HomeMy WebLinkAbout07-6934
2039193
THIS IS AN ARBITRATION MATTER.
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
ASSESSMENT OF
Arrow Financial Services as
Assignee of GE Money Bank
5996 W. Touhy Avenue
Niles, IL 60714
VS.
RONALD G SWEENEY
272 REDWOOD LN
CARLISLE PA 17013-7818
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
/f
DOCKET NO. 07 -1094Y
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
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
$3,635.11.
6. Plaintiff has made demand upon the defendant(s)for
payment of the balance due of $3,635.11 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 September
9, 2005.
WHEREFORE, plaintiff claims of the defendant(s) the sum of
$3,635.11 plus applicable costs, interest and attorney's fees.
GORDON & WEINBERG, P.C.
BY:
FREDERIC I. W INBERG, ESQUIRE
JOEL M. , ESQUIRE
Attorney for Plaintiff
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RONALD G SWEENEY
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State of New York
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County of Nassau
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law, depo
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2039193
Services as Assignee of
AFFIDAVIT
being duly'served sworn according to
1. II 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;
JI
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 onithe subject account having account number C77607061215919in
the amountlof $1,769.04; and
6. IIf called upon, affiant can testify at trial as to the facts
pertainingito this matter.
The above facts are true and orrect to the best of my knowledge,
information and belief.
f
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(NAME OF AFFIANT)
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Sworn to and Subscribed
I
before me ithis day
JUL. 1 007;
of /1, 1 t _Z,(Z0 7
lic
Arrow Financial
GE Money Bank
ANN. Notary P hlic, oaf Newer"
No. 01716.142028
Qualified in Suffoa Courdy
Commission Expires Mamb 13.2010
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IT! i a c?
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. BERG, ESQUIRE
SHERIFF'S RETURN - REGULAR
CASE NO: 2007-06934 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
ARROW FINANCIAL SERVICES
VS
SWEENEY RONALD G
TIMOTHY BLACK
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
SWEENEY RONALD G the
DEFENDANT
, at 0930:00 HOURS, on the 12th day of December-, 2007
at 272 REDWOOD LANE
CARLISLE, PA 17013-7818
RONALD G SWEENEY
by handing to
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: So Answers:
Docketing 18.00 _
Service 11.52
Affidavit
.00 '
Surcharge 10.00 R. Thomas Kline
00
12/13/2007
GORDON & WEINBERG
Sworn and Subscibed to By:
before me this day Deputy Sheriff
of A.D.
e
2039193
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
Arrow Financial Services as
Assignee of GE Money Bank
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
VS.
RONALD G SWEENEY
DOCKET NO. : 07 6934 CIVIL
TERM
PRAECIPE FOR ENTRY OF JUDGMENT FOR WANT OF AN ANSWER, ASSESSMENT
OF DAMAGES VERIFICATION OF ADDRESS AND NON-MILITARY SERVICE
TO THE PROTHONOTARY:
Enter judgment for want of an answer for plaintiff and
against defendant(s) above named only and assess damages
certified to be calculable as a sum certain from the complaint,
as follows:
Principal $1,769.04
Interest from 7/11/07
@18%; $166.63
Costs (Complaint & Service) $118.02
Total: $2,053.69
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: Arrow
Financial Services asAssignee of GE Money Bank and that the last
known address of defendant, RONALD G SWEENEY, 272 REDWOOD LN, CARLISLE
PA 17013-7818.
9
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.
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 Is+
is entered in favor of the
default for want of an ans,
$2,053.69 as per the above
Prot]
_ day of p b• , 2008 Judgment
plaintiff(s) and against defendant(s) by
Baer and damages assessed at the sum of ,
cer 'fication.
otary
GORDON & WEINBERG, P.C.
BY:
FREDERTIC I. EINBERG, ESQUIRE
JOEL Ml ,F K, ESQUIRE
Attorney for Plaintiff
2039193
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
Arrow Financial Services as Assignee
of GE Money Bank
VS.
RONALD G SWEENEY
TO/PARA
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
DOCKET NO. : 07 6934 CIVIL TERM
NOTICE OF INTENTION TO TAKE DEFAULT
RONALD G SWEENEY
272 REDWOOD LN
CARLISLE PA 17013-7818
DATE OF NOTICE/FECHA DEL AVISO: January 2, 2008
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE
PERSONALLY OR BY AN ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES
OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN
DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY 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) 249-3166COUNTY
GORDON & WEINBERG, P.C.
BY:
FREDERIC WEINB G, ESQUIRE
JOEL M. F SQUIRE
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2039193
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
Arrow Financial Services as
Assignee of GE Money Bank
VS.
RONALD G SWEENEY
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
DOCKET NO. : 07 6934 CIVIL
TERM
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.
L1 Judgment by Default $2,053.69
?L Money Judgment $
Judgment on Award of Arbitrators$
L1 Judgment on Verdict$
IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL
ATTORNEYS: FREDERIC I. WEINBERG OR JOEL M. FLINK, ESQUIRES AT THIS
TELEPHONE NUMBER: 484/351-0500
PRO ONOTI R
a/o1/os