HomeMy WebLinkAbout08-6491IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
American Express Travel Related
Services CIVIL ACTION
1804 Washington Blvd.
Baltimore, MD 21230
Plaintiff
VS. NO: 0$ - ?yq ( 0, l er?A
JEFFREY COX
853 KIEHL DRIVE
LEMOYNE PA 17043
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
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
American Express
1804 Washington Blvd.
Baltimore, MD 21230
VS.
JEFFREY COX
853 KIEHL DRIVE
LEMOYNE PA 17043
Plaintiff
CIVIL ACTION
NO: D P - 4 Y9/
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
Maryland corporation with a principal place of business located at 1804 Washington Blvd.
Baltimore, MD 21230
2. The Defendant JEFFREY COX (hereinafter "Defendant") is an adult individual
residing at 853 KIEHL DRIVE LEMOYNE PA 17043.
3. At all relevant times herein, Plaintiff was engaged in the business of debt purchase
and collection.
4. Defendant applied for and received a credit card issued by AMERICAN EXPRESS
with the account number 371388274813005.
5. The within account was sold by AMERICAN EXPRESS to NCO FINANCIAL
SYSTEMS, INC for valuable consideration and all rights under said accounts were assigned to
NCO FINANCIAL SYSTEMS, INC.
6. Use of the AMERICAN EXPRESS credit card was subject to the terms of the
Cardmember Agreement, a copy of which was sent to the Defendant along with the credit card.
7. Defendant used the AMERICAN EXPRESS credit card account
number371388274813005, for purchases, cash advances and/or balance transfers.
8. The Defendant was mailed account statements relative to the Defendant's use of the
subject credit card.
9. The Defendant defaulted under the terms of the Agreement by failing and refusing
to make monthly payments on the account as they became due. (See, Cardmember Agreement
attached hereto as Exhibit "A.")
10. The account became delinquent February 22, 2007.
11. The principal amount was $16,665.93 at the time it was received by Plaintiff.
12. Pursuant to the account agreement, any unpaid balance accrues interest at the rate
of 6.
13. The total amount due and owing the Plaintiff including interest, is $17,011.12.
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 $17,011.12 plus costs of suit, reasonable attorneys' fees and any other relief as the
Court deems just and appropriate.
submitted,
'Edwin A. Abraham Assoc.
Michael F. Ratch Esquire
Heather K. Wo ff, Esquire
Attorney I.D. os.: 86285/207805
1729 Pittston Avenue
Scranton, PA 18505
mratchford@eaa-law.com
hwoodruff@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.
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CIP
SHERIFF'S RETURN - REGULAR
CASE NO: 2008-06491 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
AMERICAN EXPRESS TRAVEL RELATE
VS
COX JEFFREY
NOAH CLINE
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
COX JEFFREY
DEFENDANT
the
, at 0013:50 HOURS, on the 5th day of November-, 2008
at 853 KEIHL DRIVE
LEMOYNE, PA 17043
JEFFREY COX
by handing to
DEFENDANT
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 16.00
Affidavit .00
Surcharge 10.00
.00
? 44. 0
Sworn and Subscibed to
before me this day
So Answers:
R. homas Kline
11/06/2008
EDWINI ABRAHAMSEN & ASSOCIATES
By: Deputy Sheriff
of A. D.
American Express
Travel Related Services In the Court of Common Pleas of
CUMBERLAND County, Pennsylvania
Plaintiff Civil Division
VS.
NO: 08-6491-CIVIL TERM
JEFFREY COX Praecipe to Withdraw Civil Complaint
853 KIEHL DRIVE
LEMOYNE PA 17043
Defendant
To the Prothonotary of CUMBERLAND County Pennsylvania:
Please enter the above Praecipe to Withdraw the Civil Complaint.
Thank you,
Michael F. Ratchford,
Edwin A. Abrahamse}
Lawyer ID 4 86285
Sworn and
, P.C.
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