P.C. BY: FREDERIC NBERG, ESQUIRE JOEL M. F NK, ESQUIRE Attorney for Plaintiff e 1 • . GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 81894 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 BANK OF AMERICA, N.A., (USA) COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. AMY E HAUF DOCKET NO. 07-4667 AFFIDAVIT OF NON-MILITARY SERVICE FREDERIC I. WEINBERG, ESQUIRE, 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 the defendant is, 6213 STANFORD CT, MECHANICSBURG PA 17050-5245; that 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. Sworn to and Subscribed L Before me this y Day of ~ ~ ~, 2007, Q~ ~ lQr~~ Not3rV Publ'c COMMON W~gLTH pF P~{y~y~ i- ~ v,v~ I A NOTARIAL SEAT. BARBARA A. PISANICK, Notary Putt City of PhilaCelphia, Phita. County M Commission Ex fires Ju 29, Zl1pg FREDERIC I. EINB G, ESQUIRE JOEL M. FLIN SQUIRE Attorney for Plaintiff 2034673 ~_ '~~' ..:.~ N~ C GORDON & WEINBERG, P.C. BY: FREDERIC I, WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 BANK OF AMERICA, N.A., (USA) AMY E HAUF TO/PARA vs. COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. 07-4667 NOTICE OF INTENTION TO T71lCS DRFIIULT AMY E HAUF 6213 STANFORD CT MECHANICSBURG PA 17050-5245 DATE OF NOTICE/FECHA DEL AVISO; September 28, 2007 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO SLATER A WRITTEN APPEARANCE PERSONALLY OR BY AN ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DSFEN9ES OR OBJECTIONS TO THE CLAIMS 3ET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TR1 DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAX BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 GORDON & WEINBERG, P.C. HY: FREDERIC I WEI ERG, ESQUIRE JOEL M. FL ES DIRE P10D-2 o `~~ c~ -~-~ , ~ ~ .b i. ..... ,,C.. ~- ~ r-~ (.. 5~ -~: ~ ~ - ~° •r; ~ ~, ....i GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 2034673 BANK OF AMERICA, N.A., (USA) vs. AMY E HAUF COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. 07-4667 NOTICE PURSUANT TO RULE 236 OF THE SUPREME COURT OF PENNSYLVANIA, YOU ARE HEREBY NOTIFIED THAT A JUDGMENT $Y DEFAULT HAS BEEN ENTERED AGAINST YOU IN THE ABOVE PROCEEDING IN THE AMOUNT OF $3,810.53. IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL GORDON & WEINBERG, P.C. AT 215/988-9600. GORDON & WEINBERG, P.C. Dated: October 9, 2007 BY: FREDERIC I`~~WF~,~TBERG, ESQUIRE JOEL M. FLI ESQUIRE Attorne~r for Plaintiff GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 2034673 ~~ t~7TARY 10 SAP -8 PM 3~ 15 ~~~YLVAI~A ~ BANK OF AMERICA, N.A., (USA) vs. AMY E HAUF COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET N0. 07-4667 ORDER TO SATISFY JtJDG~iT TO THE PROTHONOTARY: Kindly mark the judgment entered October 17, 2007 in the above-captioned matter satisfied upon payment of your costs only. GORDON & WEINBERG, P.C. BY• FREDERIC I. WEI BERG, ESQUIRE JOEL M. FLI ESQUIRE Attorney for Plaintiff P005 ~S•OC) PA DEFT C~ R 1'f' l S 7310 030~.~1 e~a~r7g5~