HomeMy WebLinkAbout08-6498
2051899
THIS IS AN ARBITRATION MATTER.
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
IDT CARMEL INC AS ASSIGNEE OF
Citibank--The Home Depot
2080 ELM STREET SE
MINNEAPOLIS, MN 55414
vs.
MARK A FOREMAN
93 PLEASANTVIEW TER
NEW CUMBERLND PA 17070-2842
ASSESSMENT OF
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
DOCKET N0. Og - (p~{q$ C`V~~ ~~IK
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. Plaintiff is a debt buyer and successor in interest to
the original creditor as set forth in the caption of this
Complaint.
2. 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.
3. 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.
4. 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, if available, is attached hereto as
Exhibit "A".
5 . All the credits to which the defendant (s) is entitled have
been applied and there remains a balance due in the amount of
$2,706.34.
6. Plaintiff has made demand upon the defendant(s)for
payment of the balance due of $2,706.34 but the defendant(s)has
failed and refused and still refuses to pay the same or any part
thereof.
7. Defendant's last payment on account was made on 9/8/05.
WHEREFORE, plaintiff claims of the defendant(s) the sum of
$2,706.34 plus applicable costs, interest and attorney's fees.
GORDON & WEINBERG, P.C.
BY:
FREDERIC I. I ERG, ESQUIRE
JOEL M. FLINK, ESQUIRE
Attorney for Plaintiff
P01A.DB
2051899
IDT (',ARt~I+ INC AS ASSIGNEE OF
Citibank--The Home Depot
VERIFICATION
I hereby state that I am the agent for the plaintiff herein,
and that the facts set forth in the attached Affidavit Mhich is
incorporated by reference in the foregoing Com4plaint in Civil
Action are true and correct to the best of my knoMledge,
information and belief and is based upon information which
plaintiff has furnished to counsel. The language in the
Complaint is that of counsel and not of plaintiff. To the extent
that the contents of the Complaint are that of counsel, plaintiff
has relied upon counsel in making this verification. This
verification is made subject to 18 Pa.C.S. §4904 Khich provides
for certain penalties for making files st~tementa.
2062 2051899
IDT CAR1~L INC AS ASSIGNEE OF
Citibank--The Home Depot
MARR A FOREMAN
6035320105506131
I
sworn accor 'ng to law,
'~~
and say that:
being duly served
1. I am the agent for the Plaintiff herein and I have custody
and control of the files relating to this account;
2. I have personal knowledge of the facts and circumatancea in
connection with this case;
3. Plaintiff's files are maintained in the usual and ordinary
course of buaineas;
4. This action is based on a claim for breach of contract and
that damages are sought as a direct result of said breach;
5. After allowing for all offsets and credits, a balance
remains on the subject account having account number
6035320105506131in the amount of $1,905.76; and
6, If called upon, affiant can testify at trial as to the facts
pertaining to this matter.
The above facts are true and corre the t of my knowledge,
information and belief.
of
Sworn to and Subsc/r)ibed
before me this ~`~ ~Y
of . ~Lt- `- 2008
Note lic
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III
David 1D. Bueff
(Prothonotary
knee X Simpson
1s` Deputy Prothonotary
KirkS. Sohonage, ESQ
Solicitor
Irene E. 9Vorrow
2nd Deputy Prothonotary
Office of the (Prothonotary
Cum6erfand County, Pennsylvania
_08- (Mz/?I CIVILTERM
ORDER OF TERMINATION OF COURT CASES
AND NOW THIS 25TH DAY OF OCTOBER, 2011, AFTER MAILING NOTICE OF
INTENTION TO PROCEED AND RECEIVING NO RESPONSE -THE ABOVE
CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA
R.C.P 230.2
BY THE COURT,
DAVID D. BUELL
PROTHONOTARY
One Courthou., e ,Square 9 Suite 100 9 Carfsle, P.A 17013 ⢠(717 240-6195 9 F'ax (717 240-6573