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Home My WebLink About09-34542045916 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 ASSESSMENT OF GE MONEY BANK D/B/A WALMART 4125 Windward Plaza Drive Alpharetta,GA 30005 VS. Jill Kuhns 467 Oak Flat Rd Newville PA 17241 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. pq - 3y5? Ccvi l L ex'm 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 as of March 31, 2009 in the amount of $3,617.06. 5. Plaintiff has made demand upon the defendant(s)for payment of the balance due 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 5/1/2007. WHEREFORE, plaintiff claims of the defendant(s) the sum of $3,617.06 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDERIC I INBERG, ESQUIRE JOEL M. FLINK, ESQUIRE Attorney for Plaintiff P01A 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. FREDERIC I. W RG, ESQUIRE EXHIBIT "A" 2244 Jill Kuhns 6032207101083236 2045916 G8 X106 T UM D/B/A WALL 1RT 1, L 01- I Te=l 04A, 5 6 -'1 , being duly served sworn according to law, depose and say that: 1. I an 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 circumstances in connection with this case; 3. Plaintiff's files are maintained in the usual and ordinary course of business; 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 6032207101083236in the amount of $3,617.06; and 6. If called upon, affiant can testify at trial as to the facts pertaining to this matter. The above facts are true and correct to the best of my knowledge, information and belief. A41 A 1. N Sworn to and Subscribed before me this OP day o 008 Notary Public `???Illiirrrtoo i \ ? (? r • i,?W7 .. U. r? ?0" F • Wag ..,,,r co 1?,,? fill Document Name: Helene Thomason KUHNS, JILL ACCT# 6032207101083236 467 OAK FLAT RD REF DATE 10/22/07 NEWVILLE, PA 17241 NCI-ID 07296166593 REF AMT 3,617.06 GE FINANCE BAL DUE 3,617.06 S T A T E M E N T O F A C C O U N T TRANSACTION DATE AMOUNT BALANCE ------------------------ -------- -------------- ----------- ******** LAST ACTIVITY ******** )ate: 10/16/2008 Time: in.n4•01 AM 0 P, r`Jti i t ,'.NARY '1099 I , F'6 f 0: i:,1 1 119 -so Pp ATTy 40,LS& a Sheriffs Office of Cumberland County R Thomas Kline ?>tr ofiuYrurrf?r Edward L Schorpp Sheriff rb Solicitor Ronny R Anderson Jody S Smith Chief Deputy OFFICE, E W Civil Process Sergeant GE Money Bank Case Number vs. Jill Kuhns 2009-3454 SHERIFF'S RETURN OF SERVICE 06/19/2009 05:40 PM - R. Thomas Kline, Sheriff who being duly sworn according to law states that he made a diligent search and inquiry for the within named defendant to wit: Jill Kuhns, 467 Oak Flat Road, Newville, Cumberland County, Pennsylvania, 17241 but was unable to locate her in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant, Jill Kuhns. Service was attempted eleven times with no one being available to accept SHERIFF COST: $49.20 June 22, 2009 ?? - -11 f?vt CJ - _ ? . i 2045916 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 WALMART VS. Jill Kuhns 467 Oak Flat Rd Newville PA 17241 F(Lt7n_0 Ff^F T { 0 _ THE PR k") I10!, C? TAF", Y ?. L 1 'f , `f 011,1 T_ 1 l 0 P ~ 7 PM1 2: 2 7 _-IMSERLA D MIN TY COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 09-3454 PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Kindly reinstate the Plaintiffs' Complaint in Civil Action in the above-captioned matter for an additional thirty (30) days. GORDON & WEINBERG, P.C. BY: FREDERIC I. ERG, ESQUIRE JOEL M. FLINK, ESQUIRE Attorney for Plaintiff(s) G) *1().00 Po A TIV e I za 5(00 +?* ag8815 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff , ~ ~. ~ ~3 - ~ ~' ~ ~ ~ ~- Jody S Smith ~. ~ Cl~ t ~.ee s''.'~;-- ~B, E t `~, Chief Deputy ~~ ~.~ ~t. ~~ ~ ~ ~~'~ _ ~ ~;~ t~• ~ ~ Richard W Stewart ~-~°~° `~- Solicitor ~~~~~~~-~G_~~~~i,r,= ~:~7~'1BE~L~,I'~i~~ COU~~~i GE Money Bank Case Number vs. 2009-3454 Jill Kuhns SHERIFF'S RETURN OF SERVICE 09/30/2010 07:40 PM -Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on September 30, 2010 at 1940 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Jill Kuhns, by making known unto herself personally, at 467 Oak Flat Road, Newville, Cumberland County, Pennsylvania 17241 its contents and at the same time handing to her personally the said true and correct copy of the same. NOAH CLINE, DEPUTY SHERIFF COST: $39.24 October 01, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF lci Cou;iiySuite She:~ff. TelxsoR, Inc. .r . 20;5916 GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 - ;r JOEL M. FLINK, ESQUIRE ' Identification No.: 81894 s ?- x-- 1001 E. Hector Street, Ste 220 . ?N. - ,rte Conshohocken, PA 19428 en '? 484/351-0500 GE MONEY BANK D/B/A WALMART COURT OF COMMON PLEAS CUMBERLAND COUNTY VS. Jill Kuhns DOCKET NO. : 09-3454 PRASCIPE FOR ENTRY OF JUDGMENT FOR NANT OF AN ANSMRR, ASSZSMM OF DAVANS 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 $3,617.06 Less: Payments on Account ( $2,020.00) Total: $1,597.06 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: GE MONEY BANK D/B/A WALMART and that the last known address of defendant, Jill Kuhns, 467 Oak Flat Rd, Newville PA 17241. 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 years of age. AND NOW, this _ !(tom day of Y 2010 Judgment is entered in favor of the plaintiff(s) and against defendant(s) by default for want of an answer and damages assessed at the sum of $1,597.06 as per the abo e certificat'on. '0% ftpvv"% P4, Pr thonotary GORDON & :,,EI BERG, P.C. BY: FREDERIC I. W NBERG, ESQUIRE JOEL M. ELI , ESQUIRE Attorney for Plaintiff 2045916 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 WALMART COURT OF COMMON PLEAS CUMBERLAND COUNTY VS. DOCKET NO. : 09-3454 Jill Kuhns 467 Oak Flat Rd Newville PA 17241 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. 1X/ Judgaent by Default $1,597.06 t--L Money Judgment $ Wald() Judgment on Award of Arbitrators$ f1 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 , Y I $ 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 2045916 GE MONEY BANK D/B/A WALMART COURT OF COMMON PLEAS CUMBERLAND COUNTY Vs. DOCKET NO. : 09-3454 Jill Kuhns TO/PARA NOTICE OF INTENTION TO TAKE DEFAULT Jill Kuhns 467 Oak Flat Rd Nevwille PA 17241 DATE OF NOTICE/FECHA DEL AVISO: October 22, 2010 II-IPORTANT 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: A/---I- FREDERIC NBERG, ESQUIRE P10D-2 JOEL M. 70K, ESQUIRE (nl[?r?brr? po ?i 57