HomeMy WebLinkAbout08-1432Robert D. Kodak, Esquire
Supreme Court I.D. 18041
KODAK & IMBLUM, P.C.
Post Office Box 11848
407 North Front Street
Harrisburg, PA 17108-1848
717-238-7152 Fax: 717-238-7158
email: robert.kodak@verizon.net
Attorney for Plaintiff
GMAC COMMERCIAL CREDIT, LLC., IN THE COURT OF COMMON PLEAS
Factor/ Assignee for DRESSY TESSY, : CUMBERLAND COUNTY, PENNSYLVANIA
INC.
Plaintiff
vs. CIVIL DIVISION - LAW
WILLIAM B. GOETZ, JR., Individually NO. b8 - 1439 Civa lP,r'Irt
and Trading As NEW ENGLANDER
Defendant
NOTICE
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claim 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 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, 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
TWO LIBERTY AVENUE
CARLISLE PA 17013
(717) 249-3166
GMAC COMMERCIAL CREDIT, LLC., : IN THE COURT OF COMMON PLEAS
Factor/ Assignee for DRESSY TESSY, : CUMBERLAND COUNTY, PENNSYLVANIA
INC.
Plaintiff
vs. CIVIL DIVISION - LAW
WILLIAM B. GOETZ, JR., Individually NO. 0 - / y 3 '2 C' "'? ?' "'
and Trading As NEW ENGLANDER
Defendant
COMPLAINT
The Plaintiff, GMAC Commercial Credit, L.L.C., Factor/Assignee for Dressy Tessy, Inc.,
by its attorneys, KODAK & IMBLUM, P.C., brings this action of Assumpsit against the Defendant
to recover the sum of Four Thousand, Five Hundred Thirty-Five Dollars and Five Cents ($4,535.05),
along with interest thereon from April 5, 2007, upon a cause of action of which the following is a
statement:
1. The Plaintiff, GMAC Commercial Credit, L.L.C., is a foreign limited liability
corporation registered to do business in the Commonwealth of Pennsylvania, and is the factoring
agent and assignee for Dressy Tessy, Inc.
2. The Defendant, William B. Goetz, Jr., an adult individual, is trading and doing
business as New Englander and has an office and place of business at 326 South 10th Street,
Lemoyne, Cumberland County, Pennsylvania 17043.
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FEB-13-2008 16:01 KNUPP KODAK & IMBLUM
VERIFICATION
717 238 7158 P.05
i tie #U A v'l
(name) (title)
of GMAC COMMERCIAL CREDIT, L.L.C., verify that the statements made in the aforegoing
document are true and correct. I understand that false statements herein are made subject to the
penalties of 18 Pa. C. S. §4904, relating to unsworn falsification to authorities.
Dated: I
GMAC COMMERCIAL CREDIT, L4.C.
By:
Title: 34077
b j : comp:34077.wpd 29Nov06
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CASE NO: 2008-01432 P
SHERIFF'S RETURN - REGULAR
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
GMAC COMMERCIAL CREDIT LLC
VS
GOETZ WILLIAM B JR ET AL
TIMOTHY REITZ , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
r-,nT F7 TATTT.T.TZ\M R TP the
DEFENDANT , at 1514:00 HOURS, on the 7th day of March , 2008
at 326 SOUTH 10TH STREET
LEMOYNE, PA 17043 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:
Docketing 18.00
Service 15.36
Postage .58
Surcharge 10.00
00
4 3. 9 4
Sworn and Subscibed to
before me this day
of
So Answers:
R. Thomas Kline
03/10/2008
KODAK & IMBLUM
Y:
De u y She
r/ff
A.D.
SHERIFF'S RETURN - REGULAR
. -.
CASE NO: 2008-01432 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
GMAC COMMERCIAL CREDIT LLC
VS
GOETZ WILLIAM B JR ET AL
TIMOTHY REITZ , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
GOETZ WILLIAM B JR T/A NEW ENGLANDER the
DEFENDANT , at 1514:00 HOURS, on the 7th day of March , 2008
at 326 SOUTH 10TH STREET
LEMOYNE, PA 17043
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:
Docketing 6.00
Service .00
Affidavit .00
Surcharge 10.00
.00
3JIgl ' C?- ? 16.00
Sworn and Subscibed to
before me this day
of
So Answers:
R. Thomas Kline
03/10/2008
KODAK & IMBLUM
By. ,
Depu y Sheriff
A.D.
GMAC COMMERCIAL CREDIT, LLC,
Factor/ Assignee for Dressy Tessy, Inc.
Plaintiff
v
WILLIAM B. GOETZ, JR. individually
and trading as NEW ENGLANDER
Defendants
IN THE COURT OF COMMON PLEAS
Cumberland COUNTY,
PENNSYLVANIA
NO. 08-1432 CIVIL TERM
CIVIL ACTION - LAW
PRAECIPE
TO THE PROTHONOTARY:
Please mark the above-captioned case as settled and discontinued with prejudice.
TO: Cumberland County
Prothonotary
Dated: August 18, 2008
Robert D. Kodak, Esquire Attorne for Plaintiff
Attorney I.D. No. 18041
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