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Home My WebLink About08-71722050607 THIS S AN ARBITRATION MATTER. DAMA S HEARING REQUIRED. GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBER , ESQUIRE Identification No.: 14L41360 JOEL M. FLINK, ESQU KE Identification No.: 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 GE MONEY BANK RECEIVABLES 4125 Windward Alpharetta,GA D/B/A QVC Plaza Driv 30005 VS. Donna Mortensen 628 Woodland Ave Mount Holly Spr PA 17065 ASSESSMENT OF COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 68 - 717 L'Ziewj NOTICE YOU HAVE BEEN SUED IN CO T. IF YOU WISH TO DEFEND AGAINST THE CLAIMS SET FORTH IN THE FOLLOWING PAGES, U MUST TAKE ACTION WITHIN TWENTY (20) DAYS AFTER THIS COMPLAINT AND NOTICE ARE RVED, BY ENTERING A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILING IN KITING 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 pU AND A JUDGEMENT MAY BE ENTERED AGAINST YOU BY THE COURT WITHOUT FURTHER NOT CE FOR ANY MONEY CLAIMED IN THE COMPLAINT OR FOR ANY OTHER CLAIM OR RELIEF RE BESTED BY THE PLAINTIFF. YOU MAY LOSE MONEY OR PROPERTY OR OTHER RIGHTS IMPO TANT 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. CUMBERI COUNTY BAR ASSOCIATION 32 S. BEDFORD STREET CA, LISLE, 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 defend nt(s) by the plaintiff under the terms of which the plaintiff agreed to extend to defendant(s)the use of I' plaintiff's credit facilities. 2. Defendant(s) a cepted and used the aforesaid credit card so issued and by so oing agreed to perform the terms and conditions prescribed bylthe plaintiff for the use of said credit card. 3. The defendant (sP 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'I to which the defendant (s) is entitled have been applied and there 2008 in the amount of $2 5. Plaintiff has payment of the balance a balance due as of November 20, 618.82. made demand upon the defendant(s)for due but the defendant(s)has failed and refused and still refuseolto pay the same or any part thereof. 6. Defendant's lat payment on account was made on 3/1/05. WHEREFORE, plaintiff claims of the defendant(s) the sum of $2,018.82 plus applicable costs, interest and attorneys fees. GORDON & WEINBERG, P.C. BY: FREDERIC I. W NBE G, ESQUIRE JOEL M. FLINK, UIRE Attorney for Plaintiff P01A VERIFICATION i FREDERIC I. WEINBER? q, 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 falsificationlto authorities. FREDERIC I. WE RG, ESQUIRE BIT "A" 2244 2050607 Go FINANCE-POST Donna Mortensen 6045763006054628 I , /-0G. /-r6 sworn according to law, AFFIDAVIT SEA i and say that: , being duly served 1. I am the agent for the Plaintiff herein and I have custody and control of the files re tinq to this account; 2. I have personal knowledge of the facts and circumstances in connection with this case; 3. Plaintiff's files *e maintained in the usual and ordinary course of business; 4. This action is ba ed on a claim for breach of contract and that damages are sought as a direct result of said breach; i 5. After allowing fo? all offsets and credits, a balance remains on the subject acco t having account number 6045763006054628in the amoun of $2,018.82; and 6. If called upon, affiant can testify at trial as to the facts pertaining to this matter. The above facts are information and belief. Sworn to and Subscribed before me this day tj? 2008 Notary Public and correct to the best of my knowledge, (N of Affiant) ? `? SANK/?c ??`y •0.yGpMM/SS?O•. ? `NOT,?L Z Z CO D 40 • • '•?F ?o .: ?Q . NTY GS9 'k I, Document Name: Helene Thomason MORTENSEN, DONNA ACCT# 6045763006054628 628 WOODLAND AVE REF DATE 10/10/07 MOUNT HOLLY SPR, PA 17065 NCI-ID 07284222184 REF AMT 2,018.82 GE FINANCE BAL DUE 2,018.82 S T A T E M j N T O F A C C O U N T TRANSACTION DATE AMOUNT BALANCE ------------------------ -- ----- -------------- -------------- LAST ACTIVITY ******** Date: 10/16/2008 Time: 9:44:49 AM m ? d C7 C _TJt L77 Yt e na c.?r co c.n N r? I V.) COURT OF COMMON PLEAS CUMBERLAND COUNTY GE MONEY BANK d/b/a QVC RECEIVABLES, Plaintiff, vs. DONNA MORTENSEN, Defendant. No. 08-7172 ANSWER TO COMPLAINT COMES NOW Defendant Donna Mortensen and for her Answer to Civil Action Complaint filed herein states: 1. Denies the allegations of paragraph 1 for lack of information and belief. 2. Denies the allegations of paragraph 2 for lack of information and belief. 3. Denies the allegations of paragraph 3 for lack of information and belief. 4. Denies the allegations of paragraph 4 for lack of information and belief. 5. Denies the allegations of paragraph 5 for lack of information and belief. 6. Denies the allegations of paragraph 6 for lack of information and belief. WHEREFORE, Defendant prays that the Complaint be dismissed and all costs of this action be assessed to Plaintiff as permitted by law. Copy to: Frederic 1. Weinberg Joel M. Flink 1001 East Hector Street, Suit e220 Conshohocken, PA 19428 Donna Mortensen, efendant 628 Woodland Avenue Mt. Holly Springs, PA 17065 CERTIFICATE OF SERVICE The undersigned certifies that the foregoing instrument was served upon all parties to the above cause or to each of the attorneys of record h in at their res ective addresses disclosed on the pleadings on 2008. By: In U. S. Mail O FAX O Hand Delivered O Overnight Courier O Certified O Other: -r Signature: ' ?i ;, ?` ' t ??' i ?.} 1..i..: _ ?s' SHERIFF'S RETURN - REGULAR CASE NO: 2008-07172 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND GE MONEY BANK ET AL VS MORTENSEN DONNA JASON VIORAL , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE MORTENSEN DONNA was served upon the DEFENDANT , at 0017:47 HOURS, on the 18th day of December-, 2008 at 628 WOODLAND AVE MOUNT HOLLY SPRINGS, PA 17065 SARA HITE by handing to ADULT DAUGHTER OF DEFENDANT 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 /. Pg10Y 18.00 5.40 .00 10.00 .00 ? 33.40 Sworn and Subscibed to before me this day of , So Answers: R . 'Thomas K i ne 12/19/2008 GORDON & WEINBERG By: D u y Sheriff A. D. 2050607' ' ' 1, 0 N 0 ,' :;' 2011 JAN 10 PM Li: C0 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 GE MONEY BANK D/B/A QVC RECEIVABLES VS. Donna Mortensen PENNS i'LVANIPI. COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 08-7172 ORDER TO SETTLE, DISCONTINUE AND END TO THE PROTHONOTARY: Kindly mark the above-captioned matter settled, discontinued and ended upon payment of your costs only. GORDON & WEINBERG, P.C. BY: FREDERIP I. OINBERG, ESQUIRE JOEL M. K, ESQUIRE Attorney for Plaintiff P003