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Home My WebLink About04-1687GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, Identification No.: 41360 21 SOUTH 21ST STREET PHILADELPHIA, PA 19103 215/988-9600 ESQUIRE THIS IS AN ARBITRATION MATTER. ASSESSMENT OF DAMAGES HEARING REQUIRED. American Express Travel Related Services, Inc. Suite 0001 Chicago, IL 60679 vs. Janet Giba 360 Peppercorn Square Enola PA 17025 COURT OF COMMON PLEAS CUMBERLAND COUNTY 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 APPEAg_ANCE 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 CA~N GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, Identification No.: 41360 21 SOUTH 21ST STREET PHILADELPHIA, PA 19103 215/988-9600 ESQUIRE THIS IS AN ARBITRATION MATTER. ASSESSMENT OF DAMAGES HEARING REQUIRED. American Express Travel Related Services, Inc. Suite 0001 Chicago, IL 60679 vs~ Janet Giba 360 Peppercorn Square Enola PA 17025 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO.: 0~- J ~ ~ ~ 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 plainEiff 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. Ail the credits to which the defendant(s)is entitled have been applied and there remains a balance due in the amount of $17,988.35. 5. Plaintiff has made demand upon the defendant(s)for payment of the balance due of $17,988.35 but the defendant(s)has failed and refused and still refuses to pay the same or any part thereof. WHEREFORE, plaintiff claims of the defendant(s) the sum of $17,988.35 at the rate of 23.46% from the date of December 30, 2002, together with costs and attorney fees. GORDON & WEINBERG, P.C. BY: FREDERI SQUIRE Attorney for la~l~ftiff 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. FREDERC~I.~~, ESQUIRE EXHIBIT "A " .lards DUPLICATE COPY Gold Card Statement of Account JANET E GIBA May 17, 2001 800-327-2177 Did y~u know t~u c~ (24 beurs / 7 d~ys) pay your bill o~ine? 3728-1~7~92002 Account Summary Due in Full 162.80 0.00 Rexible 22,639.91 0.00 * Indicates Ix~ing date. 52.00 214.80 440.64 23,080.55 Urgent - cancellation pending. Pay by 06/08/01 to avoid delinquency charge. Card Transactions for JANET E GIBA Activity for JANET E GIBA .~ New Charges Paymm~d~redits 214.80 1,798.00 0.00 0.00 Please refer to page for important inform; regarding your acco~ Card Transaction-, for DOUGLAS E LEMING AA~Nril 17, 2001' UAL MEM8ERSHIP FEE DOUGLAS E LEMING PERIOD 06/01 THRU 05/02 Activity for DOUGLAS E LEMING 35.00 New Charges 35.00 Payments/Credits 0. 00 Payment Coupon ~°"~ 3728- 149745-92002 JANET E G[BA 360 PEPPERCORN SQ ENOLA PA 17025-2601 I,,,lll,,,lll,,,,,I,l,l,l,,,I,l,ll,,ll,,,,,,ll,ll,,ll,,,ll,,,I Amount enclosed Mall Payment to: AUER[CAN EXPRESS P.O. S0X 1270 NEWARK NJ 07101-1270 IIl..h,,h,,lllh,,,,,Ih,,Ih,hlh,,llh.hh,hh,.Ihl number on all chec~ correspo~:~mce. To avoid add/fional Finance Charges an Purchases, pay New Balance before Pay~ Due Date. Note any address en tatephorm number cl' on reverse side. Unl ~u chank bern this ange will apply to any Corp~ate C_.,md Accounts you may h~ 0000372814974592002 000201280000005200 17dH JANET E GIBA Other Card Account Transactions May 17 ~2001' DEEINQ~ENCY CHARGE ON 87.80 Total of Card Activity DUPLICATE COPY ~"~ Page2of3 3728-149745-92002 17.00 New Charges 52.00 Peymeflts/Cmdlts 0.00 Flexible Payment Option statement of AC 6b_n.t Creditor: Amedcan ExpreSs CentUriOn Bank · Your Flexible Payment Account ~s seriously past due. ;..,=~; Account Minimum Summary $ Payment $ Paym~t Due ~. -,,,~ June 11,2001 Previous Balance 22.639.91 I 1,798.00J Payments/Credits 0.00 ,,. ...... This montfl's Minim[ FINANCE CHARGE 440,64 Paym~t in~udes: New Charges 0.00 Past Due New Balance 23,080.55 $1,336.00 This mo~th's ~rne. Finance Charge Balance(s) to Which ,~ Average Daily Annuid Daily Periodic P~eas~ refer toE Schedule Rate Applies ; Balance Percentage Rale Rate ALL ' , ~22.852.18 23.46% .0643% for important info~rn~ regarding your Sign Trave[ and/or Extent Payment O[o~ion. Amounts Total of Sign & Travel and/or Extended Payment Option Activity New Charges 0.00 Paymmtts/Credlte 0.00 Continued on next page ~ng y~ur ernall ad~es,q ~o Amedcan ExpressWill anal:le y, s~iedto your rmeds. S~±FF'S RETURN CASE NO: 2004-01687 P COMMONTWEALTH OF PENNSYLVANIA COIINTY OF CUMBERLAND - NOT FOUND AMERICAN EXPRESS TRAVEL RELATE VS GIBA JANET R. Thomas Kline duly sworn according to inquiry for the within named DEFENDANT GIBA JANET unable to locate Her in his bailiwick. ,Sheriff or Deputy Sheriff, who being law, says, that he made a diligent search and but was He therefore returns the COMPLAINT & NOTICE the within named DEFENDANT , GIBA JANET , NOT FOUND , as to 360 PEPPERCORN SQUARE ENOLA, PA 17025 DEFENDANT IS BELIEVED TO BE LIVING IN ALBANY, NEW YORK. Sheriff's Costs: Docketing 18.00 Service 10.35 Not Found 5.00 Surcharge 10.00 .00 43.35 Sheriff of Cumberland County GORDON & WEINBERG os/o /2oo4 Sworn and subscribed to before me this ~ ~day of ~~ GORDON & WEINBERG, P.C. By: FREDERIC I. WEINBERG, Identification No.: 41360 21 SOUTH 21ST STREET PHILADELPHIA, PA 19103 215/988-9600 ESQUIRE American Express Travel : Related Services, Inc. : Janet Giba : COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO.: 04-1687 PRAECIPE TO WITHDRAW CO*4PLAINT TO THE PROTHONOTARY: Kindly withdraw the above-captioned action, prejudice. without GORDON & WEINBERG, BY: F~D E R~I (~t~- WE I N B ERG, ESQUIRE A~rt-oT~ney for Plaintiff PO06