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HomeMy WebLinkAbout10-2783J 2075389 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 COURT OF COMMON PLEAS CUMBERLAND COUNTY CHASE BANK USA, N.A. 3700 WISEMAN BLVD. SAN ANTONIO, TX 78251 Vs. AMANDA TRITT 473 E KING ST SHIPPENSBURG PA 17257-1501 ASSESSMENT OF o 'Yl Lr^ y" -- n? r c: -v c? w _T CZi ? -may ?T OT .,1 L J rn DOCKET NO. : 10 -,Z%5 OA-V?t iem 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 4Q1.00 PA AT"q Gcrt llaan l p,?' ay ! l lo'J 4. 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 3/2/10 in the amount of $1,961.34. 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 11/16/08. 1 41, WHEREFORE, plaintiff claims of the defendant(s) the sum of $1,961.34 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDERIC L?K, EINBERG, ESQUIRE JOEL M. ESQUIRE Attorney for Plaintiff P01A P 2075389 09496432 CHASE BANK USA, N.A. AMANDA TRITT 4266841058744895 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 Ruben EXHIBIT "A" M ' 2285 2075389 09496432 CHASE BANK USA, N.A. AMANDA TRITT 4266841058744895 Ruben A. A MM I, law, depose and say that: AFFIDAVIT , being duly served sworn according to 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 $1,961.34 plus interest of $.00 at the rate of 0% less credits in the amount of $.00 totaling $1,961.34 as of February 3, 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 At Sworn to and Subscribed to (or afrfirmed) 2010 before me this day of 14/11? by 9P»fion A O&OW Proved to me on the basis of satisfactory evidence to be the personNr`yho apppar'l before me. Signature P100.1 DORTHIA DEM90 Naiary Public, State of Texas My Commission Expires Noyember 13, 2011 (Seal) of C0 M° David 1D. cBued F Renee X Simpson 1Prothonotary 0 Z 1St Deputy Prothonotary 7CirkS. Sofionage, E,SQ �y Irene E. 9lorrow Solicitor „so 271' Deputy Prothonotary Office of the Prothonotary Cum6er(and County, Pennsylvania JO —g2783 CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 29TH DAY OF OCTOBER, 2013,AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE-THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R.C.P.230.2. BY THE COURT, DAVID D. BUELL PROTHONOTARY One Courthouse Square • Suite 100 • Carlisle, PA 17013 • (717)240-6195 • Fax(717)240-6573