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HomeMy WebLinkAbout03-5033GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, Identification No.: 41360 21 SOUTH 21ST STREET PHILADELPHIA, PA 19103 215/988-9600 NCO PORTFOLIO MANAGEMENT, ASSIGNEE OF MBNA AMERICA BANK 1804 WASHINGTON BLVD. BALTIMORE, MD 21230 VS . SUZANNE J. GOSNELL 2468 COPE DR. MECHANICSBURG PA 17055 ESQUIRE INC. : NOTICE THIS IS AN ARBITP~ATION MATTER. ASSESSMENT OF DAMAGES HEARING REQUIRED. COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET 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 AMD 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 THIS IS AN ARBITRATION MATTER. ASSESSMENT OF DAMAGES HEARING REQUIRED. GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, Identification No.: 41360 21 SOUTH 21ST STREET PHILADELPHIA, PA 19103 215/988-9600 ESQUIRE NCO PORTFOLIO MANAGEMENT, INC. ASSIGNEE OF MBNA AMERICA BANK 1804 WASHINGTON BLVD. BALTIMORE, MD 21230 ¸US . SUZANNE J. GOSNELL 2468 COPE DR. MECHANICSBURG PA 17055 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO.: O.'~ ~ .S-~3~3 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,s predecessor in interest, 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. All the credits to which the defendant(s)is entitled have been applied and there remains a balance due in the amount of $1,337.15. 5. Plaintiff has made payment of the balance due of failed and refused and still refuses thereof. demand upon the defendant(s)for $1,337.15 but the defendant(s)has to pay the same or any part WHEREFORE, plaintiff claims of the defendant(s)the sum of $1,337.15, plus 24% interest from the date of 9/3/02, court costs, and attorney's fees all of which is justly due and owing from defendant(s) to plaintiff. GORDON & WEINBERG, BY: P01A 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. FREDERIC I. WEIN~E~ESQUIRE SHERIFF'S RETURN - CASE NO: 2003-05033 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND NCO PORTFOLIO MANAGEMENT INC VS. GOSNELL SUZANNE J U.S. CERTIFIED MAIL R. Thomas Kline , Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law served the within named DEFENDANT ,GOSNELL SUZANNE J , by United States Certified Mail postage prepaid, on the 2nd day of October ,2003 at 0000:00 HOURS, at 1000 N ARIZOLA ROAD APT 115 CASA GRANDE, AZ 85222 and attested copy of the attached COMPLAINT & NOTICE with receipt card was signed by RETURNED AT "UNCLAIMED" 00/00/0000 , a true Together The returned PA. on Additional Comments: SERVICE WAS ALSO ATTEMPTED AT 2468 COPE DRIVE MECHANICSBURG, DEFENDANT'S FATHER HAD HER CALL US. SHE GAVE US HER ADDRESS IN ARIZONA. Additional Comments So ans~r.~ ,~.~ ~i~ R. Thomas k~line Sheriff of Cumberland County Sheriff's Costs: Docketing 18.00 Service 6.90 Cert Mail 4.42 Surcharge 10.00 .00 39.32 Paid by GORDON & WEINBERG Sworn and subscribed to before me this O~ day of ~ 'Pgothonotary on 10/24/2003 o§ ~