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Home My WebLink About10-1732iv 2073012 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 T? o "T= -n nlr_ o > Q ? I= 7 (. ? C'? CHASE BANK USA, N.A. 3700 WISEMAN BLVD. SAN ANTONIO, TX 78251 Vs. CANDIDA ARENA 289 PLAZA DR BOILING SPRINGS PA 17007-9433 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : Ip - 11301 3-yiITar-a' 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 O t, 101 04a3log7 I' 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 or Affidavit 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 1/22/10 in the amount of $2,858.18. 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 11/2/08. I! WHEREFORE, plaintiff claims of the defendant(s) the sum of $2,858.18 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDERIC-I. EINB RG, ESQUIRE JOEL M. FLIN QUIRE Attorney for Plaintiff P01A 1 ? r s 2073012 09450182 CHASE BANK USA, N.A. CANDIDA ARENA 4266841161851447 VERIFICATION I hereby state that I am the agent for the plaintiff herein, and that the facts set forth in the attached Affidavit which is incorporated by reference in the foregoing Complaint in Civil Action are true and correct to the best of my knowledge, information and belief and is based upon information which plaintiff has furnished to counsel. The language in the Complaint is that of counsel and not of plaintiff. To the extent that the contents of the Complaint are that of counsel, plaintiff has relied upon counsel in making this verification. This verification is made subject to 18 Pa.C.S. §4904 which provides for certain penalties for making false statements. NAME Deborah Hick EXHIBIT "A" !1 1 1 & v ,,2285 2073012 09450182 CHASE BANK USA, N.A. CANDIDA ARENA 4266841161851447 ??G. AFFIDAVIT I , Debon7 Hkk 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 $2,858.18 plus interest of $.00 at the rate of 0% less credits in the amount of $.00 totaling $2,858.18 as of December 7, 2009. 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. AFFIAN Sworn to and Subscribed to (or affirmed) before me this -22:-day of De-c-- 2009 by dULWV79 Nil-Al Proved to me on the basis of satisfactory evidence to be the person(s) who appeared before me. Si t (Seal) P10 LINDA 80WARD ???:?", *6, t Notary Public, State of Texas My Commission Expires January 26, 2011 R 0 J Y SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Edward L Schorpp Solicitor i RM-MCcE P , I'vl.. 4 i 2010 MAR 22 f? M 81: v 9 l1CId 1??1 ?_ `T `! Chase Bank USA, N.A. vs. Candida Arena Case Number 2010-1732 SHERIFF'S RETURN OF SERVICE 03/19/2010 Jason Vioral, Sergeant, who being duly sworn according to law, states that on March 19, 2010 at 1337 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Candida Arena, by making known unto herself personally, at The Cumberland County Sheriffs Office, 1 Courthouse Square Room 303, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $38.80 March 19, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF JASON OR , SERGEANT !ci CouriyStAe Sherff. T7eieosoft. Inc