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Home My WebLink About08-1925IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA American Express Centurion Bank World Financial Center CIVIL ACTION 200 Vassey St. : New York, NY 10285 Plaintiff VS. No: bs - 19x5 elvi ( Term CYNTHIA BEMIS AND JONATHAN BEMIS 317 7TH ST NEW CUMBERLAN PA 17070 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 16. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA American Express Centurion Bank World Financial Center CIVIL ACTION 200 Vassey St. New York, NY 10285 Plaintiff vs. NO: CYNTHIA BEMIS AND JONATHAN BEMIS 317 7TH ST NEW CUMBERLAN PA 17070 Defendant COMPLAINT Plaintiff, American Express Centurion Bank, by and through its attorneys, Edwin A. Abrahamsen & Associates, P.C., complains of the Defendant as follows: 1. Plaintiff, American Express Centurion Bank, (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 CYNTHIA BEMIS JONATHAN BEMIS (hereinafter "Defendant") is an adult individual residing at 317 7TH ST NEW CUMBERLAN PA 17070. 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 371741663511004. M 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, 371741663511004, 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 August 31, 2007. 10. The principal amount was $$14,115.90 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 $14,115.90 at the time it was received by Plaintiff. 13. The total amount due and owing the Plaintiff including interest, is $14,115.90. 14. Pursuant to the terms of the Agreement, Defendant is liable to Plaintiff for court costs and reasonable attorney's fees. WHEREFORE, Plaintiff requests judgment in its favor and against Defendant in the amount of $14,115.90 plus costs of suit, reasonable attorneys' fees of $1,411.59 and any other relief as the Court deems just and appropriate. Respectfully submitted, Edwin A. Abr msen & Assoc. Michael F. atchford, Esquire Scott J. t, Esquire Attorney I.D. Nos.: 86285/93600 1729 Pittston Avenue Scranton, PA 18505 mratchford@eaa-law.com sbest@eaa-law.com VERIFICATION I, Michael F. Ratchford, attorney for Plaintiff,American Express Centurion Bank, 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. -E??. C=? c `' ? Tt? n ? ,. oo - D c l; =< 0 . 1 CASE NO: 2008-01925 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND AMERICAN EXPRESS CENTURION BAN VS BEMIS CYNTHIA ET AL DAWN KELL , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE BEMIS CYNTHIA DEFENDANT at 317 7TH ST was served upon the , at 1548:00 HOURS, on the 21st day of April , 2008 NEW CUMBERLAND, PA 17070 CYNTHIA BEMIS by handing to 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 18.00 Service 34.00 Affidavit .00 Surcharge 10.00 .00 4/12 rlar L 62.00- Sworn and Subscibed to before me this day So Answers: R. Thomas Kline 04/23/2008 EDWIN ABRAHAMSEN By: )a-L? Deputy Sheriff of A. D. APR-22-2008 06:58A FROM:JAMES M BACH ATTORNE 7177374220 TO:2406397 JJM No BACH AWORHE AT LAW 352 S. SPORTING HILL ROAD MECHANICSBURG, PA 17050 (717) 737.2033 FAX (717) 737.4220 FAX COVER SHEET 7° Zz - vce Date: ro -dam, Fax: 2' f/G - G 3 9 Number of Pages including this cover sheet: v IF YOU DO NOT REVIEVE ALL PAGES OF THIS FAX PLEASE CALL BUYIEDIATELY. (717) 737-2033 RE: , ?s c4vt.,6 ?e /- 10 1? 1?01 .p/dZZ-- P.1 The information contained in this fax is confidential (and may be attorney privileged), intended only for the use of individual or entity named above. If the reader of this message is not the intended recipient, you are hereby notified that any dissemination or distribution of this communication to anyone other than the intended recipient is strictly prohibited If you have received this communication in error, please notify us by telephone immediately and return the original message to us at the above address via the U.S. Mail. Thank you. . USBC PAM - LIVE - VERSION 3.1.71, Page 1 of 1 Open 'a Voluntary Bankruptcy Case U.S. Bankruptcy Court Middle District of Pennsylvania Notice of Bankruptcy Case Filing The following transaction was received from Bach, James M entered on 3/26/2008 at 8:59 AM EDT and filed on 3/26/2008 Case Name: Cynthia S. Bemis Case Number: 1:08-bk-01022 Document Number: 1 Docket Text: Chapter 7 Voluntary Petition. Filing fee due in the amount of $ 299.00 Filed by James M Bach on behalf of Cynthia S. Bemis. (Bach, James) The following document(s) are associated with this transaction: Document description: Main Document Original tilename:c:\ect\bemis, cynthia s\petition.pdf Electronic document Stamp: [STAMP bkecfStamp ID=1009835235 [Date=3/26/2008] [FileNumber4923229-0 ][5343199b46allbbd2f]8911bf19c2b6clcdlaObcb563ba4d363ed0708fea44ee4e6 94a3ld7bdl56d6e4742e363fldl1854leddl34142db7739fa7ae618bb6c3c]] 1:08-bk-01022 Notice will be electronically mailed to: James M Bach JMB@JamesMBach.com United States Trustee ustpregion03.ha.ecf@usdoj.gov 1:08-bk-01022 Notice will not be electronically mailed to: file://C:\ECF\Bemis, Cynthia S\Filed (Complete) \Ecf Receipt Case 2008-03-26@0859am.... 3/26/2008 2'd 16290b2:O1 02aL£LLSL 3NPIOlld HOUG W S341Jt:WMU UBS:90 e002-22-?]d