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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 P01A.DB 1 r } I f I I RONALD G SWEENEY { 077607061215919 I State of New York I County of Nassau I'\, law, depo § 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 I (NAME OF AFFIANT) f i 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 w 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 P10D-2 rl, Q ? cra r- r v ,.? 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