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Home My WebLink About01-1463DESSEN, MOSES & SHEINOFF BY: David S. Dessen, Esquire IDENTIFICATION NO. 17627 1814 CHESTNUT STREET PHILADELPHIA, PA 19103 (215) 564-5600 AMERICAN EXPRESS COMPANY World Financial Center New York, PA 10285 Vo PATRICIA A. WOLL 750 Allenview Drive Mechanicsburg, PA 17055 ATTORNEY FOR Plaintiff CUMBERLAND COUNTY COURTOFCOMA'IONPLKA~ CIVIL DIVISION TERM, CIVIL ACTION - COMPLAINT NOTICE You have been sued in court. If you wist~ to defend against the claims set f(3rth in the following pages, you must take ac. t ion within twenty (20) days after this complaint and no rice are served, by entering a written appearance personally or by attorney and filing in wdtlng 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 judgment may be entered against you by the court without further notice for any money claimed in the comolaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights im- portant to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AF- FORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. AVISO Lawyer Referral Service Cumberland County Bar Association Two Liberty Avenue Carlisle, PA 17013 Phone: 717-249-3166 DESSEN, MOSES& SHEINOFF BY: David S. Dessen, Esquire Attorney I.D. No. 17627 1814 Chestnut Street Philadelphia, PA 19103 (215) 496-2910 American Express Company World Financial Center New York, NY, 102854411, Plaintiff VS. Patricia A Woll 750 Allenview Drive Mechanicsburg PA 17055, Defendant NO. Attorney for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL DIVISION CIVIL ACTION - COMPLAINT 1. Plaintiff, American Express Company, is a corporation licensed to do business under the laws of the Commonwealth of Permsylvania, with a principle place of business located at World Financial Center New York, NY, 10285. 2. Defendant, Patricia A Woll, is an adult individual who resides at 750 Allenview Drive, Mechanicsburg PA 17055. 3. Plaintiff extended credit to Defendant under Account No. 3713-871727-11006, pursuant to the terms of the contract attached hereto as Exhibit "A". Plaintiffperformed all its obligation in extending said credit. Presently, there is due and owing from the Defendant to the Plaintiff the sum of 5. $10,066.19. 6. Plaintiff avers that pursuant to Plaintiffs contract with Defendant, Plaintiffs attomeys are to receive attorney's fees of 15% of the debt due, which is $1,509.93. 7. Although demand for payment has been frequently made by Plaintiff, Defendant refuses and continues to refuse to pay same. WHEREFORE, Plaintiff demands judgment against Defendant in the principal amount of $11,576.12, with additional interest from February 13,2001 and costs of suit, Respectfully submitted, DESSEN, MOSES & SHEINOFF David S. Dessen, Esquire Attorney for Plaintiff DATED: VERIFICATION I, David S. Dessen, Esquire, attorney for the Plaintiff, am authorized to take this Affidavit and hereby verify that the facts set forth in the foregoing Civil Action - Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements made herein are made subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to unsworn falsifications to authorities. David S. Dessen, Esquire Attorney for Plaintiff C NOTE £OR OHIO 30 o~.Iro,n t~ datt o[ ray~. ' LMPO RTANT ADD ITIOIRM. h~O~ON FOK YOU l~.~'t~ J. Clak, President llmo~ P~ ,~ 1-97 2/~8 8 ~ DAMAG~ INSULi. lqCI! ~ ~d ~e ~8.~ ~ee ~ $l~O~gO ~ $~0,~0 C SHERIFF'S RETURN - REGULAR CASE NO: 2001-01463 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND AMERICAN EXPRESS COMPANY VS WOLL PATRICIA A CPL. TIMOTHY REITZ , Cumberland County, Pennsylvania, who being duly says, the within COMPLAINT & NOTICE was WOLL PATRICIA A DEFENDANT , at 0014:35 at 750 ALLENVIEW DRIVE MECHANICSBURG, PA 170S5 PATRICIA A. WOLL a true and attested copy of Sheriff or Deputy Sheriff of sworn according to law, served upon the HOURS, on the 21st day of March , 2001 by handing to COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 7.44 Affidavit .00 Surcharge 10.00 .00 35.44 Sworn and Subscribed to before me this -~ ~ day of ~ ~r~[ A.D. So Answers: R. Thomas Kline 03/22/2001 DESSEN, MOSES & SHEINOFF By: