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Home My WebLink About10-18872074163 THIS IS AN ARBITRATION MATTER. ASSESSMENT^,OF DAMAGES HEARING REQUIRED. C ° GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE rl ? i Identification No.: 41360 fr -- ° JOEL M. FLINK, ESQUIRE Identification No.: 41200 Ti ?' y rn 1001 E. Hector Street, Ste 220 - . ., Conshohocken, PA 19428 E 484/351-0500 c:) FIA CARD SERVICES, N.A. 655 PAPERMILL RD Newark DE 19711 Vs. MARIA ARCE 208 SENATE AVE APT 214 CAMP HILL PA 17011 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : Ib - 188x/ 0,iV;17e-r " 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 "g. 00 P A AT'll Gc`? togo? a 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)tae 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 February 5, 2010 in the amount of $1,460.95. 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 9/29/07. WHEREFORE, plaintiff claims of the defendant(s) the sum of $1,460.95 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDERIC I. WE NBERG, ESQUIRE JOEL M. FLINK, ESQUIRE Attorney for Plaintiff P01A 2074163 FIA CARD SERVICES, W.A. MARIA ARCS 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 ofcobnsel 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. +`FiSiGP ?,??°t3e o N ^ oia 4y_ c f. p w> +?CA R-r??, Hwy ,? > .ar NAME "i .„ '.. +so ` EXHIBIT "A" MARIA ARCL 2074163 FIA CARD SERVICES, N.A. State of North Carolina 5 f County of Guilford 5 I, Robin Mays and say that: AFFIDAVIT , being duly served sworn according to law, depose 1. I am the agent for the Plaintiff herein and I have custody and control of the files relating to this accounts 2. 1 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 $1,460.95 plus interest of $.00 at the rate of 0% less credits In the amount of $.00 totaling $1,460.95 as of January 19, 2010. 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. AFFIANT Sworn to and Subscribed before me this day of 2010 U I( 7W1 Public ?O -A P? f s ?V? ?QIQf??•.i?P P?? d. C, 'irk fi,+;",yd +Ak:8Y7$90®bi???RO SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Edward L Schorpp Solicitor ~~~~~t~~, aC ~tiiuGr~.~~~~ t ~;~~F . F '-t: -..c ~.: al~~ ~,.~"t~~ 20ifl MAR 25 F~ Z= ~C~ ~r~~'c.N~SYLVA-~A ~ FIA Card Services vs. Case Number Maria Arce 2010-1887 SHERIFF'S RETURN OF SERVICE 03/20/2010 08:55 AM -Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on March 20, 2010 at 0855 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Maria Arce, by making known unto herself personally, at 208 Senate Avenue Apartment 214, Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $41.50 March 22, 2010 r-- ---->~ .~ DENNI Y, DEPU~ SO ANSWERS, "~.- RON R ANDERSON, SHERIFF ~~Cll!~' 1 t~ j hE;Yl 1 ~E:. 'it)~( !'-;:. 2074163 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. vs. MARIA ARCS 208 SENATE AVE APT 214 CAMP HILL PA 17011 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO 10-1887 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 $1,460.95 ~ Money Judgment $ ~ Judgment on Award of Arbitratora$ ~,L 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: 484/351-050 PROTHONOTARY ~/!o//O 2074163 CORDON & WEINBERG, P.C. C7 BY: FREDERIC I. WEINBERG, ESQUIRE {~ `" :~~ ~- n Identification No.. 41360 -r~'~c ~' "=' ~~ JOEL M. FLINK, ESQUIRE -- -` "~ '~ ~ T~ Identification No.: 81894 ~1z. rn 1001 E. Hector Street, Ste 220 ~ _~ Conshohocken, PA 19428 _`%`' =~= 484/351-0500 ~ ~-~ ~ ~`~' .~~ • • -_~ ~ 1 ~~ °.~ FIA CARD SERVICES, N.A. COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. MARIA ARCS DOCKET N0. 10-1887 PRAECIPE FOR ENTRY OF JUDGi4ENT FOR WANT OF AN ANSWER ASSESS~NT OF DAI~GES, 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 $1,460.95 Less: Payments on Account ( $.00) Total: $1,460.95 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. and that the last known address of defendant, MARIA ARCS, 208 SENATE AVE APT 214, 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 the Soldiers and Sailors Civil Relief Act and is (are) over 1 years of age. of 8 ~1~.00 PA A'-'ty/ C~ ! / 48oZ.8 2~'a~l~c~~~ ~o hce ~l,(c~ lec~ AND NOW, this [p`+~ day of 2010 Judgment is entered in favor of the plaintiff(s) and gainst defendant(s) by default for want of an answer a damages assesse at the sum of , $1,460.95 as per the above certifj2 at ~On.~ // c, \) Prothono~ry GORDON & WEINBEljf~, ,.~P ~C . BY: FREDERIC INBERG, ESQUIRE JOEL M. F INK, ESQUIRE Attorne for Plaintiff f 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 19928 984/351-0500 2074163 FIA CARD SERVICES, N.A. vs. MARIA ARCE COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET N0. 10-1887 NOTICE OF INTENTION TO TAIO; DEFAULT TO/PARA MARIA ARCS 208 SENATE AVE APT 214 CAMP HILL PA 17011 DATE OF NOTICE/FECHA DEL AVISO: April 13, 2010 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: FREDERI I. EINBERG, ESQUIRE JOEL FLINK, ESQUIRE P10D-2