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THIS IS AN ARBITRATION MATTER. ASSESSMENT OF
DAMAGES HEARING REQUIRED.
CORDON & 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
Arrow Financial Services as
Assignee of GE Money Bank
5996 W. Touhy Avenue
Niles, IL 60714
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
vs.
ROBERT KEENEY
270A MARSH RUN RD
NEW CUMBERLND PA 17070
DOCKET NO . ~`~ - (prI ~ ~ CIV~ ( "lG„M
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
i
COMPLAINT IN CIVIL-ACTION
1. Plaintiff is a debt buyer and successor in interest to
the original creditor as set forth in the caption of this
Complaint.
2. 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.
3. 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.
4. 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".
5 . All the credits to which the defendant (s) is entitled have
been applied and there remains a balance due in the amount of
$1,443.33.
6. Plaintiff has made demand upon the defendant(s)for
payment of the balance due of $1,443.33 but the defendant(s)has
failed and refused and still refuses to pay the same or any part
thereof.
. _ ,.
7 . Defendant' s last payment on account was made on April 27,
2005.
WHEREFORE, plaintiff claims of the defendant(s) the sum of
$1,443.33 plus applicable costs, interest and attorney's fees.
CORDON & WEINBERG, P.C.
BY:
FREDERIC W NBERG, ESQUIRE
JOEL M. FU NK, ESQUIRE
Attorney for Plaintiff
P01A.DB
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. ERG, ESQUIRE
aa3914s
Arrow Financial Services as Assignee o£
GE Money Bank
ROBERT REENEY
6019180903070031
State of New York §
County of Nassau § AFFIllAVIT
I, ~ ~ being duly served sworn accordin to
g
law, depose and say at:
1. I am the agent for the Plaintiff herein and I have custody
and control of the files relating to this account;
2. I have personal knowledge of the facts and circumstances in
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
that damages are sought as a direct result of said breach;
5. After allowing for all offsets and credits, a balance
remains on the subject account having account number
6019180903070031in the amount of $988.51; and
6. If called upon, affiant can testify at trial as to the facts
pertaining to this matter.
The above facts are true and 1rrect to the best of my knowledge,
information and belief.
(NAME OF AFFI )
Sworn to and Subscribed
ANNE M. TIMBER
before me thi s day ~jp~~ Aiaic, State of N~errrl'bIA
:1lIL I~ $ 2007 Na o1nsia2oTa
o 2 0 0 7 4ualif+ed 1n Sr;iMU~ C~u
. ~-1 G~'~ March 12010
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