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Home My WebLink About10-73752088276 • THIS IS AN ARBITRATION MATTER. DAMAGES HEARING REQUIRED. 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 ASSESSMENT OF GE MONEY BANK 4125 Windward Plaza Drive Alpharetta GA 30005 vs. James Callahan 709 Belvedere St Carlisle PA 17013 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET N0. :'~ -1 3~S c ~ -03 ~o ~, .y +~ ~ C ~! ~~ N ~o c7 0 -s ~V A -t v ~ -C 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 ~p a~ ~q~~ ,~~, ~~~~ ~~~ ~~ ~~ a 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 November 8, 2010 in the amount of $4,764.52. 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 9/25/2009. WHEREFORE, plaintiff claims of the defendant(s) the sum of $4,764.52 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDERIC I. W BERG, ESQUIRE JOEL M. FLINK, ESQUIRE Attorney for Plaintiff 2oae2~6 10-23653-0 GS DAY SAZi1C Jasws Callahan 60113101'56233329 I hereby state that I am the agent for the plaintiff herein, and that the facts set forth is the attached 1lffidsvit which is incorporated by reference is the foregoing Coeeplaiat in Civil Action are true cad correct to the best of my knowledge, information cad belief cad is based upon information ~-hich plaintiff has furnished to counsel. The languages is the Cosrplaint is that of counsel cad not of plaintiff. To the extent that the contents of the Cosiplaiat are that of counsel, plaintiff hsa relied upon counsel is making this verification. This verification is made subject to 18 Pa.C.B. $4904 Mhiah provides for certain penalties for false states<eats . EXHIBIT "A" 2244 2088276 10-23653-0 Q~ llOriBY SrAtI1C James Callahan 6011310156233329 71P'a'IDI-VIT I~ ~ , being duly seswd sxorn according to lax, daposa and nay that: 1• = am the agent for the Plaintiff herein and I haw custody and control of the lips r~latinq to this account; 2. I haw personal knoxledge of the facts and airausstanaes in aonnaotion with this case; 3. Plaintiffs files are maintained in the usual and ordinary course of business; 4. Thin nation is based on a claim for breach of contract and that damages era sought as a direct result of said broach; 5. There is nox due and oxinq Eros defendant to plaintiff, the aaount of $4,764.52 plus interest of $.00 at the rata of 04 lass credits in the aaount of $.00 totaling $4,764.52 sa of October 13, 2010. 6. If called upon, affiant can testify at trial as to the feats pertaining to this matter. The above feats are true and rsact to the beat of my knoxledga, information and belie!. Sxorn to and Subsar bafor~ mr this ~ day 0.``~~ ~vr1N I t~'~~.,'AS,~~~ ~Q~,.;}aEXai~~s. Go ~,. __ ~ ' V' PAY v% p_ • O a C~ : o Z ®~ U ~•. W ~i ~ AP?;; '~ ~~ °° /~ Q ~~ ••.. J o\ SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson OF T FILED-OFFICE Sheriff PRO T11, QtIO p Jody S Smith ""DEC _8 P Chief Deputy CUMBERLAND 3' C N?- ), Richard W Stewart PENNSYLVANIA Solicitor GE Money Bank Case Number vs. 2010-7375 James Callahan SHERIFF'S RETURN OF SERVICE 12/02/2010 08:00 PM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on December 2, 2010 at 2000 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: James Callahan, by making known unto himself personally, at 709 Belvedere Street, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to him personally the said true and correct copy of the same. NOAH CLINE, DEPUTY SHERIFF COST: $33.40 December 03, 2010 SO ANSWERS, RONNY R ANDERSON, SHERIFF 2088276 GORDON & WEINBERG, P.C. C BY: FREDERIC I. WEINBERG, ESQUIRE Mai _ n X Identification No.: 41360 JOEL M. FLINK, ESQUIRE cnr" Identification No.: 81894 .-x- w ? 1001 E. Hector Street, Ste 220 :_z- Conshohocken, PA 19428 ` 484/351-0500 =' N GE MONEY BANK VS. James Callahan COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 10-7375 PRAECIPE FOR ENTRY OF JUDGNMT FOR PANT OF AN ANSWER, ASSESSMENT OF DAMAGES, 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 $4,764.52 Less: Payments on Account ( $.00) Total: $4,764.52 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: GE MONEY BANK and that the last known address of defendant, James Callahan, 709 Belvedere St, Carlisle PA 17013. 2. The annexed notice(s) of intention to file this praecipe was (were) mailed to all parties, defendant and to their record attorneys, if any, after default occurred, and at least ten days prior to the date of filing of this praecipe. 3. The said defendant(s) is (are) not: in the military service of the United States or otherwise within the coverage of the Soldiers and Sailors Civil Relief Act and is (are) over 18 years of age. 11"II)t?&6) 14" tg# i11A3LIU X/010 t AND NOW, this day of 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 , $4,764.52 as per the above certification P r o t h o y GORDON & WEINERG, P.C. -;?>r BY: FREDERIC t. EINBERG, ESQUIRE JOEL M. 4JZNK, ESQUIRE Attorney for Plaintiff 2088276 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 GE MONEY BANK COURT OF COMMON PLEAS CUMBERLAND COUNTY VS. DOCKET NO. : 10-7375 James Callahan 709 Belvedere St Carlisle PA 17013 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. Judgment by Default $4,764.52 L-L Money Judgment $ L_Z Judgment on Award of Arbitrators$ L-L Judgment on Verdict$ IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL ATTORNEYS: FREDERIC I. WEINBERG OR JOEL M. FLINK, ESQUIRES AT THIS TELEPHONE NUMBER: 484/351-0500 1? /Z/ // --r?) ?? PR NOTARY 1 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 2088276 GE MONEY BANK COURT OF COMMON PLEAS CUMBERLAND COUNTY Vs. DOCKET NO. : 10-7375 James Callahan NOTICE OF INTENTION TO TAKE DEFAULT TO/PARA James Callahan 709 Belvedere St Carlisle PA 17013 DATE OF NOTICE/FECHA DEL AVISO: December 23, 2010 II?ORTANT 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 S. BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 GORDON & WEINBERG, P.C. BY: FREDERI I. WEINBERG, ESQUIRE JOEL M. F NK, ESQUIRE P10D-2 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 2088276 GE MONEY BANK COURT OF COMMON PLEAS CUMBERLAND COUNTY Vs. DOCKET NO. : 10-7375 James Callahan NOTICE OF INTENTION TO TAKE DEFAULT TO/PARA Jerome S. Lamet, Esquire 542 S. Dearborn St. Ste. 1260 Chicago, IL 60605 DATE OF NOTICE/FECHA DEL AVISO: December 23, 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 S. BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 GORDON & WEINBERG, P.C. BY: FREDERIC I. EI BERG, ESQUIRE JOEL M. FL NK, SQUIRE P10D-2