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Home My WebLink About09-51472059917 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 FIA CARD SERVICES, N.A. f/k/a BANK OF AMERICA 1825 E. BUCKEYE RD. PHOENIX, AZ 85034 VS. JEFFREY L FORSYTHE 650 BALTIMORE PIKE GARDNERS PA 17324-8805 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : Qq - !Sl x'1 CI o ( rM 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 April 22, 2009 in the amount of $7,400.93. 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 3/6/08. WHEREFORE, plaintiff claims of the defendant(s) the sum of $7,400.93 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDERIC I. WEI BERG ESQUIRE JOEL M. FLINK, IRE 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. `?-n FREDERIC I. WEINBERG, ESQUIRE EXHIBIT "A" e,20 5-491 q STATE OF Georgia ) COUNTY OF Cobb ) FIA CARD SERVICES, N.A. V. JEFFREY L FORSYTHE AFFIDAVIT OF ACCOUNT COMES NOW, Christie McElreath, and after being duly sworn before the below person authorized to administer oaths states the following: 1. I am over 18 years old and sui juris. 2. I am agent for FIA CARD SERVICES, N.A.. 3. I am familiar with the books and records of the Plaintiff. 4. These books and records are kept in the ordinary course of business. 5. The agreement attached hereto is true and correct. 6. The Defendant (s) owe (s) the principal sum of $7,400.93. 7. I know no liability insurance, bond or other security which may be available to pay this debt. 8. The Defendant (s) account number for which he owes the debt is 4800115992633537. 9. The Defendant (s) is/are not a minor nor an incompetent person. 10. Affiant has no knowledge of whether the Defendant (s) is/are on active duty in the military. 11. The Defendant (s) is/are past due on this account and in breach of the contractual agreement to pay as agreed. e L Agent Christie McE reath FIA CARD SERVICES, N.A. Sworn to and subscribed before me this &of, .,?, 2009. P WASy /,L . NOTARY PUBLIC My Commission ExC? $;` EXPIRES SO GORDON & WEINBERG, P. - 1IZC? DEC. 17, 201 10 ' 09079746 JEFFREY L FORSYTHE 650 BALTIMORE PIKE GARDNERS PA 17324-8805 ACCOUNT NUMBER 4800115992633537 FIA CARD SERVICES, N.A. BALANCE AS OF PAYMENT MINIMUM PAYMENT DUE DATE PAYMENT ENCLOSED April 4, 2009 PAST DUE $7,400.93 $ Make Checks Payable to Bank of America, N.A. (USA) MESSAGE FROM-SANK OF AMERICA, N.A. (USA) YOUR ACCOUNT WITH FIA CARD SERVICES, N.A.IS PAST DUE $7,400.93. THE PAST DUE AMOUNT IS INCLUDED IN THE MINIMUM PAYMENT. THE PAST DUE AMOUNT INCLUDES THE ORIGINAL PRINCIPAL BALANCE OF $7,400.93. PLEASE REMIT IMMEDIATELY. IF YOU HAVE ALREADY SENT A PAYMENT FOR THE ABOVE AMOUNT, THANK YOU. 0 FL F t-) n,r T, 'w TA R Y 1Cu9 i .+L r 9 M i 1 I: 4 i *%,!50 Pb AM--f C& rp 81'1 at a a85?3 4 2059917 GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 XOEL M. FLINK, ESQUIRE Identification No.: 81894 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 FIA CARD SERVICES, N.A. f/k/a BANK OF AMERICA VS. JEFFREY L FORSYTHE COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 09-5147 PRAECIPE FOR ENTRY OF JUDGMENT FOR WANT OF AN ANSWER, ASSESSMENT OF DAMAGES, VERIFICATION OF ADDRESS AND NON-MILITARY SERVIC19 TO THE PROTHONOTARY: Enter judgment for want of an answer for plaintiff and against defendant(s) JEFFREY L. FORSYTHE above named only and assess damages certified to be calculable as a sum certain from the complaint, as follows: Principal $7,400.93 Less: Payments on Account ( $.00) Total: $7,400.93 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: FIA CARD SERVICES, N.A.f/k/a BANK OF AMERICA and that the last known address of defendant, JEFFREY L FORSYTHE, 650 BALTIMORE PIKE, GARDNERS PA 17324-8805. 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 3CA day of 'E , 2009 Judgment is entered in favor of the plaintiff(s) an against defendant(s) by default for want of an answer and damages assessed at the sum of , $7,517.33 as per the abov ertificat' if )1W P thonota GORDON & WEINBERG, P.C. BY: FREDERIC I. WE ERG, ESQUIRE JOEL M. FLI ESQUIRE Attorney for Plaintiff 2059917 GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 FIA CARD SERVICES, N.A. f/k/a BANK OF AMERICA Vs. JEFFREY L FORSYTHE TO/PARA COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 09-5147 NOTICE OF INTENTION TO TAKE DEFAULT JEFFREY L FORSYTHE 650 BALTIMORE PIKE GARDNERS PA 17324-8805 DATE OF NOTICE/FECHA DEL AVISO: August 27, 2009 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY AN ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER- IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 GORDON & WEINBERG, P.C. BY: FREDEP C I(. WEINBERG, ESQUIRE JOEL?. FLINK, ESQUIRE P10D-2 OF THE PROTHOROM 2009 SEP 30 PM 1: 14 014"A'al 4 4. oo PA A-n-Y Cr,r qa IG$ 04 Ablao No-he e WOLAIJ 2059917 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 FIA CARD SERVICES, N.A. f/k/a BANK OF AMERICA VS. JEFFREY L FORSYTHE 650 BALTIMORE PIKE GARDNERS PA 17324-8805 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO NOTICE 09-5147 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. /L Judgment by Default $7,400.93 ?L Money Judgment $ ?L Judgment on Award of Arbitrators$ f? 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 Lob, -low P HONOT Sheriffs Office of Cumberland County R Thomas Kline Sher Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant ~atti~~ir of ~uinb~^rf,~~d ~^ ~ ~JficiL"E C.c fHE i~kP.i=F Fll ~ Ti-i ~ ~ . _ `` ~,~~ 3 Ntic1 ! t t5 i~ .J' ~ / t'r~ ~ L. f ,. , t 1.. Edward L Schorpp Solicitor FIA Card Services Case Number vs. Jeffrey L. Forsythe 2009-5147 SHERIFF'S RETURN OF SERVICE 07/31/2009 04:14 PM -Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on July 31 2009 at 1614 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Jeffrey L. Forsythe, by making known unto Linda Forsythe, wife of defendant at 650 Baltimore Pike Gardners, Cumberland County, Pennsylvania 17324 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $37.90 August 03, 2009 SO ANSWERS, .its' R THOMAS INE, SHERIFF l D uty eriff