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Home My WebLink About07-5175_ THIS IS AN ARBITRATION MA DAMAGES HEARING REQUIRED. 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 Capital One Bank 4851 Cox Road Glen Allen, VA 23060 vs. APRIL A STONEROAD 105 POPLAR ST E PENNSBORO PA 17025 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. a7 - .S7'~.S' Cr ~v~ ~~C Ci~ 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 $E 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 2039100 TIER. ASSESSMENT OF 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. A true and correct copy of the Statement of Account is attached hereto as Exhibit "A". 4. All the credits to which the defendant (s) is entitled have been applied and there remains a balance due in the amount of $1,662.23. 5. Plaintiff has made demand upon the defendant(s)for payment of the balance due of $1,662.23 but the defendant(s)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 July 24, 2004. WHEREFORE, plaintiff claims of the defendant(s) the sum of $1,662.23 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE JOEL M. FLINK, ESQUIRE Attorney for Plaintiff POlA VERIFICATION FREDERIC I. WEINBERG, 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. 1 L FREDERIC I. WEINBERG, ESQUIRE 2039100 Capital One Hank APRIL A STONBROAD 4388641771186496 s ...~ ...~ AFFIDAVIT s I, SARA RIIBIN, being duly served sworn according to law, depose ~ and say that: ~ _ ~ 1. I am the agent for the Plaintiff herein and I have custody . =,,. and control of the files relating to this accoun ; 2. I have personal knowledge of the facts and circumstances in s connection with this case; 3. Plaintiff's files are maintained in the usual and ordinary course of business; 4. This action is based on a claim for breach of contract and :ems that damages are sought as a direct result of said breach; a~ -~- 5. After allowing for all offsets and credits, a b balance er remains on the subject account having account num 4388641771186496in the amount of $1,643.95; and 6. If called upon, affiant can testify at trial as to the facts pertaining to this matter. The above facts are true and co ec too the best y knowledge, information and belief. • 8~ S SIN Sworn to and Subscribed 88~ ~ before me this day >~ ~ ~ f i of 2007 .... ~ s Notary Publi I ~ ~ ~~u James J, Flood Ne ,~~~' w YadC Np~ry Public, State 0 Reg. #Oi FL6142574 • Qualified in Suffolk Coun 2010 2 1 My Commission Exoi~es 031 N ~ ~~ 0 F J ~! r, ~ .., C ~• C.. ~~~ l_ i. ~_^-'{ ^,: N ca c:~a N "'t~ !V -.-1--{1 ~~'t TS ~~ _~ _~~~ ..~ ~`~ t~7 ("Ci -G SHERIFF'S RETURN - REGULAR CASE NO: 2007-05175 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CAPITAL ONE BANK VS STONEROAD APRIL A DAVID MCKINNEY Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE STONEROAD APRIL A DEFENDANT was served upon the at 1740:00 HOURS, on the 30th day of August 2007 at 105 POPLAR STREET SUMMERDALE, PA 17093 APRIL STONEROAD by handing to a true 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 15.36 Affidavit .00 Surcharge 10.00 .00 9'»ID~ ~ 43.36 Sworn and Subscibed to before me this day So Answers: ~~~~ " /• R. Thomas Kline 08/31/2007 GORDON & WEINBERG By: ~ eputy Sheriff of A.D. CAPTfAL ONE BANK IN THE COURT OF COMMON PLEAS PLAINTIFF OF CUMBERLAND COUNTY, PENNSYLVANIA VS. APRIL A. STONEROAD CIVIL ACTION NO: o~-5i75 DEFENDANT ANSWER TO PLAINTIFF'S COMPLAINT i. Denied. Defendant is without knowledge or information sufficient to form a belief as to the truth of the matters averred in Paragraph i of Plaintiffs Complaint and strict proof thereof is demanded at trial. 2. Denied. Defendant is without knowledge or information sufficient to form a belief as to the truth of the matters averred in Paragraph 2 of Plaintiff s Complaint, and strict proof thereof is demanded at trial. 3. Denied. It is specifically denied that Exhibit "A" evidences that Defendant applied for the credit card issued. As exhibit "A" speaks for itself, any attempt to summarize or characterize same is denied. 4. Denied. It is specifically denied that Exhibit "A" evidences that Defendant applied for the credit card issued. As exhibit "A" speaks for itself, any attempt to summarize or characterize same is denied. 5. Denied. It is specifically denied that Plaintiff has repeatedly requested payment and strict proof thereof is demanded at trial. 6. Denied. The averments set forth are conclusions of law to which no responsive pleading is required. WHEREFORE, Defendant April A. Stonere~~d demands judgment in her favor, together with all applicable court costs. Respectfully submitted, April A. Stoneroad Pro Se VERIFICATION I, hereby verify that the averments made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of i8 Pa. C.S.A. 4904 relating to unsworn falsification to authorities. r CERTIFICATE OF SERVICE I, April A. Stoneroad do hereby certify that I sent a true and correct copy of the foregoing document to all counsel of record by placing a copy of the same in the United States first-class mail, postage prepaid, addressed as follows: Frederic 1. Weinberg, 4?360 Joel M. Flink, 41200 GORD4N ~ WElNBERG, P.C. 1001 E. Hector Street, Suite 220 Conshohocken, PA 19428 Attorneys for P/aindffs Date: ~ 1"~ ~-' ~- ~.F ~ ~~ ~~-~., ~. ~~'~= ~. ~"U ~' ~s'.~ ~ ~~ ., ---• GORDON & WEINBERG, P.C. r 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 Capital One Bank COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. DOCKET NO. 07-5175 APRIL A STONEROAD PRAECIPE FOR JUDGMENT The Prothonotary will please enter Judgment in the above matter by default for want of an answer against the Defendant, APRIL A STONEROAD, and assess the damages as per statement below. FREDERIC I. WEINB G ESQUIRE JOEL M. FLINK, ESQ IRE Attorney for Plaintiff Principal $1,643.95 Interest from 7/5/07 C~9.9% $42.36 Costs (Complaint & Service) $121.86 Total: $1,808.17 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) d y prior to the date of the filing of this Praecipe.`' FREDERIC I. WEI G, ESQUIRE JOEL M. FLINK, ESQUIRE Attorney for Plaintiff Filed: By the Prothonotary: AND NOW, thi s ~Jr~~ day of (~C:'~'D~1 2 0 0 7 Judgment is entered in favor of the plaintiff(s) and against defendant, for want of an answer and damages assessed at the sum of $1,808.17 as per the above certification. [~ s ~ h- ~- Pr thonotary D~ ~, - --- CORDON & 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 Capital One Bank COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. DOCKET NO. 07-5175 APRIL A STONEROAD CERTIFICATION OF ADDRESS I hereby certify that the precise residence of the holder of the within judgment is; Capital One Bank and that the last known address of defendant, APRIL A STONEROAD, 105 POPLAR ST, E PENNSBORO PA 17025. CORDON & WEINBERG, P.C. BY: FREDERIC I. NBERG, ESQUIRE JOEL M. FLINK, ESQUIRE Attorney for Plaintiff A .--, 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 Capital One Bank COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. DOCKET NO. 07-5175 APRIL A STONEROAD 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, 105 POPLAR ST, E PENNSBORO PA 17025; 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 Before me t~hi s ~' Day Gu~ ~~~v~ Notary Public COMMO ALTH OF PENNSYLVANIA NOTARIAL SEAL BARBARA A. PISANICK, Notary Public City of Ph~adelphia. Ph~a. County Commission Ex ices Jul 29,201)9 FREDERIC I. EI ERG, ESQUIRE JOEL M. FLINK, ESQUIRE Attorney for Plaintiff _~ ..:~ e~ _~ s~ ~_ '~ ..:~ ao~9ioo GORDQN & WSINBERG, P.C. BY: FREDERIC I. WBINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 494/351-0500 Capital One Bank APRIL A STONEROAD TO/PARA vs. COURT OP COMMON PLEAS CUMBERLAND COUNTY DOCKET NQ. 47-5175 ~QOTICS OP II~TEliTIOIQ TO TAlCB DLFAtT~.T APRIL A STQNEROAD IOS PC}PLAR ST E PENNSBORO PA 17025 DATE OF NOTICE/FECHA DEL AVISO: September 27, 2007 Il3PORT1-1~T lIQTICI6 YOU ARE IN DEFAUI,~T BECAUSE YOV HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY AI'1 ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DBFENSEB OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOiJ. UNLESS YOU ACT WITHIN TEN DAYS PROM THE DATE QF THIS NOTIC$, A aUDGMENT MAY BB ENTERED AGAINST YOU WITHOUT A HEARING AIAD YOIJ MAY .LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYBR 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 FARING A LAWYER. _..__...__.,.IF YOU CANNOT AFFORD TO HIRE A I,~AWYER, ..TI3I8 OFFLC$ MAY BE ABLE TO .. .. PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEB. CUMBERLAND COUNTY aA.R ASSOCIATION 32 S. BEDFORD STREET CARLISLE, PA 17013 (717} 249-3166 GORDON & WEINBERG, P.C. BY : ,, FRBDBRIC I. W INBE ESQUIRE JOEL M. FLINK, IRE P10D-2 0 ~• -(A. ~- r,a ~~ ~ ~ -i-1 _ _s ~ ,~ ~ ~ ~ D - ...~ ~ F --. , , Ul ~ ; _ ~ ; -A -~ "` a 1 ~ --C . 4 '"_ ' 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 2039100 Capital One Bank COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. DOCKET N0. 07-5175 APRIL A STONEROAD NOTICE PURSUANT TO RULE 236 OF THE SUPREME COURT OF PENNSYLVANIA, YOU ARE HEREBY NOTIFIED THAT A JUDGMENT BY DEFAULT HAS BEEN ENTERED AGAINST YOU IN THE ABOVE PROCEEDING IN THE AMOUNT OF $1,808.17. IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL GORDON & WEINBERG, P.C. AT 215/988-9600. GORDON & WEINBERG, P.C. Dated: October 8, 2007 BY: FREDERIC I W INBERG, ESQUIRE JOEL M. FLI ESQUIRE Attorney for Plaintiff ~~ ~-~ ~~ ~ ,0%5/0~ / OO IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CAPITAL ONE BANK Pl i iff 5175 207 N0 07 a nt , . Fn vs. - v. APRIL A STONEROAD . Defendant = CZ RULE 1312-1 The Petition for Appointment of Arbitrators shall be substantially in the- Following form: - PETITION FOR APPOINTMENT OF ARBITRATORS TO THE HONORABLE, THE JUDGES OF SAID COURT: JOEL M. FLINK ,counsel for the p defendant in the above action (or actions), respectfully represents that: 1. The above-captioned action (or actions) is (are) at issue. 2. The claim of plaintiff in the action is $ 1662.23 The counterclaim of the defendant in the action is The following attorneys are interested in the case(s) as counsel or are otherwise disqualified to sit as arbitrators: JOEL M. FLINK, ESQ. WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. ly submitted, Aspf ORDER OF COURT k'uaq,?@? ,a icy>?o a AND NOW, 19 , 20AA , in consideration of the foregoing petition, Esq., and w? Esq., and Esq., are appointed arbitrators in t e above _ap?w_ ed action (or actions) as prayed for. p N Sd C) cca, By the Court LA- Cq_ c°-:"V Soel M. Qp ON <?- / 1{ roa Kevin .Hess, P.J. J(n CL- fip Ezuj. 0- ?? c ?? / CAPITAL ONE BANK, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA: VS. CIVIL ACTION - LAW APRIL A. STONEROAD, NO. 07-5175 CIVIL Defendant ORDER AND NOW, this Z-/ ' day of June, 2012, the appointment of a Board of Arbitrators in the above-captioned case is VACATED. Stephanie Chertok, Esquire, Chairman, shall be paid the sum of $50.00. ? Stephanie Chertok, Esquire Court Administrator BY THE COURT, Z`t 1"04 Kevin ess, P. J. _ N - 0 2039100 GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 41200 r,s.p? c 1001 E. Hector Street, Ste 220 `,rr Conshohocken, PA 19428 N) v i 484/351-0500 Capital One Bank COURT OF COMMON PLEAS":- CUMBERLAND COUNTY vs. APRIL A STONEROAD DOCKET NO. : 07-5175 PRAECIPE FOR ENTRY OF JUD' rNT BY AGREEMENT TO THE PROTHONOTARY: Enter judgment by agreement for plaintiff and against defendant(s) APRIL A STONEROAD above named only and assess damages certified to be calculable as a sum certain from the complaint, as follows: Principal $2,779.10 Total: $2,779.10 Understanding the false statements made herein are subject to penalty under 18 Pa.C.S.A. §4904, Unsworn Falsification to Authorities, I verify that.: 1. The last known addresses of the parties are: Capital One Bank and that the last known address of defendant, APRIL A STONEROAD, 105 POPLAR ST, SUMMERDALE PA 17093. 2. The annexed notice(s) of intention to file this praecipe was (were) mailed to all parties, defendant and to their record attorneys, if any, after default occurred, and at. least ten days prior to the date of filing of this praecipe. 416-50 P4 A-r7-1 Cl Ila= er a,71 t43 ou?ce kui la 3. The said defendant(s) is (are) not in the military service of the United States or otherwise within the coverage of the Soldiers and Sailors Civil Relief Act and is (are) over 18 years of age. AND NOW, this Ol? day of June 2012 Judgment by agreement is entered in favor of the plaintiff(s) and anst defendant(s) at the sum of , $2,779. as #M*,r t*R.Ngbove ce fication. Prothonotary GORDON & WEINBERG, P.C. BY. FREDERI I. WZINBERG, ESQUIRE JOEL M. Fh K, ESQUIRE Attorney for Plaintiff A '4 2039100 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 Capital One Bank COURT OF COMMON PLEAS Prothonotary of Cumberland County VS. APRIL A STONEROAD DOCKET NO. : 07-5175 JUDG 48M BY AGREE IM AND NOW, this day of p , 2012, it is hereby stipulated and agreed to by and between, APRIL A STONEROAD her successors and assigns and Frederic I. Weinberg, Esquire, counsel for Capital One Bank that the Court enter a determination in the above-captioned case as follows: 1. Judgment shall be entered in the amount of Two Thousand Seven Hundred Seventy-Nine Dollars and Ten Cents($2779.10) in favor of Capital One Bank and against, APRIL A STONEROAD her successors and assigns; 2. Plaintiff, Capital One Bank will agree to accept the sum of $28.75 per week from, APRIL A STONEROAD her successors and assigns. The first payment of $28.75 per week shall become due and payable on Firday May 25, 2012 and then on every Friday of every month thereafter until the Stipulated Judgment is paid in full; 3. In the event that APRIL A STONEROADsuccessors and assigns do 4 4 not make payments as prescribed in paragraph 2, they will be considered in default and the Plaintiff, Capital One Bank shall be allowed to exercise any and all remedies available at law. Date: Dater APRIIL A S Defendant FREDERIC I. WE NBERY Esquire Attorney for P ain ff I . D. H1360 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484%351-0500 2039100 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 Capital One Bank COURT OF COMMON PLEAS CUMBERLAND COUNTY Vs. DOCKET NO. : 07-5175 APRIL A STONEROAD NOTICE Pursuant to Pa.R.Civ.P. 236 of the Supreme Court of Pennsylvania, you are hereby notified that a judgment has been entered against you in the above proceeding as indicated below,. /X/ Judgment by Agreement $2,779.10 Money Judgment $ Judgment on Award of Arbitrators$ Judgment on Verdict$ IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL ATTORNEYS: FREDERIC I. WEINBERG OR JOE F NK, UIRES AT IS TELEPHONE NUMBER: 484/351-0500 PROTHONOTARY 2039100 :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 PENNSYLVANIA y�`�� C0Urdr r VA Pyr, ., Capital One Bank vs. APRIL A STONEROAD TO THE PROTHONOTARY: COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 07-5175 ORDER TO SATISFY JUDGMENT Kindly mark the judgment entered June 25, 2012 in the above - captioned matter satisfied upon payment of your GORDON & WEINBERG, P.C. BY: P005 costs only. FREDERIC I. JOEL M. FIJI Attorney f N:ERG, ESQUIRE K, ESQUIRE r Plaintiff auk C m-/0600 ,t/ )(P los