HomeMy WebLinkAbout10-3843;OURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CAVALRY PORTFOLIO SERVICES, LLC, AS
ASSIGNEE OF CAVALRY SPV I, LLC, AS
ASSIGNEE OF GE MONEY BANK
Plaintiff
v.
WII.LIAM BARRICK JR
Defendant(s)
CIVIL ACTION ~ _
~ ,
~ .- .a..e
-~. rF~~-
-O ~i°^F
NOTICE TO DEFEND ~ ,: ° f ;~;
:?; -r~
~F1 '-G
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 IS 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 FAII. TO DO SO,
THE CASE MAY PROCEED WITHOUT YOU AND A JUDGMENT 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.
THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE
USED FOR THAT PURPOSE.
CUMBERLAND COUNTY BAR ASSN
32 S BEDFORD ST
CARLISLE, PA 17013
(717) 249-3166
13829247
Thomas Law Offices, PLLC
By: ~ ~~
Douglas M. arinos, Esquire
Atty. I.D. #53104
Attorney for Plaintiff
101 North Cedar Crest Blvd
Allentown, PA 18104
(866) 434-2993
cx ~6~74
~-~ a,93
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CAVALRY PORTFOLIO SERVICES, LLC, AS
ASSIGNEE OF CAVALRY SPV I, LLC, AS
ASSIGNEE OF GE MONEY BANK CIVIL ACTION
Plaintiff CASE NO.:
v. .
COMPLAINT
WILLIAM BARRICK JR
Defendant(s)
1. Plaintiff, Cavalry Portfolio Services, Llc, As Assignee Of Cavalry Spv I, Llc, As Assignee Of Ge Money
Bank, ("Cavalry") is a Limited Liability Company with an address of 7 Skyline Drive, 2nd Floor, Hawthorne,
New York, 10532.
2. Defendant(s), William Barrick Jr, is/are an adult individual with an address of:
WII.LIAM BARRICK JR
116 SALEM CHURCH RD
MECHANICSBURG, PA 170502834
3. On or about 7/31/2007, Defendant executed a Revolving Credit Agreement ("Agreement")bearing interest at
the rate of 10%. A true and correct copy of the Agreement is attached hereto, made a part hereof and marked as
Exhibit "A".
4. The Defendant defaulted under the terms of the Agreement by failing to make the monthly payments when
due.
5. The balance due and owing on the aforesaid application is $9,848.44 as of May 18, 2010.
13829247
6. Despite repeated demands, the Defendant has failed and refused to pay the aforesaid balance due and owing.
7. Defendant has not objected to account statements issue.
8. Defendant is liable to Cavalry on this debt as an account stated.
9. Pursuant to the Agreement, Cavalry may declare all amounts due under the Agreement immediately due and
payable without notice or demand.
10. Defendant is in default of the terms of the Agreement and is indebted to the Plaintiff in the amount of
$9,848.44 plus interest at the rate of 10% per annum as of the date of filing pursuant to the Application.
WHEREFORE, Cavalry demands judgment against the Defendant in the amount of $9,848.44 plus
interest from and after date of calculation, at the per annum rate of 10% and costs of suit.
Thomas Law Offices, PLLC
By: G~%~n~o
Douglas M. arinos, Esquire
Atty. I.D. #53104
Attorney for Plaintiff
101 North Cedar Crest Blvd
Allentown, PA 18104
(866) 434-2993
13829247
ATTORNEY VERIFICATION
I, DOUGLAS M. MARINOS, ESQUIRE, do hereby verify that I am the Attorney
for Plaintiff, CAVALRY PORTFOLIO SERVICES, LLC, AS ASSIGNEE OF CAVALRY SPV
I, LLC, AS ASSIGNEE OF GE MONEY BANK, that I am fully authorized to make this
verification on its behalf and that the Plaintiff is unavailable to make this Verification and that
the facts set forth in the attached pleading are true and correct to the best of my knowledge,
information and belief and that the source of my information is interviews with my client and the
Plaintiff s filed documents.
Verifier understands that false statements herein made are subject to the penalties
of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities.
DOUG AS M. MARINOS, Esquire
Dated: May 18, 2010
EXHIBIT "A"
~owE's
[O415L]
C822 (8/07) 7031-SCHUMER-T&C-I-REV 6/08
i ~ ~ ~• ~ ~ ~
ANNUAL PERCENTAGE RATE FOR PURCHASES
21.99%
GRACE PERIOD FOR REPAYMENT OF THE BALANCE FOR PURCHASES
26 days if no previous balance or full payment is made; otherwise none
METHOD OF COMPUTING THE BALANCE FOR PURCHASES
Average Daily Balance {Including New Purchases)
MINIMUM FINANCE CHARGE
$1.00
Late Payment Fee: $0 for a Balance under $30; $15 for a Balance of $30-$49.99; $20 for a Balance of $50-$99.99; $30 for a Balance of
$100.00-$999.99; and $35 for a Balance of $1,000 or more. (Balance means Previous Balance on Statement that shows the Late Fee.)
Returned Check Fee: $20
The information about the costs of the Card described above is accurate as of June 1, 2008. This information may have Changed after that date. To
find out what may have changed, write to us at P.O. Box 981064, EI Paso, TX 79998-1064. If approved, the full terms of the Agreement: (a) will be
sent to you with your card, (b) will be governed by federal and Utah law, and {c) may be changed by us as provided in the Agreement.
CONSENT TO ELECTRONIC COMMUNICATIONS
1. Categories of Communications.
You understand and agree that GE Money Bank, the issuer of Lowe's Credit Card, our assignees, or other holders of your Lowe's Credit Card account ("GEMS", "we" or "us") may pro-
vide to you by electronic means the following categories of information with respect to applying for and obtaining a Lowe's Credit Card account ("Account'), which may include dis-
closures required by applicable federal or state law (collectively, "Communications")
• The Lowe's Credit Card Agreement ("Agreement"), including, wdhout limitation, any Truth in Lending Act disclosures; and
• Other federal and state law disclosures, notices and communications in connection with the application for an Account or opening an Account.
• GEMB's Privacy Policy For The Lowe's Credit Card Program.
2. Manner of Consent.
You acknowledge that by agreeing to the Consent to Electronic Communications through this website, you demonstrate that you qn access informatlon that we would provide to you
by posting electronic Communicabons on our website.
3. How to Withdraw Consent.
You may withdraw your consent to receive electronic Communications by not submitting your online application. However, you may not apply online unless you consent to receive elec-
tronic Communications.
4. Hardware and Software Requirements.
In order to access and retain Communications, you must have:
• An Internet Browser which supports HTML 4.0 and SSL-encryption, such as Netscape 4.0 or later and Microsoft Internet Explorer 4.0 or later.
• A means to print or store notices and information through your browser software.
• A personal computer or equivalent device capable of connecting to the Internet via dial-up, DSL, Cable Modem, Wireless Access Protocol, or equivalent, and that supports the
foregoing requirements.
5. Paper Copies of Communications.
Upon your request, we will send you a paper copy of the Agreement, GEMB's Privacy Policy for the Lowe's Credit Card Program and/or other material provided pursuant to the Consent
to Electronic Communication. If you would like a paper copy of any of this material please wnte to us at P.0. Box 103064, Roswell, GA 30076 or call us at 1-877-969-9017. There will
be no charge for a paper copy of this material.
6. Communicatlons in Writing.
All Communications in either electronic or paper format from us to ou will be considered "in writing:' You should print or download a copy of this Consent to Electronic Communication,
the Agreement, GEMB's Privacy Policy for the Lowe's Credit Card Program, your application and any other Communication that is important to you for your records.
7. Electronic Signatures.
You acknowledge that by clicking on the "I Agree" or similar button at the Lowe's Credit Card application, you are indicating your intent to sign the relevant document or record and
that this shall constitute your signature.
8. Federal Law.
You acknowledge and agree that your consent to electronic Communications is being provided in connection with a transaction affecting interstate commerce that is subject to the fed-
eral Electronic Signatures m Global and National Commerce Act, and that you and we both intend that the Act apply to the fullest extent possible to validate our ability to conduct busi-
ness with you by electronic means.
Federal law requires us to obtain, verify, and record information that identifies you when you open an account. We will use your name, address, date of birth, and other informa-
tion for this purpose.
GE MONEY BANK
CREDIT CARD AGREEMENT
RETAIL INSTALMENT CREDIT AGREEMENT
Nonnegotiable Consumer Note
1. GENERAL. This Agreement ("Agreement') gavems Your Lowe's credit card arxount ("Account"). In
this I~reement and your billing statement ("SStatement' , "we", "us",and "our" means GE Money Bank,
4246 South Riverboat Road, Suite 200, Salt Lake City, ~T 84123-2551; "you" and "your" means all per-
sons who we approve to use the Account; and "Card' means your Lowe's Credit Card. The effective date
of this Agreement ("Effective Date") will be the earlier of (i) the date you submit an Account application
that is approved by us, or (ii) the first da0a that you or someone authorized by you uses the Account [in
NY the first date that you or someone authorized by you signs a sales slip a memorandum indicating
a Purchase (as defined herein) on the Account].
2. USE OF ACCOUNT. You may use your Account to purchase goads a services ("Purchases"), up
to any credit limit we may establish ("Credit Limit"). We may decline to authorize arty Purchase or
change your Credit Limit at arty lime. You may use your Account only for personal, family orhouse-
hddpurposes.
S. PROMISE TO PAY. You promise to pay us for all credit that we extend on your Account fa
Purchases and all other amounts owed to us under the terms of this Agreement.
4. FINANCE CHARGES.
A. The Finance Charge for a billing period is calculated by applying the Periodic Rate to the Account
balance subject to Finance Charge for each day in the billing period and adding together all of those
daily Fnance Charge amounts. There is a minimum FINANCE CHARGE of X1.00 for a billing
period in which a F~finance Charge is assessed.
B. The Periodic Aate fa your Account is .06025% (ANNUAL PERCENTAGE RATE 21.99%).
5. BALANCE SUBJECT TO FINANCE CHARGE.
A. The balance sub' ct to finance Charge is the Daily Balance of the Account. However, there is no
balance subject to Finance Charge for a billing period ii there is no Previous Balance on your Account
for that billing period or the sum of your payments and credits on your Account during the billing peri-
od is atleast equal to the Previous Balance.
B. To determine the Account balance subject to Finance Charge, we take the beginning balance of your
Account each day, which includes arty unpaid Finance Charges and add any new Purchases and other
debits for that day and subtract any payments and other aedits applied that day. Each day we also
add arty Finance Charges, late Payment Fees, and Returned Check Fees assessed that day. Debt can-
cellation fees and credit insurance premiums, if any, are not included. This gives us the "Dairy
Balance" of the Account. Any Dairy Balance of less than zero will be treated as zero.
B. WHEN FINANCE CWIRGES BEGIN TO ACCRUE. If there is no Previous Balance for the billing peri-
od athe sum of your payments and credits for the billing period is at least equal to the Previous
Balance, new Purchases and other charges in that billing period will begin to, acaue a Finance Charge
as of the first day of the next billing period if a finance Charge is imposed in the next billing period.
If there is a Previous Balance is the billing period and the sum of your payments and credits for the
billing period is not at least equal to that Previous Balance, new Purchases and other charges in that
billing period will begin to accrue a Finance Charge from the later of the date of the transaction or the
lirst day of the billing period in which the transaction is posted to your Account.
7. PAYMENTS.
A. You must pay at least the Minimum Payment on your Statement by 5:00 p.m. (ET) on the Payment
Due Date shown on the Statement. You may pay more than the Minimum Payment at arty time. Ii you
have a balance subject to finance charge, earlier payment may reduce the amount of finance charges
you will pay. The Minimum Payment initially will be the sum of (i) the greater of: (a)1/35th of the New
Balance shown on your Statement, rounded to the next highest dollar, or {b) $15, plus (ii) the month-
Iycharges for arty optional credit insurance or debt cancellation product you have electeddto purchase
for your Account. However, it during any four month period immediately following a billing period in
which a late fee is assessed, you pay at least the Minimum Payment each month but the total of your
payments does not at least equal the sum of the finance charges billed on your Statement each
month, plus 1 % of your New Balance each month, plus the particular late fee that was assessed in
the billing period before the four month period, your Minimum Payment will be changed for future
months to the greatest of $15,1i35th of your New Balance, rounded to the next highest dollar, or the
sum of 1% of your New Balance plus finance charges and late tees billed on your Statement, round-
ed to the next highest dollar. In each case, (i) if your New Balance is less than $15, your Minimum
Payment will be equal to the New Balance, and (ii) if your New Balance is greater than $15, your
Minimum Payment also will include any past due amounts and any payment due in connecten rnth
a specific promotional purchase.
S. All written commrniptiora concerning disprtad amornta, including airy chedr or other pay-
ment instromenl fiat (I) ladkates that the pa(ym1erd coratidtes "payment in till" or la tendered
(SDiapuMd ParmeMs' ),dm,~ be mailed or delivered t his al the addcess for billing inl9niries
shown on the talemerd, not the Payment Address.
C. All payments, except Disputed Pa moots, must be mailed or delivered to us at the address shown
on your Statement (the "Payment Address"). We may also offer services in which you may pay your
bill by telephone ("Pay by Phone") or through the Internet. We may charge fees for these services. Our
customer service representatives are instructed to Tell you about any fees far Pay by Phone. services
and any fee fa making an online payment will be disclosed to you ailine. Arty payments received after
5:00 p.m. (ET) on any business day, or on any day other than a business day, volt be credited on the
next business day. Creditto your Account maybe delayed up to five dayys if payment (a is not received
at the Payment Address, (b) is not made in U.S. dollars drawn on a U.S. financial insti utlon located in
the U.S., (c) is not accompanied by the remittance coupon attached to your statement, (d) contains
more than one payment or remittance coupon, (e is not received in the remittance ernelope provided
or (f) includes staples, paper clips, tape, a tolde~ check, or correspondence of any type. You under-
stand,however, that payments may not be made, and may not be deemed received by us, at any Icea-
tion other than the Payment Address, at a Lowe's store in the United States or via our Pay by Phone
or online payment services, if provided. Although we post your payments in the manner described
above, we may delay restoring your available Credit Limit in the amount of your pa moot. All credits
for payments to your Account are subiect to final payment by the institution on which the item of pay-
meniwas drawn.
D. We reserve the right to select the method by which payments and credits are allocated to your
Account in our sole discretion. The payment allocation method that we use may result in higher
Finance Charges on your Account, depending on the types of transactions you make (such as promo-
tional ornon-promotional purchases), and the timing and amount of your payments. if you have any
questions about the allocation of your payment or would prefer to choose a different payment alloca-
tion option we offer, please call customer service at 1-800-444-1408.
E. We reserve the right to obtain payment electronicalry for any check or other ihstrument that you
send to us by initiating an ACH (electronic) debit in the amount of your check or instrument to your
account. Your check a item will not be retumed to you by us or your bank. Your bank account may
be debited as early as the same day we receive your payment.
S. FEES. You agree to pay the fallowing fees.
A. If we have not received your required Minimum Payment by 5:00 p.m. (ET) on tfce Payment Due
Date shown on your Statement, we may Impose a Late Payment Fee, based on your New Balance at
the time your delinquent Minimum Payment was calculated, as indicated below:
Under 0.00 D~
$30 - $49.99 $$15
$100 $999.99 $30
$1000 or above $35
B. A Returned Check Fee of $20 if any check or other instrument sent to us, or arty electraiic pay-
ment authorization you provide us in payment on your Account, is not honored upon first present-
ment, even if the check, instrument or electronic authorization is later honored.
9. CANADIAN TRANSACT10N3. In addition to making Purchases from Lowe's in the United States,
your Card can also be used to make Purchases from any Lowe's store in Canada (each such Purchase,
a "Canadian Purchase"). In addition to all other provisions of this Agreement, the following addition-
alterms will appy to each Canadian Purchase.
A. Ii you make or return a Canadian Purchase in Canadian dollars, we will convert the transaction
amount into U.S. dollars using our currency conversion procedure. Under the currency conversion
procedure that we currently use, the Canadian dollar transactiai amount is converted into a U.S. dol-
laramount by mulliptying the transaction amount in the Canadian dollar currency by a currency can-
version rate. The currency conversion rate that we currently use is a prevailing foreign exchange rate
selected in our discretion. The currency cornersion rate drat we use for a particular transaction is the
rate in effect when we do the cornersion. This rate may differ from the rate in effect when the
Canadian Purchase or retum occurred or when it was posted to your Account, and may be higher or
lower than the rate you could have gotten if you had converted U.S. dollars into Canadian dollars.
B. Returns of Canadian Purchases will be subject to Lowe's return policies. Under the return policies
currently in effect, a Canadian Purchase can only be returned at a Lowe's store in Canada and cannot
be returned at a Lowe's store in the United States. In the event that a United States Lowe's store does
permit the return or exchange of the Canadian Purchase, the Lowe's store will not issue a credit to
your Account for the Canadian Purchase amount. For example, the United States Lowe's store, in its
discretion, may provide you with other merchandise, a gift card or cash in exchange for the Canadian
Purchase. The Canadian Purchase amount will continue to be a part of your Account balance, and you
will remain responsible for paying the Canadian Purchase amount.
10. SECURITY INTEREST. You grant us a purchase money security interest in each item of merchan-
dise purchased on your Account to secure its unpaid purchase pnce until such merchandise is paid
in full. Solely for the purpose of determining the extent of our purchase money security interest in
each such item of merchandise, your payments ewll be allocated first to Finance Charges on the
Account, and then to pay oft each Purchase on the Account in the order in which die Purchase was
made (ii more than one item was purchased on the same day, your payments will be allocated to pay
oil the lowest priced item first). If you made a Purchase pursuant to a credit promotion, the balance
with respect to the promotlonal Purchase may be shown on Statements during the promotional peri-
odand may reflect a different payment allocation method. In no event will we assert a security inter-
est inthe promotional Purchase to an amount greater than the lowest balance shown on a Statement
for that promotlonal Purchase. We agree that no secunty interest is or will be retained or acquired
under this Agreement in any real property which is used or is expected to be used as your dwelling.
11. SPECIAL PAYMENT PLANS. From time to time, you may be offered special promotional terms
which madity the terms of this Agreement with respect to certain Purchases on your Account
("Special Payment Plans"). The provisions of this Agreement apply to any Special Payment Plan,
unless otherwise provided in this Agreement or under the Special Payment Plan offering.
12. TERMINATIONICHIINGE IN TERMS. You may terminate yourAccount atany time by providing us
written notice. We may, at arty time and subject to applicable law, change, add or delete provisions of
this Agreement "Terms Change") or terminate your Account. Unless prohibited by applicable law, we
may apply any 1(erms Change to any outstanding or future balances of your Account. We volt send to
you notice of any Terms Change as required by applicable law. Upon any termination of your Account,
you remain obligated to repay the balance of your Account and this Agreement will continue to apply
until you do so.
19. DEFAULT. Subject to the limitations of applicable law, we may declare you in default it you: (i) tail
to make at least the Minimum Payment when due; (ii) violate any other term of this Agreement; or
(iii) become the sul~ect of a bankruptcy or insolvency proceeding. After your default or our death,
and subject to the limitations of applicable law, we may: (i) reduce your Credit Limit; (ii~ terminate
your Account; (iii require immediate payment of your entire Account balance; (iv) terminate any
Special Payment ~lan and cornertany balance on such Plan to the standard terms and conditions of
the Account; (v) bong an action to collect all amounts owed; and/or (vi) take any action allowed by
law. If, after your default, we refer your Account for collection to an attorney who is not our salaried
employee, you uwll pay, to the extent permitted by applicable law, our collection costs, including court
costs and reasonable attorneys' fees.
14. LUUIILITY FOR UNAUTHORIZED USE. The Card is issued to you by us at your request and you
agree to destroy it upon demand. You may be liable for the unauthorized use of the Card. You agree to
promptty notify us if our Card is lost or stden or of possible unauthorized use of your Card by writ-
ing to P.O. Box 981401, EI Paso, TX 79998-1401 or by calling us at 1-800.444-1408. You will not be
liable tar unauthorized use that occurs after you notity us of the loss, theft, or possible unauthorized
use and, in any case, your liability for unauthori~d use will not exceed $50 (in NY, you will have no lia-
biliryryfor unauthorized use of the Cartl poor to the Effective Date). Ii you orally give us notice concem-
ingloss ar theft, you agree to confirm it in venting. You agree that unauthorized use does not include
use try a person to whom you have gNen authority to use the Account or Card and that you will be
liable for all use by such a person. To terminate that authonty, you must notify us at 1-800-444-1408.
1S. CREDR REPORTS AND ACCOUNT INFORMATION. You give us permission to request information
and to make whatever inquiries we consider necessary and appropriate (including obtaining informa-
tion from third parties and requesting consumer reports from consumer reporting agencies) for the
purpose of considering your application far this Account and subsequently, in connection with any
updates, renewals a extensions of creditor reviewing or collecting your Account. Vou also authorize
us to report information concerning you or your Account, including information about your perform-
anceunder this Agreement, to consumer reporting aggencies and others who may property receive such
information. II ya he8ere flat we bare reposed Iracerrote iribrmatlon abort nor to a corisiimer
repor8ng agenry, please crnhd ra al P.O. Box 981400, EI Paso, iX 79998-1400. la doing m,
please iderdiy the iraixrrob indormation and fell rs why yon believe it is incorrect. II yon bare a
copy of the credit repod that inclydes the Imcerrete Information, please Inclyde a co of That
s 6m Bed to a cor~u mertieiporllraJtagencytll yor MII b idflll the Inns I ibis Aug its ~rd maybe
16. USE OF INFORMATION ABOUT YOU AND YOUR ACCOUNT/CONSENT TO COMMUNICATIONS.
You authorize and direct us to furnish information about you and your Account to Lowe's Companies,
Inc. (and i~ affiliates) for use in connection with the Lowe's credit card program, including to create
and update their customer records, to assist them in better serving you, and to provde you with spe-
cial promotions. in addition, you agree to the use of information about you and your Account described
in the Privacy Policy. The Privacy Policy is a part of this Agreement and is enclosed or attached here-
to. You consent for us to contact you using all media, and for all purposes (including collection pur-
poses), using all contact intamatian you provide to us. You agree that we may use automated equip-
ment to dial your telephone number or to deliver messages to you. You may limit this consent based
on the optics we may provde to`you by calling customer sennce. Any charges for contacting you
which may be billed to you try your communications carrier are your responsibility.
17. TELEPHONE MONRORINfi. To ensure that yyou receive accurate and courteous customer serv-
ice, on occasion, your call may be monitored by our employees or agents and you agree to any
such monitoring.
18. JOINT ACCOUNTS. Ii this is a joint account, each of you will be jointly and indfvidualty responsi-
blefor your obligations under this Agreement; notice to one of you will be considered to be notice to
both of you; and we ran rely on instructions from one of you, even if we receive inconsistent instruc-
tions Irom the other person.
19. WAIVER. We may, in our sole discretion, choose to not exercise any right under this Agreement,
including the right to impose the Lull amount of airy charge, without waiving that right. A,rry waiver of
a right by us must be in writing and signed by us. Except as we may agree in a signed writing, we will
not wave arty rights if we (a accept a late a partial payment, (b~ accept a check or other payment
marked "payment in Lull" or tendered with other conditions or limitations, {c) extend the due date of
any pa . ent due under this Agreement, and/or (d) release any collateral or person responsible to
your obligations under this Agreement.
20. CHANGE OF ADDRESS. You will notify us promptly it ycu change your address. We may send
Statements and other notices to your address in our records until we have a reasonable opportunity
to update our records with arty new address for you.
21. ARBRRATN)N PROVISION. Please read this arbitration provision carefully. IT PROVIDES THAT
ANY PAST, PRESENT OR FUTURE LEGAL DISPUTE OR CLAIM OF ANY KIND, INCLUDING STAMO-
RYAND COMMON LAW CLAIMS AND CLAIM8 FOR EQURABLE RELIEF, THAT RELATES IN ANY WAY
TO YOUR ACCOUNT OR YOUR RELATIONSHIP WiTH US f"CLAIM" WILL BE RESOLVED BY BIND-
ING ARBITRATION IF EITHER YOU, WE OR LOWE'S ELEC73 TO AR~ITNATE.
Rigor b Re)eet Arbitration: Yor may re ect this arbtlreBa provision, in which stem mither yet
nor We will hate the dgbt to regrire a~ilretion. Rejection will not affect arty other aspect of these
terms. To reject the arbitration provision, you must send us a notice within sixty (60) days after you
open your account. The notice must include your name, address, and account number and be mailed
to P.O. Box 981429, EI Paso, TX 19998-1429. This is the only method you can use to reject the arbi-
tration provision.
As used in this provision: "We," "Us;' and "Our" means {i) GE Money Bank and all of its respec-
tive parents, subsidiaries, affiliates, predecessors, successors, assigns, employees, officers and
directors (collectively, the "Bank"}, and (2} Lowe's Companies, Inc. and all of its respective parents,
subsidiaries, affiliates, predecessors, successors, assigns, employees, officers and directors (collec-
tiveN, "Lowe's"), if Lowe's is named as a co-party with the Bank in a Claim asserted by you. .
TThis arbitration provision covers all Claims, except that We will not elect to arbitrate an individ-
ual Claim brought by you in small claims court or its equNalent, unless that Claim is transferred,
removed, or appealed tc a different court. This provision replaces any existing arbitration provision
between you and Us.
The following describes the arbitration procedure, and its implications:
• Notice: If you or We elect to arbitrate, the other parry must be notified. Your notice must be sent to
GE Money-Americas, Legal Operation, 777 Long Ridge Rcad, Stamford, CT 06927. Notice can be
given aster a lawsuit has been filed, in which case it can be made in papers in the lawsuit.
•Adminislretor. The person who starts the arbitration pproceeding must choose an administrator,
which can be either the National Arbitration Forum, P.O. Box 50191, Minneapolis, MN 55405,
o~ri, (800) 474-2371; or the American Arbitration Association, 335 Madison Avenue,
NewNew Y~0011, www•adr•ora, 600) 778-7879. The actual arbitrator will be selected under the
administrator's rules, and must be a lawyer vuith at least ten years of experience.
• AppBcable Law: These terms involve interstate commerce and this arbitration provision is governed
by the Federal Arbitration Act, 9 U.S.C. Section 1 et seq. (the "FAA"). Utah law shall apply to the
extent state law is relevant under Section 2 of the FAA in determining the validity of this provision.
The arbitrator has to follow: (1) the substantive law, consistent with the FAA, that would apply if the
matter had been brought in court, (2) this arbitration provision, and (3~ the administrator's rules.
The arbitrator is authorized to award remedies that would apply if the individual action were in a
court (including, without limitation, punitive lama es, which shall be governed by the constitution-
alstandards employed by the U.S. Supreme Court.
• LocalbrlFees: The arbitration will take place in a location reasonably convenient to you. Ii you ask
us, vve will pay all filing, administrative, hearing and/or other fees the administrator a arbitrator
charges up to $2,500. If the cost is higher, you can ask us to pay more and we will consider your
request in good faith. Under all circumstances, we will pay all amounts vce are required to pay under
applicable law.
• JodgmenUAppeals: A court may enter jud merit upon the arbitrator's award. The arbitrator's deci-
sion will be final and binding except for: (1t any appeal right under the FAA; and (2) any parry may
appeal decisions relating to Claims of more than $100,000 to athree-arbitrator panel appointed by
the administrator, which will reconsider all over again any aspect of the appealed award. If you
appeal, We will consider in good faith a request chat We pay any additional fees of the administra-
tor or arbitrator.
IMPORTANT LIMITATIONS AND RESTRICTIO(NS: IF A CLAIM fi0E3 TO ARBITRATION, NEITHER
(PY(2) EN6A EEN DIS OVERY (NIfEIOTHE RIGI~HTOEOBTAINRNFORMATIO((N11FROM HE OTHIE
CLARSS)ACTIONEIN(CDURT OR IN ARBRRAT ON, E THER ASIA CIASS AESPRE ENTAiTYE OR A
OR ((b)) OIN OR CONSI LIDATE TOUR Cllt MS'S) WITH CLAIMS OF ANY OTHER PERSONTITHE
RIfiHi TO APPEAL IS MORE LIMITED IN ARBITRATION THAN IN COURT. OTHER RIBHTS THAT
YOU WOULD HAVE IF YOU WENT TO COURT MAY ALSO NOT BE AVAILABLE IN ARBTRATION.
ONLY A COURT MAY DETERMINE THE VALIDITY AND EFFECT OF PARTS S, 4 AND 5 OF THIS
PARAGRAPH. IF A COURT SHOULD HOLD SUCH PART(S1 TO BE INVALID, THEN THE ENTIRE
PROVISION SHALL BE NULL AND VOID. HOWEVER, THIS WILL NOT LIMIT THE RIGHT TO
APPEAL SUCH HOLDINfi. IF A COURT SHOULD HOLD ANY OTHER PART(S) OF THIS ARBITRA-
TION PROVISION TO BE INVALID, THE REMAININfi PARTS SHALL BE ENFORCEABLE.
This arbitration provision will survive the termination of your account and will remain in force no
matter what happens to you.or your account. If the administrator's rules conflict with the rules
described in this provision, this provision will appy.
22. 60YERNINfi LAW. Tdis Agreement and you Accoral and any claim, dlsprte or conlror~ny
arising from or relating to this Agreement or yorr Accost, whether based or comrect, tort, irerd
and other intentional toils, alatrte, common law and/or errriry, are governed by and comlreed in
aowMance wllh federal law, aed to the extent Ihat slaty law appNes, the lava of the Slate of Ubb
(witlrort regard to imerml pdnciplns of conllids of taw). The legality, nniorrssMliry and irderyro-
tation of Ibis agreerrrenl arM the amornn comrected for, charged and received ruder this
Agreemem will be reined by arch laws. Tina Agreemem is entered irrb behreen yor and ra In
Utah. We mate decisions abort granting aedil b yorr Irom, exend credit to yin ruder this agree-
ment Irom, aril axept yorr paymems it Uqh. '
23. ASSIfitA613tT. We may sell, assign or transfer arty of our rights,or obligations under this
Agreement or your Account, including our rights to payments, without prior none to you. You may
not sell, assign or transfer any of your rights or obligations under this Agreement ar your Account.
24. SEYERABILITY. If arty provision of this Agreement is determined to be void a unenforceable
under applicable law, all other provisions of this Agreement shall still be valid and enforceable.
25. ENTIRE A9REEMENT. This Agreement, together with any application you signed or other-
wise submitted in connection with the Account (which is hereby incorporated by reference in
this Agreement), constitutes the entire agreement between you and us relating to your Account
and supersedes any other prior or contemporaneous agreement between you and us relating to
your Account. This Agreement may not be amended except in accordance with the provisions
of this Agreement.
STATE NOTICE
NEW JERSEY RESIDENTS: Because certain provisions of this Agreement are subject to applicable
laws, they may be void, uneniaceable ar inapplicable in some jurisdictions. None of these provisions,
however, is vcid, unenforceable or inapplicable in New Jersey.
WISCONSIN RESIDENTS: No provision of a marital property agregiment, a unilateral statement under
sec. 766.59, Wis. Saats., or a court decree under sec 766.70, Wis. Stats., adversely affects the inter-
est of the credits unless the creditor prior to the time credit is granted, is furnished a copy of the
agreement, statement or decree or has actual knowledge of the adverse provision when the obli~a-
ticn to the creditor is incurred. ReaideNa of Whcarsin apprylrg for an individral accord mrsl give
as the mine and address of Ihelr apace, regardless of whether lire spores maq ores the card.
Please provide Ihls latormador to rs al P.O. Box 961478, EI Paso, TX 79993-1478.
Yorr sigratrre on the applialior or sales slip for the iri8al prrchaae approved a this Aaornt
represems yorr algnatrre a This Agreemem and Is irrwrponted by refererrce.
~~~~
Margaret Keane
Executive Vice President
GE Money Bank
Notice: The following is important informatics regarding your right to dispute billing errors.
YOUR BILLING RIGHTS
KEEP THIS NOTICE FOR FUTURE USE
This notice contains important information aboutyour rights and our responsibilities under the Fair
Credit Billing Act.
Noliry Us in Case of Ertots or Orealions Abort Yorr Bill
If you think your bill is wrong, or if you need more informaton about a transaction on your bill, write
us on a separate sheet at the address shown on your Statement under billing inquiries. Write to us
as soon as possible. We must hear Irom you no later than 60 days after we sent you the first bill on
which the error or problem appeared. You can telephone us, but doing so will not preserve your
rights.
In your letter, give us the following information:
• Your name and Account number
• The dollar amount of the suspected error.
• Describe the error and explain, if you can, why you believe there is an error.
It you need more information, describe the item you are not sure about.
Your Right and Orr ResponslblNtiea After We Receive Yerr WrBten Notice
We must acknowledge your fetter wnthin 30 days, unless we have corrected the error by then. Within
90 days we must either correct the error or explain why we believe the bill was correct.
Alter we receive your letter, we cannot try to collect any amount you question, or report you as
delinquent. We can continue to bill you for the amount you question, including finance charges, and
we can apply any unpaid amount against your credit limit. You do not have to pay airy questioned
amount while we are investigating, but you are still obligated to pay the parts of ycur bill That are not
in question.
If we find that we made a mistake on your bill, you will not have to pay any finance charges relat-
ed toany questioned amount. If we didn't make a mistake, you may have to pay finance charges, and
you will have io make up arty missed payments on the questioned amount. In either case, we vnll send
you a statement of the amount ycu owe and the date that it is due.
If you fail to pa the amount that we think you owe, we may report you as delinquent. However,
if our expianabon does not satisfy you and you write to us within ten days telling us that you still
refuse to pay, we must tell anyone we report you to that yyou have a question about your bill. And, we
must tell you the name of anyone we reported you to. We must tell anyone we report you to that the
matter has been sealed between us when it finally is.
Ii we don't follow these rules, we can't collect the first $50 of the questioned amount, even if your
bill was correct.
Special Rile for Credit Card Purchaaea
It you have a problem with the quality of property or services that you purchased with a credit card,
and you have vied in good faith to correct the problem with the merchant, you may have the right not
to pay the remaining amount due an the property or serwces. There are two limitations on this rf!)ht:
(a) You must have made the purchase in your home state or, if not within your home state, with-
in 100 miles of your current mailirp address; and
(b) The purchase price must have been more than $50.
these limitations do not appy if we own or operate the merchant, or if we mailed you the adver-
tisementfar the property or services.
PRIVACY POLICY
This Privary Policy describes our information collection and sharing practrCes Please read it careful-
Iy. The Policy applies onty to current and farmer customers and applicants in then relatioFlShips with
usrelating to consumer lowe's CredifCard Accounts of GE Money Bank (;`we a 'us'').
Irriornratlon We Collect - We collect personally,idenbhable'information about you (surh as your
address, phone. bomber; social security number, mother's maiden name and transaction mforma4on
abeut items pgrchased; paymenisandpaymentmethod), forident[f[cahon; accountmabagement,
servicing and marketing purposes. We obtaih information about you tluecdy Trom you (such as on
application forms), throughyouruse of our productsandsernces;and in somecases, from third par
ties (such as credrt bureaus and demooggraphic firms): Oceaslonakry we may also collect information
about you onljne using "cookies`. (smallpieces of data stored by your lotemet browser onyour cam-
pater) or othertechnology that may lac. used to remember passwords far you, to track your websrte
Usage wrth us; and to provide you wfth customized conteht, among other things.
IMormallonlNei3harowitft'Others--We may use and sfiareall of theintormahon we collect; sutr
jectto applicable law; with the follovripg (these ezampfes are not intended tti be elk-inclusive)
• Lowe's Companies, inc. and its atllllales, for use: in connection with theocnsumer t.owe s Credit
Card program and as ottiervnse permitted by law, iftey may!use this information to update then
records, to provide you with notices of special. prompt{ons arid other taitnred offerings, to answer"
questions about your Accpunt and perform. other low~e's Credit Card program functions or for other
purposes permitted by law: They may use thekr affiliates, licensees oc third-patty service providers
(such as modelmgantl tlatebase companies)TO assistthem jh any of theseactivrhes
• Serrlce Prodders, (mclutljng our affiliates) to assist us m servicing Accounts Irke preparing billing
statements arid promotional matenalst and respondrng to customer mquir~es, We also may use-
markedhg firms such as modeling Compapies, to assist us ih our awn marketing efforts:
• Fjnanclal Ipstilullons uilth Whom We Jolmry Oder Flasncial Products, such as loan. products or
cietlitinsorance. kfyaurbilhng address in Vemtont, this ihfcrmatlon will be Hmited to your name.
and contactiritormatiob; and transaction and experience mtormahon ohyour Account:
• Oar AlBltales; who are .other r~mpanles In the 6enenC$lecidc Corwprry cordorale tamllY
(AGE Farelly"}, tar servicing or marketing purposes subject to vow right to opt out of sharing
oicredit elrgfpilitymformation, such as certa[n reformation Ttom credit bpreaus and your appl[-
cation as provided in the !Ys Your Cfioice section below. And subject toyour r~gnt o opt out; "
oar affiliates also may tfse tnformaboh from usCgncernmg your credit eligibility andyour trans-
`:actions and experience with us, to sertl you markefing olicitationsabautproductsarrd services-
•Third Parlles, who sre Interested n otlering Spector products or services to you, subject to your '
right to optout as provided m the ICs Your Choice section. fnr example;we disclosebntormation;
'either directly. or through lowe'sGompanres, Inc. andits aftillafes, [afinabcial services. providers
offering productssuch as insurance; mortgages or loans,and nonhnanciakcompaoles ottenngcon-
:.Sumer products and services VJe may disclose name address and teleprione numoe[s, as well as
AccounCpurchaseond performance history
• Others; We report Accounnntorrriation; such as creddlimit„baiances and payment reformation, to
credit bureaus: Id addition, we mayouyand Self assets; linesoi~pusiness antllor Accdun~ When
this occurs; customer information generally is disclosed tobidders antlisoneofthe ttansferretl
pusmess assets. We also disclose informaton about you to mird parties in certain other cncum-
stances,aspermittedbylaw
(hr SeaAty Procedures-We maintain physical, eiecironin; and procedural safeguards thatcom-
ply with federal standards to guard nonpublic personal information aboutyou. We limifaccess to per-
spool and Account iMormation to those employees and agents who assist us in providing products
and services to you. We also require third parties to whom we disclose nonpublic personal informa-
honto adhere to this Pnvacy Policy and to estahlisb information security procedures.
Your Access to Ildora[atloo-- We provide you access tq mformaGori about yourAccountby send-
ingyoumonthrybiAingstatetnents outlining your transactions; iinanCe Charges; and other-Account
intormation,and by providingcustomet service representatkvestbansweryour questions
tioW This Poiky Applies to Yorr -The examples contained in this Privacy Policy are illustrations
only,andarenotinthndedtobeagmclusive,lfyoudecide ockoseyourAcnouniorbe~omeaninac-
tivesustomer ortf we close or suspend your Account, vro vnll continue to adhere to the privacy pWi-
cres and practices described in this notice To the extent`we retain information about you. We may
amend this Prroany Pbhcy at any: time arid we wrll mformyou of changes as required try law You may
have other prNacyprntecUOnsonder state laws and we will comply with applicable state laws when
we tlisglose information aboutyou_Thrg Prlv'acy Policy apples oplp to consumer Lowe s CreditCard
Accounts of GE Money Batik and does not apply to arty other accounts you may have with us; and
LOWE'S
[0415L]
C822 (8/07) 7031-SCHUMER-T&C-I-REV 6/08
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
~~~~titp oC 4"u~t~lrrrl~,~~
t'i . J:~: x
;~~.
t~~F cE ,,;~ -N~ ~,.~a~~F
~'I ~~J i'...._ '4.
LQiu Jlr' _~ ~'~'~ ~~ ~~
Gl..'i^/.~ _ .'IJIV~t
F ~~~ ~ , ~''~~it=.
Cavalry Portfolio Services, LLC
vs.
William E Barrick, Jr
Case Number
2010-3843
SHERIFF'S RETURN OF SERVICE
07/07/2010 08:25 PM -Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on July
7, 2010 at 2025 hours, she served a true copy of the within Complaint and Notice, upon the within named
defendant, to wit: William E. Barrick Jr., by making known unto himself personally, at 116 Salem Church
Road, Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time
handing to him personally the said true and correct copy of the same.
SHERIFF COST: $37.00
July 08, 2010
A A COBAUGH, DEP
SO ANSWERS,
RON R ANDERSON, SHERIFF
;c} CountySuito Shenff. Teleosoft. Inr,.
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CAVALRY PORTFOLIO SERVICES, LLC, AS
ASSIGNEE OF CAVALRY SPV I, LLC, AS
ASSIGNEE OF GE MONEY BANK
Plaintiff
V.
WILLIAM BARRICK JR
Defendant(s)
PRAECIPE FOR JUDGMENT
-7n
CIO
r
? -c
TO: PROTHONOTARY- CIVIL DIVISION:
Enter Judgment against above-named defendant William Barrick Jr, , for failing to file an answer.
Prothonotary to assess damages as follows:
Debt $9,848.44
Costs to be added
Attorney's Fees $.00
Interest from 5/18/2010 @ 1OWaived
Total Amount $9,848.44
Pursuant to Pa. R.C.P. 237. 1, I hereby certify that notice of intention to file this Praecipe was mailed to
the above-named Defendant on August 24, 2010, and a copy of same is attached herewith.
Allentown, Pennsylvania:
Date: 8/24/2010
THOMAS LAW OFFICES, PLLC
By: ?a
Douglas M. arinos, Esquire
Atty. I.D. #53104
Attorney for Plaintiff
101 North Cedar Crest Blvd
Allentown, PA 18104
(866) 434-2993
• CIVIL ACTION
CASE NO.: 2010-3843
0
L7
41q-6v
ate 7;'31v
aV81?
-?r_L ?w kf
13829247
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CAVALRY PORTFOLIO SERVICES, LLC, AS
ASSIGNEE OF CAVALRY SPV I, LLC, AS
ASSIGNEE OF GE MONEY BANK CIVIL ACTION
Plaintiff
V.
WILLIAM BARRICK JR
Defendant(s)
TO: WILLIAM BARRICK JR
116 SALEM CHURCH RD
MECHANICSBURG, PA 170502834
DATE OF NOTICE: August 24, 2010
: CASE NO.: 2010-3843
TEN DAY NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN
THIS CASE. 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 NOTICE TO A LAWYER AT ONCE. IF YOU
DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING
OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSN
32 S BEDFORD ST
CARLISLE, PA 17013
(717) 249-3166
Thomas Law Offices, PLLC
By:
s-161p-
Dougl . Marinos, Esquire
Atty. I.D. #53104
Attorney for Plaintiff
101 North Cedar Crest Blvd
Allentown, PA 18104
(866) 434-2993
13829247
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CAVALRY PORTFOLIO SERVICES, LLC, AS
ASSIGNEE OF CAVALRY SPV I, LLC, AS
ASSIGNEE OF GE MONEY BANK ; CIVIL ACTION
Plaintiff
V.
WILLIAM BARRICK JR
Defendant(s)
CASE NO.: 2010-3843
TEN DAY NOTICE
TO: WILLIAM BARRICK JR
116 SALEM CHURCH RD
MECHANICSBURG, PA 170502834
DATE OF NOTICE:
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN
THIS CASE. 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 NOTICE TO A LAWYER AT ONCE. IF YOU
DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING
OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSN
32 S BEDFORD ST
CARLISLE, PA 17013
(717) 249-3166
Thomas Law Offices, PLLC
By:
Douglas . Marinos, Esquire
Atty. I.D. #53104
Attorney for Plaintiff
101 North Cedar Crest Blvd
Allentown, PA 18104
(866) 434-2993
13829247
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CAVALRY PORTFOLIO SERVICES, LLC, AS
ASSIGNEE OF CAVALRY SPV I, LLC, AS
ASSIGNEE OF GE MONEY BANK
Plaintiff
v
WILLIAM BARRICK JR
Defendant(s)
• CIVIL ACTION
• CASE NO.: 2010-3843
AFFIDAVIT OF NON-MILITARY SERVICE
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF LEHIGH
: SS
I, Douglas M. Marinos, Esquire, being duly sworn according to law, deposes and says that he is attorney
for Plaintiff and to the best of his knowledge, William Barrick Jr, the above-named Defendant(s) is/are not in
the Military Service or in any branch of the armed forces of the United States or its allies, nor otherwise within
the provisions of the Soldiers and Sailors Civil Relief Act of Congress of 1940 and its Amendments; that
Defendant(s) reside(s) at 116 SALEM CHURCH RD, MECHANICSBURG, PA 170502834 and that said
Defendant(s) is/are over twenty-one years of age.
Dougl . Marinos, Esquire
Sworn to and subs bed
before me this 3d day
0
of t ,20
N
Public
CO1bE?IONWEALFfi OF PEWSYLVAMA
NOTARIAL SEAL
Elizabeth A. Gschrey, Notary Public
South Whitehall Township, Lehigh County
My commission expires September 11, 2012
13829247
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CAVALRY PORTFOLIO SERVICES, LLC, AS
ASSIGNEE OF CAVALRY SPV I, LLC, AS
ASSIGNEE OF GE MONEY BANK CIVIL ACTION
Plaintiff
. CASE NO.: 2010-3843
v
WILLIAM BARRICK JR
Defendant(s)
CERTIFICATION OF ADDRESS
TO THE PROTHONOTARY:
I, Douglas M Marinos, Esquire, certify that to the best of my knowledge, the correct address of the
Defendants is:
116 SALEM CHURCH RD
MECHANICSBURG, PA 170502834
And the address of the Plaintiff is:
Cavalry Portfolio Services, Llc, As Assignee Of Cavalry Spv I, Llc, As Assignee Of Ge Money Bank
7 Skyline Drive
Hawthorne, NY 10532
Thomas Law Offices, PLLC
??y
BY: eo
Douglas M. arinos, Esquire
Attorney I.D. # 53104
Attorney for Plaintiff
101 North Cedar Crest Blvd
Allentown, PA 18104
(866) 434-2993
13829247
REQUEST FOR JUDGMENT
CAVALRY PORTFOLIO SERVICES,
LLC, AS ASSIGNEE OF CAVALRY
SPV I, LLC, AS ASSIGNEE OF GE
MONEY BANK, Plaintiff
VS.
WILLIAM BARRICK JR, Defendant
No. 2010-3843
Enter Judgment in favor of plaintiff CAVALRY PORTFOLIO SERVICES, LLC, AS ASSIGNEE OF
CAVALRY SPV I, LLC, AS ASSIGNEE OF GE MONEY BANK and against WILLIAM BARRICK
JR for the sum of $9,848.44, plus costs of suit, for failure to file/want of an appearance as provided
by the rules of court, and Act of Assembly in such case made and provided.
TO THE PROTHONOTARY OF CUMBERLAND COUNTY.
IN THE COURT OF COMMON PLEAS
CIVIL ACTION LAW
OF CUMBERLAND COUNTY
Attorney for Plaintiff
August 24, 2010
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CAVALRY PORTFOLIO SERVICES, LLC, AS
ASSIGNEE OF CAVALRY SPV I, LLC, AS
ASSIGNEE OF GE MONEY BANK
Plaintiff
V.
WILLIAM BARRICK JR
Defendant(s)
• CIVIL ACTION
CASE NO.: 2010-3843
( X ) Notice is hereby given that a Judgment in the above-captioned matter has been entered against
you in the amount of $9,848.44
on
( X ) A copy of all documents filed with the Prothonotary in support of the within judgment is/are
enclosed.
by:
If you have any questions regarding this Notice, please contact the filing party:
Douglas M. Marinos, Esquire
Thomas Law Offices, PLLC
101 North Cedar Crest Blvd
Allentown, PA 18104
(866) 434-2993
(This Notice is given in accordance with P.R.C.P. 236)
13829247