The URL can be used to link to this page

Home My WebLink About10-50682083155 THIS IS AN ARBITRATION MATTER. ASSESSNZNT flF DAMAGES HEARING REQUIRED. n k GORDON & WEINBERG, P.C. -' BY: FREDERIC I. WEINBERG, ESQUIRE , Identification No.: 41360 JOEL M. FLINK, ESQUIRE _..W Identification No.: 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 n ..w 484/351-0500 b CHASE BANK USA, N.A. 200 White Clay Center Drive, Newark, DE 19711 VS. RICHARD R HENSEL 191 SALEM CHURCH RD MECHANICSBURG PA 17050-2835 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 10 - So(08 atV t t Tem 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 0 jga.0o P b A71-{ c-1 maoa6 Q?k ail 10 19 / 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 June 9, 2010 in the amount of $13,806.75. 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 6/4/09. WHEREFORE, plaintiff claims of the defendant(s) the sum of $13,806.75 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDERIC I. W INB G, ESQUIRE JOEL M. FLIN QUIRE Attorney for ,aintiff P01A 2083155 10038919 Chase Bankcard Services, Inc., a subsidiary of Chase Bank USA, N.A. RICHARD R HENSEL 5417126798585138 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. L NAME 2285 2083155 10038919 Chase Bankcard Services, Inc., a subsidiary of Chase Bank USA, N.A. RICHARD R HENSEL 5417126798585138 AFFIDAVIT JZV?on. A. A. I, to law, depose and say that: , being duly served sworn according 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 $13,806.75 plus interest of $.00 at the rate of 0% less credits in the amount of $.00 totaling $13,806.75 as of May 13, 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 to (or affirmed) before me this day of 2010 by Ruben?1. Proved to me on the basis of s tisfactory evidence to be the persons o appe re b fore me. Signature (Seal) OF- d- DORTHIA DEMBO P100.1 Notary Public, State of Texas My commission Expires November 13, 2011 _I I SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ~ ~ . -- ~s~tiitr cC ~u~a6nr,~ ~,~ ~-~ - Jody S Smith '~~` Chief Deputy ~ ~,~ '~ ,~~rt ...:~;,~~,,, Z~'~~ AUK, 13 PM ,Zi 1Z Richard W Stewart ~- - Solicitor c,~~,cE ~?~= s~-s(~r , ~: ~ r , Chase Bank USA, N.A. vs. Case Number Richard R. Hensel 2010-5068 SHERIFF'S RETURN OF SERVICE 08/11/2010 10:54 AM -William Cline, Corporal, who being duly sworn according to law, states that on August 11, 2010 at 1054 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Richard R. Hensel, by making known unto himself personally, at 191 Salem Church Road, Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time handing to him personally the said true and correct copy of the same. ILLIAM CLINE, DEPUTY SHERIFF COST: $37.00 August 12, 2010 SO ANSWERS, .~ c~~--~ RON R ANDERSON, SHERIFF (c} CountySuite Sheriff. Teloosoft Inc. 1 s T ~~- ~_ ~_ 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 4841351-0500 F^t ~^^ F 4aY' ~~ Y, t ~ ~ Rr ~~~~ via _~ ~6~ ~~~ ~~ ~~E~u~ ~ r44~,~ ~ ~ CHASE BANK USA, N.A. vs. RICHARD R HENSEL COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET N0. 10-5068 PRAECIBE FOR ENTRY OF JVDGN~TT FOR ~iANT OF AN AN89PER, ASSE33l~NT OF DA~~AGE3 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 $13,806.75 Less: Payments on Account ( $.00) Total: $13,806.75 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: CHASE BANK USA, N.A. and that the last known address of defendant, RICHARD R HENSEL, 191 SALEM CHURCH RD, MECHANICSBURG PA 17050-2835. 2. The annexed notice(s) of intention to file this praecipe was (were) mailed to all parties, defendant and record attorneys, if any, after default occurred, and at ten days prior to the date of filing of this praecipe. 3. The said defendant(s) is (are) service of the United States or otherwise the Soldiers and Sailors Civil Relief Act years of age. to their least not in the military within the coverage and is (are) over 18 ~*13a~3 2'~a49~s7 of . ~lofieslUa~Qac AND NOW, this ~_ day of L.C'a 2010 Judgment is entered in favor of the plaintiff(s) and against defendant(s) by default for want of an answer and damages assessed at the sum of , $13,806.75 as per the aby~ve certif~~ion. .-. ~thonotary D~gVSD 'D . ~L LI,FE lr GORDON & WEI BE P.C. BY: FREDER'XC~ : WEINBERG, ESQUIRE JOEL M. FLINK, ESQUIRE Attorney for Plaintiff 2083155 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. vs. RICHARD R HENSEL 191 SALEM CHURCH RD MECHANICSBURG PA 17050-2835 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET N0. 10-5068 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. fR1 Judgment by Default $13,806.75 f~ Money Judgment $ ~ Judgment on Allard of Arbitrators$ ~ Judgment on Verdict$ IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, ATTORNEYS: FREDERIC I. WEINBERG OR JOEL M. FLINK, TELEPHONE NUMBER: 484/351-^~^^ PLEASE CALL ESQUIRES AT THIS 10~3/lO 2083155 GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FUNK, ESQUIRE Identification No.: 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 989/351-0500 CHASE BANK USA, N.A. COURT OF COMMON PLEAS CUMBERLAND COUNTY RICHARD R HENSEL TO/PARA vs. DOCKET N0. 10-5068 NOTICE OF INTENTION TO TAIO; DEFAULT RICHARD R HENSEL 191 SALEM CHURCH RD MECHANICSBURG PA 17050-2835 DATE OF NOTICE/F'ECHA DEL AVISO: September 1, 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 5. BEDFORD STREET CARLISLE, PA 17013 (717) 299-3166 GORDON & WEINBERG, P.C. BY: FREDERIC I W ERG, ESQUIRE JOEL M. FUNK, ESQUIRE PLOD-2