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Home My WebLink About08-33312048205 THIS IS AN ARBITRATION MATTER. ASSESSMENT OF 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 FIA Card Services, N.A. f/k/a Bank of America 275 S. VALENCIA AVE. BREA, CA. 92823 VS. SHARON L HOOVER, a/k/a SHARON BEASTON 323 MANCHESTER RD CAMP HILL PA 17011-6123 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : O$ - 333 C -tv; I le m 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. 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. 2. 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. 3. 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". 4. All the credits to which the defendant (s) is entitled have been applied and there remains a balance due in the amount of $8,050.95. 5. Plaintiff has made demand upon the defendant(s)for payment of the balance due of $8,050.95 but the defendant(s)has failed and refused and still refuses to pay the same or any part thereof. 6. Defendant's last payment on account was made on May 7, 2007. WHEREFORE, plaintiff claims of the defendant(s) the sum of $8,050.95 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDERIC I. EI ERG, ESQUIRE JOEL M. FLI K, E QUIRE Attorney for aintiff P01A 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. WE ERG, ESQUIRE EXHIBIT "A" FIA CARD SERVICES, N.A. SHARON L HOOVER 123 MANCHESTER RD CAMP HILL PA 17011.6123 ACCOUNT NUMBER 4888937996438992 BALANCE AS OF PAYMENT MINIMUM PAYMENT DUE DATE PAYMENT ENCLOSED February 15, PAST DUE $8,050.95 S 2008 Make Ckcka Payable to But Of America, N.A (USA) MESSMU MO( RAW OF AMERICA, N.A, (USA) YOUR ACCOUNT WITH FIA CARD SERVICES, N.A.IS PAST DUE $8,050.95, THE PAST DUE AMOUNT IS INCLUDED IN THE MINIMUM PAYMENT. THE PAST DUE AMOUNT THAT INCLUDES ORIGINAL PRINCIPAL BALANCE OF $7,125.90 AND INTEREST ON THAT BALANCE OF $925.05 HAS ACCRUED THROUGH October 2, 2007. PLEASE REMIT IMMEDIATELY. IF YOU HAVE ALREADY SENT A PAYMENT FOR THE ABOVE AMOUNT, THANK YOU. STATE OF Georgia ) COUNTY OF Cobb ) FIA CARD SERVICES, N.A. V. SHARON L HOOVER AFFIDAVIT OF ACCOUNT -ZAIZv5 COMES NOW, Rhonda Odom, and after being duly sworn before the below person authorized to administer oaths states the following: I am over 18 years old and sui buris. 2. 1 am agent forFIA CARD SERVICES, N.A.. 3. I am familiar with the books and records of the Plaintiff. 4. These books and records are kept in the ordinary course of business. 5. The agreement attached hereto is true and correct. 6. The Defendant (s) owe (s) the principal sum of $7,125.90. 7. The Defendant (s) owe (s) past due interest of $925.05 through October 2, 2007. 8. 1 know no liability insurance, bond or other security which may be available to pay this debt. 9, The Defendant (s) account number for which he owes the debt is 4888937996438992. 10. The Defendant (s) is/are not a minor nor an incompetent person. 1 l . Affiant has no knowledge of whether the Defendant (s) is/are on active duty in the military. 12, The Defendant (s) is/are past due on this account and in breach of the contractual agreement to pay as agreed. gent Rhonda Odom FIA CARD SERVICES, N.A. Sworn to and subscribed before me thi?& of , 2008. My Commission Expires: GORDON & WEINBERG, P.C. 07316447 OTARY PUBLIC ? J. ?? " ?pIRES GEAR 200 JUNE 14, ??/? CO4Mnrmnuna n ? C7 J -Ti /? 0 O ?F7 t C:/ SHERIFF'S RETURN - REGULAR CASE NO: 2008-03331 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FIA CARD SERVICES N A VS HOOVER SHARON L AKA SHARON BEA SHAWN HARRISON , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon HOOVER SHARON L AKA SHARON BEASTON the DEFENDANT , at 0933:00 HOURS, on the 31st day of May , 2008 at 323 MANCHESTER ROAD CAMP HILL, PA 17011-6123 by handing to SHARON HOOVER 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 6/0 qlep 0, Sworn and Subscibed to before me this of 18.00 16.00 .00 10.00 .00 44.00 day So Answers: R. Thomas Kline 06/02/2008 GORDON & WEIM'BAG By: A. D. Cie Sere - e N ?jAn b? AfVt F4 c R Vj RULE 1312-1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA O : 20 NO C cn r • ?D r? Dn zo The Petition for Appointment of Arbitrators shall be substantially in tl?; C_- Following form: PETITION FOR APPOINTMENT OF ARBITRATORS TO THE HONORABLE, THE JUDGES OF SAID COURT: r.? c? a CD r41 C-) N J 3 0 0 1; n k , counsel for the plaintiff/defendant in the above action (or actions), respectfully represents that: 1. The above-captioned action (liens) is (am) at issue. 2. The claim of plaintiff in the action is S ^? J The counterclaim of the defendant in the action is The following attorneys are interested in the case(s) as counsel or are otherwise disqualified to sit as arbitrators: WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. Re ctfully s miffed, ORDER OF COURT AND NOW, petition, Esq., and captioned action (or actions) as prayed for. 200 , in consideration of the foregoing Esq., and Esq., are appointed arbitrators in the above By the Court, Kevin A. Hess, PT 0 r"nF -Urn o° --1 O =-n O _n 2F3 CD ran D -c #gi4o Po A? at,? 52788 u`5 ; IN THE COURT OF COMMON PLEAS OF 'See-V A I ?Ll,t, ?A?^ K b? Yk p c R CUM13ERLAND COUNTY, PEN NSYLVANIA b ?. 3 3 20 v j NO. I n Y??6?? Ve- 116? Il Imo- ?It1 ??'1 G -o: o o o -n =..n . 7 i?? m? rr ?r- ° Y "< o -1O ?YC-) C") xO RULE 1312-1 The Petition for Appointment of Arbitrators shall be substantially in tl?; c-- C:? O D Following form: o ? PETITION FOR APPOINTMENT OF ARBITRATORS TO THE HONORABLE, THE JUDGES OF SAID COURT: 1 ?( yy? , r, 1; 6 k , counsel for the plaintiff/defendant in the above action (or actions), respectfully represents that: 1. The above-captioned action ( ) is (on) at issue. ^? J 5 2. The claim of plaintiff in the action is $ The counterclaim of the defendant in the action is The following attorneys are interested in the case(s) as counsel or are otherwise disqualified to sit as arbitrators: WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. Res tfu]ly s miffed, ORDER OF COURT AND NOW, /D , 200 , in consideration of the foregoing petition, Esq., and Esq., and • ?, ;?2 Esq., are appointed arbitrators in the above captioned action (or actions) as prayed for. By the Court, tf Uj , 'n L-) 7C - La.-C3 L _ ? 44 4,j S Ke A. Hess, PT ,. C-) C:) 00 P -4 Arry C=10- _ W _ C 140 q p 5-2788 y. .-U.. t p ? i 4rd scy,1e>°s rvA Plaintiff ,S4&?(,n L-, 4)ore, alk/Q 9AC(v-or\ asta? Defendant In The Court of Common Pleas of Cumberland County, Pennsylvania No. eQ5 - 3 33 1 Civil Action - Law. Oath We do solemnly swear (or affirm) that we will support, obey and defend the Constitution of the United States and the Constitution of this Commonwealth and that we will discharge the duties of our office with fidelity. Sign tore Signature i?o -r7??HA-% 6 - Name (Chairman) Name S kav l Ls i04-j Law Firm P(-)(22-9 Address ec\?i1sic PA rioi3 City, Zip c eWk4t LAW, LL- Q Law Firm to W- N IeiH sT Address ?;4Ru0,1-E * 17,43 City, Zip Signature wow A W(an Name doh Sori ?.?-? z Law Firm 3a M f?/la! kvI'. Address b6mp\ M 3 City, Zip Award We, the undersigned arbitrators, having been duly appointed and sworn (or affirmed), make the following award: (Note: If damages for delay are awarded, they shall be separately stated.) Z 2 3 3, 28 doman? 1, <6 1 3 7#- 3 2 1 h ko4p-) n osao. ,? h w (aid a . . Ar, ' rator, dissents. (Insert name if applicable.) Date of Hearing: 7- 2D ( 1 Date of Award: 3-7-2-0)1 (Chairman) Notice of Entry of Awar Now, the -7" day of M 6t rt 4_, 20 11 , at 9:33 A M. the above award was entered upon the docket and notice thereof given by mail to the parties or their attorneys. Arbitrators' compensation to be paid upon appeal: $ 3SZ) • 6*90 By: -- P ? Prothonotary Deputy -, ELI- COS • qE^ fr ry • ? Sail Ivt. ?l-????• ?=s1 SG?urch L • AooJer ANA ??oh 4'e5 ma.lt-d Ag,L 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 2048205 r --?c ? n C) D ;- fit" i YiA Card Services, N.A. f/k/a Bank of America VS. SHARON L HOOVER 323 MANCHESTER RD CAMP HILL PA 17011-6123 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 08-3331 CIVIL TERM NOTICE PURSUANT TO RULE 236 OF THE SUPREME COURT OF PENNSYLVANIA, YOU ARE HEREBY NOTIFIED THAT A JUDGMENT BY DEFAULT HAS BEEN ENTERED AGAINST YOU IN THE ABOVE PROCEEDING IN THE AMOUNT OF $9,107.60. IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL GORDON & WEINBERG, P.C. AT 484-351-0500 GORDON & WEINBERG, P.C. BY: FREDERIC I INBERG, ESQUIRE JOEL M. FLINK, ESQUIRE I Attorney for Plaintiff Dated: 4V tk 0g,a W4.00 - fd OLW Mj -?q7q& 5 -E4as79gj `4tNc-e Mo,`oa GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 PAUL M. SCHOFIELD, JR., ESQUIRE Identification No.: 81894 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 2048205 r'iA Card Services, N.A. f/k/a Bank of America VS. SHARON L HOOVER COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 08-3331 CIVIL TERM PRAECIPE TO ENTER JUDGICINT ON ARBITRATION ARMW TO THE PROTHONOTARY: Please enter judgment on the attached arbitration award in favor of the plaintiff, FIA Card Services, N.A. f/k/a Bank of America, against the defendant, SHARON L HOOVER in the amount of $9,107.60. NBERG, ESQUIRE FREDERIC VNKESQUIRE JOEL M. FL Attorney aintiff GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 PAUL M. SCHOFIELD, JR., ESQUIRE Identification No.: 81894 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 FIA Card Services, N.A. f/k/a Bank of America VS. SHARON L HOOVER COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 08-3331 CIVIL TERM VERIFICATION FREDERIC I. WEINBERG, ESQUIRE, hereby states that he is the attorney for the plaintiff in this action and verifies that the statements made in the foregoing pleadings 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. Section 4904 relating to unsworn falsification to authorities. FREDERIC I NBERG, ESQUIRE CERTIFICATION OF SERVICE I, FREDERIC I. WEINBERG, ESQUIRE, hereby certify that I, on the date below, served a copy of Plaintiff's Praecipe to Enter Judgment on Arbitration Award, via First Class Mail, postage pre- paid, to all other parties or their counsel of record. SHARON L HOOVER aka SHARON BEASTON 323 MANCHESTER RD CAMP HILL PA 17011-6123 FREDERIC I. Dated: 'a(t( , ESQUIRE P002-14 ? 1 ?) (41-wd Scrv, Cf_ s ) NA Plaintiff S?ar o,-N hJt'Q Sj-&j Defendant In The Court of Comma OX q ? )jj IS n Pleas of Cumberland County, Pennsylvania No. 1Q5 Civil Action - Law, We do solemnly swear (or affirm) that we wilOath States and the s port, obey and defend the Constitution Constitution of this Commonwealth and that we will discharge the duties of our?officeed with fidelity. Sign ure ?04)1,V?K' S I ?? _ Name (Chainnaii '~- Eaw Firm P O R,N (2.2-9 Address Ce'd I SIC city, Signature T:E' mc Fes-. Na_ w LAW LIL C Law 'F- 9 ID W. W ACT}} ;7- Address PA 1-7o I Zip City, Zip t Wit A $4 aw 1 Name Jo??on 'Dv;, k, Law Firtn Md/ Address LGroV At I743 city, Zip Award We, the undersigned arbitrators, having been duly oll? ing award: AOZnted and sworn (or affirmed), make the 5 -7 (Note- If damages for delay are awar ded, they shall be separately stated.) 46 13 734- L3 -2 1 1, - -1 - - h a (h a_4? • Rz tith'ator, dissents. (Insert name if aPPlieable Date of Hearing: .3 - 7- Z o Date of Award: '3 7-2-011 {Chairman) +J1 { Notice of Entry of Awar Now, the day of J j(Art4 20 entered upon the docket and, notice thereof given by mail to the Parties or atto?rne?cyS hove award was Arbitrators' compensation to be paid upon appeal: $ •3,5d .G3? TRUE COPY FROM RECORD in W a to *" of WN C0awI hem s at ? pw, hwW TOO.Z.&WO &&fgd 20 /1 Prothonotary By. -"--- ?` Deputy