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2058749
THIS IS AN ARBITRATION MATTER.
DAMAGES HEARING REQUIRED.
GORDON & WEINBERG, P.C.
BY: FREDERIC I. WEINBERG, ESQUIRE
r 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 LOWE'S
VISA PLATINUM
4125 Windward Plaza Drive
Alpharetta,GA 30005
VS.
STEPHEN BOWMAN
42 CARLTON AVENUE
CARLISLE PA 17013
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
DOCKET NO. 0q- 3q55 0,I (arm
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
a
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 April 28, 2009
in the amount of $4,407.25.
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 6/11/2008.
WHEREFORE, plaintiff claims of the defendant(s) the sum of
$4,407.25 plus applicable costs, interest and attorney's fees.
GORDON & WEINBERG, P.C.
BY:
FREDERIC I. BERG, ESQUIRE
JOEL M. FLINK, ESQUIRE
Attorney for Plaintiff
VERIFICATION
0
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. WEI BE , ESQUIRE
EXHIBIT "A"
4
2244
STEPHEN BOWMAN
4305982481424268
2058749
09-03723-0
GE FINANCE-POST
AFFIDAVIT
I, Fran ie Dunn being duly served sworn according to
law, depose and say that:
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 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. There is now due and owing from defendant to plaintiff, the amount
of $4,407.25 plus interest of $.00 at the rate of 0% less credits in the
amount of $.00 totaling $4,407.25 as of March 25, 2009.
6. If called upon, affiant can testify at trial as to the facts
pertaining to this matter.
The above facts are true and orrect to the best of my knowledge,
information and belief.
r
AFFIANT Frankie Dunn
Sworn to and Subscribed
before me this day
of Y I I Y 1`._L' , 2009
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Notary Public.
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Sheriffs Office of Cumberland County
R Thomas Kline 4?ptr +t cumbex'4 Edward L Schorpp
Sheriff Solicitor
Ronny R Anderson Jody S Smith
Chief Deputy OFFCE of THE S46R1FF Civil Process Sergeant
SHERIFF'S RETURN OF SERVICE
05/28/2009 07:08 PM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on May 28,
2009 at 1908 hours, he served a true copy of the within Complaint and Notice, upon the within named
defendant, to wit: Stephen Bowman, by making known unto Shirley Bowman, wife of defendant at 42
Carlton Avenue Carlisle Cumberland County, Pennsylvania 17013 its contents and at the same time
handing to him personally the said true and correct copy of the same.
SHERIFF COST: $33.40 SO ANSWERS,
May 29, 2009 R THOMAS KLINE, ERIFF
MFUty Sheriff
2009-3455
GE Money Bank
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Stephen Bowman
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