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Home My WebLink About10-17362072568 THIS IS AN ARBITRATION MATTER. DAMAGES HEARING REQUIRED. GORDON & WEINBERG, F.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 C-) N y 7; ?T ° CHASE BANK USA, N.A. 3700 WISEMAN BLVD. SAN ANTONIO, TX 78251 Vs. PAT A HECKMAN 1432 SIMPSON FERRY RD NEW CUMBERLAND PA 17070 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : l0 - 173(0 NOTICE .a- e-m I TerN 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 0100 Pb ATry a0-0641S e a38'7sa 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 January 20, 2010 in the amount of $12,736.34. 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 7/18/08. WHEREFORE, plaintiff claims of the defendant(s) the sum of $12,736.34 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDERIC I. PEI ERG, ESQUIRE JOEL M. FLIN , ESQUIRE Attorney for Plaintiff P01A t 2072568 09296953 CHASE BANK USA, N.A. PAT A HECKMM 4031135000053255 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 furn,_shed 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. ?6v NAME D&6mvhHl is EXHIBIT "A" 2285 2072568 09296953 CHASE BANK USA, N.A. PAT A HECKMAN 4031135000053255 AFFIDAVIT I, D860nA11>k 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 $12,736.34 plus interest of $.00 at the rate of 0% less credits in the amount of $.00 totaling $12,736.34 as of December 4, 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 WorahW 'bed to (or affirmed) Sworn to and SubsAli before me this a of 2009 by Proved to me on the basis of satisfactory evidence to be the person(s) who appeared before me. Signat?e (Seal) P100.1 `1/11118/, • °''LINDA BOWARD Notary Public, State of Texas 3"•; ?• MY Commission Expires January 26, 201 t, a'a .:'u ,. ._ ,..? ,. ? _ .1 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Edward L Schorpp Solicitor k r. T ERIFF Nil C 4 r Chase Bank USA, N.A. Number vs. I 201Case0-1736 Patricia Ann Heckman SHERIFF'S RETURN OF SERVICE 03/12/2010 04:29 PM - Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on March 12, 2010 at 1627 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Patricia Ann Heckman, by making known unto Marlin Yohe, Brother of defendant at 1432 Simpson Ferry Road, New Cumberland, Cumberland County, Pennsylvania 17070 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $43.30 March 15, 2010 GERALD WORTH INGTO EPUTY SO ANSWERS, RON R ANDERSON, SHERIFF (cj Gcur' Suite Sheriff _ Telec c't. Inc. 2072568 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 CHASE BANK USA, N.A. COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. DOCKET N0. 10-1736 PAT A HECKMAN 1432 SIMPSON FERRY RD NEW CUMBERLAND PA 17070 NOTICE Pursuant to Pa.R.Civ.P. you are hereby notified you in the above procee~ LL 236 of the Supreme Court of Pennsylvania, that a judgment has been entered against ding as indicated below. Judgment by Default $12,736.34 Money Judgment $ Judgment on Allard of Arbitratora$ 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: 484/351-05 ~, PROTHONOTARY 3/~0/l D 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 20725¢,$;-i_;~_,-:~ _;, -'' - r ':tfy -.- : ~, ~,,, . -~ CHASE BANK USA, N.A. vs. PAT A HECKMAN COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. 10-1736 PRAECIPE FOR ENTRY OF JUDGMENT FOR PANT OF AN ANSNER ASSESSMENT OF DAIQ~iGES, 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 $12,736.34 Less: Payments on Account ( $.00) Total: $12,736.34 Understanding the false statements made herein are subject to penalty under 18 Pa.C.S.A. X4904, Unsworn Falsification to Authorities, I verify that: 1. The last known addresses of the parties are: CHASE BANK USA, N.A. and that the last known address of defendant, PAT A HECKMAN, 1432 SIMPSON FERRY RD, NEW CUMBERLAND PA 17070. 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 ~~~,~ pp,p~ service of the United States or otherwise within the coverage of ~yr~~~g the Soldiers and Sailors Civil Relief Act and is (are) over 18 e~ay1~7~ years of age. ~o~ ~la~d AND NOW, this ~~'' day of 2010 Judgment is entered in favor of the plaintiff(s) and ainst defendant(s) by default for want of an answer and damages assessed at the sum of , 512,736.34 as per the above certi 'catio ,•~ Prothonot ry GORDON & WEINBE~G, P.C. BY: FREDERIC WE~NBERG, ESQUIRE JOEL M. INK, ESQUIRE Attorne~ for Plaintiff 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 2072568 CHASE BANK USA, N.A. vs. PAT A HECKMAN TO/PARA COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET N0. 10-1736 NOTICE OF INTENTION TO TAIL DEFAULT PAT A HECKMAN 1432 SIMPSON FERRY RD NEW CUMBERLAND PA 17070 DATE OF NOTICE/FECHA DEL AVISO: April 7, 2010 II~ORTANT 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: FREDERI WEINBERG, ESQUIRE JOEL M LINK, ESQUIRE P10D-2