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Home My WebLink About08-6642NC030093 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 American Express Centurion Bank RISK INFORMATION & BANKIN NEW YORK, NY 10285--441 Vs. KIMBERLY JOHNSON 1933 FRY LOOP AVE CARLISLE PA 17013 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 08 - (0(049, 0'wa-Fem 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, if available, 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 $7,601.73. 5. Plaintiff has made demand upon the defendant(s)for payment of the balance due of $7,601.73 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 9/20/06. WHEREFORE, plaintiff claims of the defendant(s) the sum of $7,601.73 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDERIC WEI ERG, ESQUIRE JOEL M. F (INK SQUIRE Attorney Plaintiff P01A NC030093 372345059671007 American Express Centurion Bank VERIFICATION I hereby state that I am the agent for the plaintiff herein, and that the facts set forth in the attached Affidavit which is incorporated by reference in the foregoing Complaint in Civil Action are true and correct to the best of my knowledge, 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 which provides for certain penalties for making false statements. N e .18811 E. Rarrmarren EXHIBIT "A" NC030093 372345059671007 American Express Centurion Bank Plaintiff, vs. KIMBERLY JOHNSON Doc ket #k AFFIDAVIT Defendant. Jean E.Ramserren being of full age, hereby certify as follows: 1. I am more than 18 years of age and am competent to make this affidavit. 2. I am employed by plaintiff, American Express Centurion Bank as a custodian of records for the records and facts at issue. 3. I am familiar with all of the facts and circumstances in connection with this case and have been authorized to make this certification in the above referenced case. 4. In the ordinary course of business and as a regular business practice, American Express Centurion Bank `s employees or representatives with knowledge of the accounts compile business records memorializing account activity and transactions at or near the time they occur. 5. Entries in the files and business records of Plaintiff are made contemporaneously with transactions in order to preserve the accuracy of the transaction. 6. Plaintiff's files and business records are maintained by American Express Centurion Bank 7. I have custody and control of the files and business records relating to this account. 8. There is now due and owing from defendant to plaintiff, the amount of $7,601.73 plus interest of $.00 at the rate of 0% less credits in the amount of $.00 totaling $7,601.73 as of July 8, 2008. 9. The documents attached to this affidavit, if any, are true and accurate copies of business records regarding the Defendant's account. 10. Upon information and belief, the Defendant is not now, nor has been within 30 days hereof, in the military service of the United States as defined in the Service members Civil Relief Act as amended nor an infant, incompetent, under mental defect or infirm. 11. Defendant is entitled to no known valid defenses, setoffs or counterclaims, and further states that written demand was made upon the Defendant. I affirm under the penalty of y that t a ue and correct. (OF AFFIANT) Sworn to and Subscribed before me this S-11., day of 200 Notary blic IVVtiA? - ?SO" Notary pwic Stets of Fronds Madelyn Gon=W My Cortmipion D0793614 a w ExPM 08/01/2012 1:3 , ! Fik tdt Traissa Farts Olt+a15 K-u YV- Wt?Y,w Hsp 4 !+? w ..:.. Or IF rr 4f ¢S ra k? r aru are PA; ENT CLR ?• ' ""' "" 1Sess•t 148.173. YS1.7R VF..+IMN i,l ... !. Q%Fp`Yn:.Yn la Ye... ?? :. ? :.,2?A?rt?naf ?6r C>?.:..j, n'?nd.i•NT. .?? .... .? , r T f -T) fTj `r Xl - SHERIFF'S RETURN - REGULAR CASE NO: 2008-06642 P COMMONWEALTH OF PENNSYLVANIA:, COUNTY OF CUMBERLAND AMERICAN EXPRESS CENTURION BAN VS JOHNSON KIMBERLY KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvani,a, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon TnUMCnV VTM11L'RT.V the DEFENDANT , at 2005:00 HOURS, on the 13th day of November , 2008 at 1933 FRY LOOP AVENUE CARLISLE, PA 17013 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 Service Affidavit Surcharge 11u1/o 1 C„ So Answers: 18.00' ,•" ?i? ?,.° 5.00 r ..=.?* 00 10.00 R. Thomas Kline .00 33.00 11/14/2008 GORDON & WEINBERG Sworn and Subscibed to By before me this day I of A.D. 'v GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 81894 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 American Express Centurion Bank VS. KIMBERLY JOHNSON NC030093 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 08-6642 PRAECIPE FOR ENTRY OF JUDGMENT FOR WANT OF AN ANSWER ASSESSMENT OF DAMAGES, VERIFICATION OF ADDRESS AND NON-MILITARY SERVICE TO THE PROTHONOTARY: Enter judgment for want of an answer for plaintiff and against defendant(s) above named only and assess damages certified to be calculable as a sum certain from the complaint, as follows: Principal Total: $7,601.73 $7,601.73 Understanding the false statements made herein are subject to penalty under 18 Pa.C.S.A. §4904, Unsworn Falsification to Authorities, I verify that: 1. The last known addresses of the parties are: American ExpressCenturion Bank and that the last known address of defendant, KIMBERLY JOHNSON, 1933 FRY LOOP AVE, CARLISLE PA 17013. 2. The annexed notice(s) of intention to file this praecipe was (were) mailed to all parties, defendant and to their record attorneys, if any, after default occurred, and at least ten days prior to the date of filing of this praecipe. 3. The said defendant(s) is (are) not in the military service of the United States or otherwise within the coverage of the Soldiers and Sailors Civil Relief Act and is (are) over 18 •1? , the Soldiers and Sailors years of age. AND NOW, this is entered in favor of the default for want of an ans, $7,601.73 as per the above Civil Relief Act and is (are) over 18 _ day of %6paPV , 2009 Judgment plaintiff(s) and aga nst defendant(s) by aer and damages assessed at the sum of , ce?tification.n Prothonotary GORDON & WEINBE , P.C. BY: FREDER C I. WEINBERG, ESQUIRE JOEL M. LINK, ESQUIRE Attorney for Plaintiff ? ~Y ?.t ? a NC030093 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 American Express Centurion Bank Vs. KIMBERLY JOHNSON TO/PARA COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 08-6642 NOTICE OF INTENTION TO TAKE DEFAULT KIMBERLY JOHNSON 1933 FRY LOOP AVE CARLISLE PA 17013 DATE OF NOTICE/FECHA DEL AVISO: December 5, 2008 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY AN ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 GORDON & WEINBERG, P.C. BY: FRED C/I/. WEINBERG, ESQUIRE JOEL FLINK, ESQUIRE P10D-2 ? Q • LN Mn NC030093 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 American Express Centurion Bank VS. KIMBERLY JOHNSON COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. 08-6642 NOTICE Pursuant to Pa.R.Civ.P. 236 of the Supreme Court of Pennsylvania, you are hereby notified that a judgment has been entered against you in the above proceeding as indicated below. /X/ Judgment by Default $7,601.73 Money Judgment $ Judgment on Award of Arbitrators$ Judgment on Verdict$ IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL ATTORNEYS: FREDERIC I. WEINBERG OR JOEL M. FLINK, ESQUIRES AT THIS TELEPHONE NUMBER: 484/351-0500 d&c4 PR HONOTA NC030093 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 American Express Centurion Bank COURT OF COMMON PLEAS CUMBERLAND COUNTY VS. KIMBERLY JOHNSON DOCKET NO. : 08-6642 ORDER TO SATISFY JUD(NMNT TO THE PROTHONOTARY: r+ t ? z W ;"?r=? - -46 ? ? = > c_ rn Kindly mark the judgment entered January 9, 2009 in the above-captioned matter satisfied upon payment of your costs only. GORDON & WEINBERG, P.C. BY: FREDERIC I. FAIN RG, ESQUIRE JOEL M. FL K, QUIRE Attorney f 1 aintiff P005 MARC R. GORDON FREDERIC 1. WEINBERG' JOEL M. FLINK' CHRISTOPHER S. FROBA' 'Also member NJ Bar 1001 E. HECTOR STREET GW SUITE 220 n t t o r n e y s a t l a w CONSHOHOCKEN, PA 19428 February 2, 2011 KIMBERLY JOHNSON AKA KIMBERLY HINTON 1933 FRY LOOP AVE CARLISLE PA 17013 RE: Creditor American Express Centurion Bank Current Balance Due: 0.00 - My File No: NC030093 Dear Mr. JOHNSON: 1200 LAUREL OAK ROAD SUITE 104 VOORHEES, NJ 08043 PHONE: (484) 351-0500 FACSIMILE: (484) 351-0501 TOLL FREE: (866) 465-8087 (Reply to PA office) Please be advised that we are in receipt of your final payment which serves as satisfaction of the debt owed. This debt is now paid in full and I am closing my file. I am enclosing an original Order to Satisfy Judgment which I have executed and which you must file with the Court in order to mark this matter settled on the court docket. There may be a fee to file the enclosed Order. You may take this document or mail it to the address listed below for filing. Please contact the court below to determine the amount of any fee. Prothonotary of Cumberland County One Courthouse Square Carlisle, PA 17013 717/240-6195 FAILURE TO FILE THIS ORDER TO SATISFY JUDGMENT WILL CAUSE THE JUDGMENT TO APPEAR OPEN AND UNSATISFIED TO ANYONE INQUIRING INTO YOUR CREDIT. Thank you. Very truly yours, GORDON & WEINBERG, P.C. /s/ Frederic I. Weinberg FREDERIC I. WEINBERG, ESQUIRE FIW:dmm Enclosures THIS LETTER AND ANY FUTURE LETTERS FROM OUR FIRM ARE AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. www.gordonweinberg.com