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Home My WebLink About08-04782040523 IS IS AN ARBITRATION MATTER. ASSESSMENT OF MAGES HEARING REQUIRED. GORDON & WEINBERG, P. . BY: FREDERIC I. WEI E Identification N . JOEL M. FLINK, E Q Identification N . 1001 E. Hector Street Conshohocken, PA 194 8 484/351-0500 FIA CARD SERVICE, N.A BANK OF AMERICA, N.A. 1825 E. BUCKEYE RD PHOENIX, AZ 85034 VS. CRAIG S JUMPER 320 N BEDFORD ST CARLISLE PA 17013-190 320 N BEDFORD ST CARLISLE PA 17013-1909 RG, ESQUIRE : 41360 UIRE : 41200 Ste 220 f/k/a COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : DS- 1475 CtV c I Tc-m NOTICE YOU HAVE BEEN SUED N COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIMS SET FORTH IN THE FOLLOWING PA ES, YOU MUST TAKE ACTION WITHIN TWENTY (20) DAYS AFTER THIS COMPLAINT AND NOTICE E 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 WIT OUT YOU AND A JUDGEMENT MAY BE ENTERED AGAINST YOU BY THE COURT WITHOUT FURTHE NOTICE FOR ANY MONEY CLAIMED IN THE COMPLAINT OR FOR ANY OTHER CLAIM OR RELIE 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 1. Plaintiff i a debt buyer and successor in interest to the original creditor as set forth in the caption of this Complaint. 2. At all time relevant hereto, the defendant(s) was the holder of a credit card, which at the request of the defendant(s) was issued to the def ndant(s) by the plaintiff under the terms of which the plaintiff greed to extend to defendant(s)the use of plaintiff's credit fa ilities. 3. Defendant(s? accepted and used the aforesaid credit card so issued and by s doing agreed to perform the terms and conditions prescribe by the plaintiff for the use of said credit card. 4. The defenda t (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, if available, 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 $3,917.10. 6. Plaintiff has made demand upon the defendant(s)for payment of the balance due of $3,917.10 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 03/15/2007. WHEREFORE, plain iff claims of the defendant (s) the sum of $3,917.10 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDERIC I. W IN RG, ESQUIRE JOEL M. FLINK, ESQUIRE Attorney for Plaintiff P01A.DB VERIFICATION FREDERIC I. WEIN ERG, 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. WEINB , ESQUIRE ? ? - I rya c f 7 ? j ?' . n p " 7 G ? a C p z C SHERIFF'S RETURN - REGULAR CASE NO: 2008-00478 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FIA CARD SERVICE NA VS JUMPER CRAIG S MICHAEL BARRICK Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon JUMPER CRAIG S the DEFENDANT , at 0014:41 HOURS, on the 31st day of January , 2008 at 320 N BEDFORD STREET CARLISLE, PA 17013-1909 by handing to ADULT IN CHARGE 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 Service Affidavit Surcharge alb?loP 7," 18.00 4.80 .00 10.00 .00 3? 2.80 Sworn and Subscibed to before me this day So Answers: l? R. Thomas Kline 02/05/2008 GORDON & WEINBE By: Dep ty Sheriff of A. D. FIA CARD SERVICES f/k/a BANKOF AMERICA Plaintiff VS. CRAIG S. JUMPER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-478 Civil Action - Law ANSWER AND NOW comes the Defendant by and through her undersigned counsel, and files this Answer and in support thereof responds as follows: 1. Admitted. 2. Admitted. 3. Admitted. 4. Admitted. The terms and contents of Exhibit "A" speak for themselves. 5. Denied. It is denied that plaintiff kept accurately running records of all debits and credits regarding defendant's account and strict proof is demanded. Defendant specifically denies and disputes owing $3917.10 to plaintiff and strict proof, explanation and evidence of the calculation of this sum is demanded. 6. Denied. Defendant has never made and outright refusal to pay. 7. Neither admitted or denied. After reasonable investigation, defendant is unable to form an opinion as to the truth of the averments contained in Paragraph 6 of plaintiff's complaint. WHEREFORE, defendant demands judgment against plaintiff pnd that plaintiff's complaint be dismissed with prejudice. Date: 3- 3 - O l5 ID. # 93211 J. Chad Moore, Esquire I.D. # 76660 Attorney for Defendant 270 Market Street Millersburg, PA 17061 717-692-5533 VERIFICATION LEAH M. STUMP, ESQUIRE, hereby states that she is the attorney for the Defendant in this action and verifies that the statements made in the foregoing pleading are true and correct to the best of her 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 unworn falsification to authorities. Attorney for Defendant FIA CARD SERVICES f/k/a BANKOF AMERICA Plaintiff vs. CRAIG S. JUMPER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-478 Civil Action - Law CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing Answer has been served by first class mail, postage pre-paid upon the following : Frederic I. Weinberg, Esquire Gordon & Weinberg, PC 21 South 21 s' Street Philadelphia, PA 19103 (215) 988-9600 3. ?. of Date 1.L. tt/VVVV Leah M. Stump, Esquire I.D. #93211 Attorney for Defendant 270 Market Street Millersburg, PA 17061 (717) 692-5533 ! ? !"° ' ~ ? ? '? ..r 5"` ?' ??? ? ?? t?? k 4 ?... +l ?." ? ~?-?? ' ' ?:i t.? ?. .. ..r' -? 2040523 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 FIA CARD SERVICE, N.A. f/k/a COURT OF COMMON PLEAS BANK OF AMERICA, N.A. CUMBERLAND COUNTY Vs. CRAIG S JUMPER DOCKET NO. : 08-478 SUGGESTION OF BANKRUPTCY OF DEFENDANT TO THE PROTHONOTARY: AND NOW, this 06Nov09, it is suggested of record that Defendant, CRAIG S JUMPER, filed a petition in bankruptcy under Chapter 7 of the Bankruptcy Code on or about October 19, 2009, in the United States Bankruptcy Court for the Middle District of Pennsylvania, docket number 09-08152. Therefore, this matter should be stayed until further notice. GORDON & WEINBERG, P.C. BY: FREDERIC I. IN ERG, ESQUIRE JOEL M. FLINK, ESQUIRE Attorney for Plaintiff i °t r !", {