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Home My WebLink About09-42572053098 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 JC Penney 4125 Windward Plaza Drive Alpharetta,GA 30005 VS. Louise Lamoreaux 850 Yverdon Dr Camp Hill PA 17011 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. 0C(-4&5, a v<<Teey% 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 merchandise 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 May 13, 2009 in the amount of $4,608.70. 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 11/20/07. WHEREFORE, plaintiff claims of the defendant (s) the sum of $4,608.70 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. (4-7 BY: FREDERIC I. W NBERG, ESQUIRE JOEL M. FLI , ESQUIRE Attorney for Plaintiff P01A VERIFICATION 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. ez? FREDERIC I. E ERG, ESQUIRE ),0530618 In Creditor Name: GE Money Bank Debtor Name: LAMOREAUX, LOUISE Account Number: ************8855 AFFIDAVIT OF ACCOUNT BALANCE & NON-MILITARY STATUS STATE OF GEORGIA COUNTY OF FULTON :SS Court Judicial (Circuit/District) BEFORE ME, being duly sworn according to law, deposes and says that he/she is for GE Electric Capital Corporation ("GE Capital'), and that he/she is duly authorized to take this Affidavit on behalf of GE Corporation, and that the facts contained in the attached pleading are true and correct to the best of his/her information, knowledge and belief: 1. I am a competent person over eighteen years of age. I am an employee of General Electric Capital Corporation ("GE Capital"), which is an authorized servicer for certain credit accounts issued by GE Money Bank, and I am authorized to make this Affidavit. 2. The scope of my job responsibilities includes the performance of collection and recovery services. In the performance of my duties for GE Capital, I am familiar with the manner and method by which GE Capital creates and maintains its normal business records, including computer records of its credit accounts held under the name of GE Money Bank. 3. To the best of my knowledge of GE Capital's business records and practices for servicing of its credit accounts, the contents of this Affidavit are true and correct. If called upon and sworn to testify hereto I could and would so competently testify thereto. 4. In the ordinary course of business GE Capital maintains or has access to copies of credit agreements and/or credit card applications entered into between GE Money Bank and its customers enabling such customers to open and use credit accounts with GE Money Bank. I have reviewed form agreements for credit programs for which GE Capital refers accounts to attorneys for collection litigation, each of which provide that the creditor is entitled to recover, to the extent permitted by applicable law, its reasonable attorney's fees and costs incurred in any action to enforce its rights under the agreement. 5. GE Capital maintains, as a regular practice of its business, computer records of activity on GE Money Bank revolving credit accounts; including purchases made, payments received, amounts owing on such accounts, credits and offsets. It is the regular practice of GE Capital's business that entries may be made in such computer records only by individuals having personal knowledge (from examining account documentation) of the information reflected therein and that such entries are made at or near the time the events reflected in them occurred. It is also the regular practice of GE Capital's business to send monthly statements to the accountholders of GE Money Bank credit card accounts reflecting the purchases made, payments received and amounts owing on such accounts. 6. As of the date of this affidavit, GE Capital's computer records for this account reflect an unpaid balance of 4,608.70. 7. Demand has been made to the Defendant(s) more than 30 days prior hereto for payment of the unpaid balance on this account, but payment for the unpaid balance has not been made. 8. GE Capital's records for this account reflect that the Defendant or Defendants (are) or (is) not in the military service of the United States or any of its allies. I declare under the penalty of perjury that the foregoing is true and correct. ??U 5 4/22/2009 ,k AA 4OV-k?RY LIAISON SPE A IS Affiant Date T e forgoing affidavit sworn to and subscribed before me thi6 a day of , My commission expires ?i Q`: •' ?gSION •••.• "lam ??i O??A9 • 'i .. : V A9y Q .. 2 ;?iOT a ;: 410 'if IR 14 ?f ......• coUNTA 41#11111110 NCI Legal 1-800-230-9596 Document Name: Helene Thomason LA'MOREAUX, LOUISE ACCT# 6008890722308855 850 YVERDON DR REF DATE 07/09/08 CAMP HILL, PA 17011 NCI-ID 08192185117 REF AMT 4,608.70 GE FINANCE BAL DUE 4,608.70 ******************************************************************************* S T A T E M E N T O F A C C O U N T TRANSACTION DATE AMOUNT BALANCE ------------------------ -------- -------------- s ******** LAST ACTIVITY ******** Date: 5/4/2009 Time: 8:38:48 AM Q $18.5D PIS AnI Gc. 8q t 4 F-r aaq 141 Sheriffs Office of Cumberland County R Thomas Kline ?jr at'Clutrbrr,4&t Edward L Schorpp Sheriff Solicitor Ronny R Anderson Jody S Smith Chief Deputy OF'F4cE .?F -,r,„ S?-MPF Civil Process Sergeant GE Money Bank I vs. Case Number Louise Lamoreaux 2009-4257 SHERIFF'S RETURN OF SERVICE 06/29/2009 10:50 AM - Steve Bender, Deputy Sheriff, who being duly sworn according to law, states that on June 29, 2009 at 1050 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Louise Lamoreaux, by making known unto Robert Mussleman, adult in charge at 850 Yverdon Drive Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $41.50 June 30, 2009 SO ANSWERS, R THOMAS; KLINE, SHERIFF r Z Deputy Sheriff N C? ..o C- C= rs?s rv .r7 rl.? C? -i C 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 2053098 GE Money Bank D/B/A JC Penney vs. Louise Lamoreaux COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 09-4257 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 $4,608.70 Less: Payments on Account ( $.00) Total: $4,608.70 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/AJC Penney and that the last known address of defendant, Louise Lamoreaux, 850 Yverdon Dr, Camp Hill PA 17011. 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 day of AU0 2009 Judgment is entered in favor of the plaintiff(s) and gainst defendant(s) by default for want of an answer and damages assessed at the sum of , $4,728.70 as per the above certi ication. Prothono ary GORDON & WEINBE , P.C. BY: FREDERIC I W NBERG, ESQUIRE JOEL M. FL , ESQUIRE Attorney for Plaintiff 2053098 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 JC Penney COURT OF COMMON PLEAS CUMBERLAND COUNTY Louise Lamoreaux TO/PARA Vs. DOCKET NO. : 09-4257 NOTICE OF INTENTION TO TAKE DEFAULT Louise Lamoreaux 850 Yverdon Dr Camp Hill PA 17011 DATE OF NOTICE/FECHA DEL AVISO: July 21, 2009 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: FREDERIC VVINBERG, ESQUIRE JOEL M. FL K, ESQUIRE P10D-2 RLED-C,l: ICF OF THE FPOT I? NIOTARY 2009 AUG 19 PH 2: 52 +14.00 Pry ATTY 0 e S14 8S t4 aac.4aA ti 2053098 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 JC Penney VS. Louise Lamoreaux 850 Yverdon Dr Camp Hill PA 17011 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 09-4257 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. Judgment by Default $4,608.70 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 P THONOTAR 8//R/o9 2053098 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 JC Penney VS. Louise Lamoreaux COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. ORDER To SATISFY JUDGDNT TO THE PROTHONOTARY: 09-4257 rn? c ' -r M C Cn Z) -> C) ? N co 5' e7 Kindly mark the judgment entered August 19, 2009 in the above-captioned matter satisfied upon payment of your costs only. GORDON & WEINBERG, P.C. BY: FREDERIC I. EIN ERG, ESQUIRE JOEL M. FLIN , SQUIRE Attorney for Plaintiff P005 PI,Y ? ?- (1 D D y? eaaaa?913 Red