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THIS IS AN
ASSESSMENT
Goldman & Warshaw, P.C.
BY: Barry A. Rosen, Esquire
PA Identification No: 42951
GOLDMAN & WARSHAW, P.C.
312 W. Broad Street
Quakertown, PA 18951
267-373-9730
Counsel for Plaintiff
H0100908
ARBITRATION MATTER.
OF DAMAGES HEARING
REP iAgb.
E -
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. : It) - 5139
CiviITerm
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
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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
5122571009687213 in the amount of $2,094.41 including pre-charge
off interest through January 30, 2009; as of May 3, 2010 there
remains a balance due in the amount of $2,094.41.
7. Plaintiff has made demand upon the defendant(s)for payment
of the balance due of $2,094.41 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 9,
2008.
WHEREFORE, plaintiff claims of the defendant the sum of
$2,094.41 plus applicable court costs and interest.
Goldman & Warshaw, P.C.
BY: /Z, I /?,
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
H0100908
CHASE BANK USA, N.A.
3700 Wiseman Blvd
San Antonio, TX 78251
VERIFICATION
I, Rukn $L B?arrrz hereby state that I am the
Alsstfta*Treaaw
of Plaintiff heroin; 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 unswom falsification to authorities.
By:
Print Name: Ru6en A ?w
Title: filhisdam rhr uami
H0100908
CHASE BANK USA, N.A.
3700 Wiseman Blvd
San Antonio, TX 78251
WENDY T SHEAFFER
5122571009687213
AFFIDAVIT
I, Ren A. A(MW being duly sworn according to law, depose and say that:
1.I 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 5122571009687213 in the amount of $2,094.41 plus costs.
6.If called upon, aillant 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 Fbm A A lru
before me this I day
of -'411 X01 D
Notary blic
!...,
rio DORTHIA DLExpires
I Notery Public, St?v?,`, Mvcommissio it, Novembei 1
David D. Buell
Prothonotary
Office of the (Prothonotary
Cum6erCancf County, PennsyCvania
xirkS. Sofionage, o:SQ
SoCicitor
w —_513 9 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 • Suite100 0 CarfisCe, (PA • (Phone 717 240-6195 • Ea.,717 240-6573