HomeMy WebLinkAbout10-51381 ` r
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H0100907
THIS IS AN ARBITRATION MATTER.
ASSESSMENT OF DAMAGES HEARING REQUIRED.
Goldman & Warshaw, P.C.
BY: Barry A. Rosen, Esquire
PA Identification No: 42951" Q
GOLDMAN & WARSHAW, P.C.
312 W. Broad Street
Quakertown, PA 18951
267-373-9730 ?.
Counsel for Plaintiff W
CHASE BANK USA, N.A.
3700 WISEMAN BLVD.
SAN ANTONIO, TX 78251
Vs.
WENDY T SHEAFFER
815 FACTORY ST
CARLISLE PA 17013-1352
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
DOCKET NO. : lO - 51Z6
NOTICE
0,\,;(--&.
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
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COMPLAINT IN CIVIL-ACTION
1. Plaintiff, CHASE BANK USA, N.A. , is a federally chartered bank
with a business address as stated in the caption above.
2. Defendant WENDY T SHEAFFER is an adult individual residing at
the above captioned address.
3. 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.
4. 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.
5. The defendant (s) received and accepted goods and merchand-
ise and/or accepted services and/or cash advances through the use
of the credit card issued by the Plaintiff. A true and correct
copy of Plaintiff's Affidavit is attached hereto as Exhibit "A".
6. After allowing for all offsets and credits, a balance as of
May 3, 2010 remains on the subject account having account number
4266841180464347 in the amount of $2,249.25 including pre-charge
off interest through January 30, 2009; as of May 3, 2010 there
remains a balance due in the amount of $2,249.25.
7. Plaintiff has made demand upon the defendant(s)for payment
of the balance due of $2,249.25 but the defendant(s)has failed and
. refused and still refuses to pay the same or any part thereof.
8. Defendant's last payment on account was made on June 15,
2008.
WHEREFORE, plaintiff claims of the defendant the sum of
$2,249.25 plus applicable court costs and interest.
Goldman & Warshaw, P.C.
BY:
Barry A. Ros Esquire
Attorney for Plaintiff
THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR
THAT PURPOSE THIS COMMUNICATION IS FROM A DEBT COLLECTOR
PACARD
I f
CHASE BANK USA, N.A.
3700 Wiseman Blvd
San Antonio, TX 78231
H0100907
VERIFICATION
I, hereby state that I am the
AAdda"tTmaaovr of Plaintiff herein; that I am authorized to make
this verification on behalf of Plaintiff in the foregoing action; that I have personal knowledge of the
statements made in the foregoing Complaint; and that the statements made in Plaintiffs Complaint are
true and correct to the best of my knowledge, information and belief.
I understand that the statements in this verification are made subject to the penalties of 18
Pa.C.S. §4904 relating to unsworn falsification to authorities.
By:
Print Name: fujm A. AG,atw --
Title: XL ,Irraat my
'
CHASE BANK USA, N.A. H0100907
3700 Wiseman Blvd
San Antonio, TX 78251
WENDY T SHEAFFER
4266841180464347
AFFIDAVIT
being duly sworn according to law, depose and say that:
1.1 am the agent for the Plaintiff herein and I am familiar with the files relating to this account;
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.After allowing for all offsets and credits, a balance as of December 16, 2009 remains on the subject
account having account number 4266841180464347 in the amount of $2,249.25 plus costs.
6.1f 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.
Sworn to and Subscribed
before me this J day
of l? 1q?
Notary Public
r DORTHIA DEMIO
Notary Pi,blic, state of Tex-
MY commission Expires
'Y? I.? `r November 13.2011
David cD. BuelT
Prothonotary
Office of the prothonotary
Cum 6erfancfCounty, cPennsyfvania
rkS. Sohonage, ESQ
Solicitor
In -S138 CIVIL TERM
ORDER OF TERMINATION OF COURT CASES
AND NOW THIS 28TH DAY OF OCTOBER, 2014, 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 0 Suite100 0 CarCsfe, P) 0 (Phone 717 240-6195 0 'Fax 717 240-6573