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Home My WebLink About08-0847V IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA American Express Travel Related Services CIVIL ACTION World Financial Center 200 Vassey St. New York, NY 10285 Plaintiff :NO: D$ - 84,7 Civil - FE M VS. STEVEN HETRICK 1256 KUHN RD BOILING SPRIN PA 17007 Defendant : NOTICE TO DEFEND 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 to Defend are served, by entering a written appearance personally or by an 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 judgment 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. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ON AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT REDUCED FEE OR NO FEE. MIDPENN LEGAL SERVICES 401 EAST LOUTHER STREET CARLISLE, PA 17013 717-243-9400 1 M IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA American Express Travel Related : Services CIVIL ACTION World Financial Center 200 Vassey St. : New York, NY 10285 Plaintiff VS. NO: 0Y- Y y 7 C,;;j STEVEN HETRICK : 1256 KUHN RD : BOILING SPRIN PA 17007 Defendant COMPLAINT Plaintiff, American Express Travel Related Services, by and through its attorneys, Edwin A. Abrahamsen & Associates, P.C., complains of the Defendant as follows: 1. Plaintiff, American Express Travel Related Services, (hereinafter "Plaintiff") is a Delaware corporation with a principal place of business located at World Financial Center, 200 Vassey St., New York, NY 10285. 2. The Defendant STEVEN HETRICK (hereinafter "Defendant") is an adult individual residing at 1256 KUHN RD BOILING SPRIN PA 17007. 3. At all relevant times herein, Plaintiff was engaged in the business of extending credit to potential clients. 4. Defendant applied for and received a credit card issued by Plaintiff with the account number 378346161426003. 5. Use of the American Express credit card was subject to the terms and conditions of the Cardmember Agreement (hereinafter "Agreement"), a copy of which was sent along to the Defendant with the credit card. A copy of this document has been requested from American Express, and will be provided upon receipt. 6. Defendant used the American Express credit card with account number, 378346161426003, for purchases, cash advances and/or balance transfers. Use of the card in this manner constituted acceptance of the terms and conditions and subjects the Defendant to the terms and conditions contained therein. 7. The Defendant was mailed monthly account statements relative to the Defendant's use of the subject credit card. 8. The Defendant defaulted under the terms of the Agreement by failing and refusing to make monthly payments on the account as they became due. 9. The account became delinquent on April 21, 2006. 10. The principal amount was $$31,158.16 at the time of charge-off. 11. Pursuant to the account agreement, any unpaid balance accrues interest at the contract rate of 0%. 12. The principal amount was $31,158.16 at the time it was received by Plaintiff. 13. The total amount due and owing the Plaintiff including interest, is $31,158.16. 14. Pursuant to the terms of the Agreement, Defendant is liable for Plaintiffs court costs and reasonable attorney's fees in the amount of 25% of the balance. WHEREFORE, Plaintiff requests judgment in its favor and against Defendant in the amount of $31,158.16 plus costs of suit, reasonable attorneys' fees of $7,789.54 and any other relief as the Court deems just and appropriate. y Edwin A. Abrahamse & Assoc. Michael F. Ratchf , Esquire Scott J. Best, E ire Attorney I.D os.: 86285/93600 1729 Pitt n Avenue Scranton, PA 18505 mratchford@eaa-law.com sbest@eaa-law.com VERIFICATION I, Michael F. Ratchford, attorney for Plaintiff,American Express Travel Related Services, am fully familiar with the facts set forth in the within Complaint and am authorized to make this Verification on behalf of Plaintiff. I Verify that the facts set forth in the within allegations are true and correct to the best of my knowledge, knowing that any false statements are punishable by law pursuant to 18 C.S.A. 4904. EDWIN A. ABRAHAMSEN MICHAEL F. RATCHFORD SCOTT J. BEST' *ALSO MEMBER OF NJ BAR February 4, 2008 Cumberland County Sheriffs 1 Court House Sq. Carlisle, PA 17013 THE LAW OFFICE OF EDWIN A. ABRAHAMSEN & ASSOCIATES, P.C. WWW.EAA-LAW.COM Re: American Express Travel Related Services vs. STEVEN HETRICK Our file Nos.: N07-4091 Dear Sheriff: In regard to the above-noted matter, enclosed please find the following: 1. A true and correct copy of the Complaint; 2. The completed form for service; 3. A check for service; 4. A self-addressed return envelope for the return of service. Please serve the named defendant in accordance with the County Rules of Civil Procedure. If you should have any questions or concerns, please do not hesitate to call me at (570) 558-5510. The defendants address is : STEVEN HETRICK 1256 KUHN RD BOILING SPRIN PA 17007 Thank you for your attention to this matter. Edwin ssociates, P.C. Michtchford, Esquire mratchford@eaa-law.co Enclosures mfr/MR 1 729 PITTSTON AVE. • SCRANTON, PA 1 8505 • (P) S70.55B.551 0 • (F) 570.556.551 1 g t 00 00 O v N r_ C r "' fi 1 ?? ?_. rv "Cf N ;,y n SHERIFF'S RETURN - REGULAR CASE NO: 2008-00847 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND AMERICAN EXPRESS TRAVEL RELATE VS HETRICK STEVEN DAVID MCKINNEY , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT L NOTICE was served upon HETRICK STEVEN the DEFENDANT , at 0915:00 HOURS, on the 8th day of February-, 2008 at 1256 KUHN ROAD BOILING SPRINGS, PA 17007 STEVEN HETRICK by handing to a true and attested copy of COMPLAINT L NOTICE _ together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge .211.131a r ?- So Answers: 18.00 7.68 ? Mu.= .00 10.00 R. Thomas Kline .00 vO' 35.68 02/11/2008 EDWIN ABRAHAMSEN Sworn and Subscibed to before me this of ,11 By : ? ? ?: day Deputy Sheriff , A.D. David D. Bueff Prothonotary xirkS. Sohonage, ESQ Solicitor J O v 1750 &me X Simpson 15G Deputy Prothonotary Irene E. 94orrow 2nd Deputy Prothonotary Office of the Prothonotary Cumberland County, (Pennsy(vania lLA - eyl CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 25TH DAY OF OCTOBER, 2011, AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE -THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R.C.P 230.2 BY THE COURT, DAVID D. BUELL PROTHONOTARY One Courthouse Square • Suite 100 9 Carfsfe, PA 17013 • (717) 240-6195 * f'ax (717) 240-6573