Loading...
HomeMy WebLinkAbout10-7377 ' 2089929 THIS IS AN ARBITRATION MATTER. ASSESSMENT OF 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 ~ "' ~ - 'Q~ GE MONEY BANK COURT OF COMMON PLEAS ,2~ ~ ~ *~ 4125 Windward Plaza Drive CUMBERLAND COUNTY ter- N ,,,,, Alpharetta GA 30005 ~~ ~o p 0 <r~ ~+o vs. DOCKET N0. : ~~..'~~"~"~ ~~ 3 ~~ _ Stanley Douglas ~*~, -~ w c o~ 1330 Williams Grove Rd `~ s Mechanicsburg PA 17055 _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 ~~ ~~a~~~ ~~ 5~~~ ~'~ 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 3, 2010 in the amount of $1,738.76. 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 9/19/2009. WHEREFORE, plaintiff claims of the defendant(s) the sum of $1,738.76 plus applicable costs, interest and attorney's fees. CORDON & WEINBERG, P.C. BY: FREDERIC I WEI RG, ESQUIRE JOEL M. FLIN ESQUIRE Attorney for Plaintiff 2089929 10-29775-0 GB _ ~~ Stanley Douglas 6008893473087660 VBRIp'ICATIO®1 I hereby state that I am the agent for the plaintiff herein, and that the fasts set forth is the attached Affidavit Which is incorporated by reference in the foregoing Ccmrplaiat in Civil Action are true and correct to the beat of my kaoMledge, information and belief sad is based upon information Mhiah plaintiff has furnished to counsel. The lanquaq~ in the Comrplaint is that of counsel and not of plaintiff. To the extent that the aonteats of the Ccarplaiat are that of counsel, plaintiff has relied upon counsel in making this verification. This wrifiaatioa is made anbjeat to 18 Pa.C.B. X4904 which provides for certain penalties for making false statements. ~X~~~ ~~ EXHIBIT "A" 2244 2089929 10-29775-0 GE DIaNBY HAai1C Stanley Douglas 6008893473067660 laK, doss and say that: ~'B'ID1-VIT being duly s~rwd sworn according to 1• _ as the agent for the Plaintiff heroin and I haw custody and control of the fibs r~latinq to this account; 2. I haw personal knoMl~dq~ of the feats and circumstancws in connection Kith this caste; 3. Blaintiff'a fibs arm maintained in the usual and ordinary courses of business; 4. This action is basted on a alms for breach of contract and that damagrs era sought as a direct result of :aid braaoh; 5• ors is ao~- due cad oMiaq Eros daft to plaintiff, the amount of $1,738.76 plus int~st of $.00 at th• rato of 0~ lace cradita in the amount of $.00 totaling $1,738.76 as of Ootobor 11, 2010. 6. if aall~d upon, affiant can testify at trial as to the facts p~rtaininq to this mattor. Thy chow fasts arm truce and r~ct to the host of my knoMladq., information and b~li~f. AFFIAt~1T SMOrn to and Sub crib~d bafor~ s~ thi ~y 10 A} 44@dlfJ + c..: a ~5~~ d0®O ~ ~~*oe2pso ;°' tea` ~®~~~ ®ddd~ ®1i'a\P®~~`® SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor FILED-OFFICE Or HE PROTHONOT , 't' 2010 DEC -9 PM 4: 20 CUMBERLAND COUNTY PENNSYLVANIA GE Money Bank Case Number vs. Stanley E. Douglas 2010-7377 SHERIFF'S RETURN OF SERVICE 12/02/2010 06:33 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on December 2, 2010 at 1833 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Stanley E. Douglas, by making known unto himself personally, at 1330 Williams Grove 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. RYAN BURGETT, DEPUTY SHERIFF COST: $37.00 December 03, 2010 SO ANSWERS, RON W? R ANDERSON, SHERIFF David 11 Buelt Prothonotary Office of the (Prothonotary Cum6erfand County, Pennsylvania Kirks. Sofionage, F,SQ Solicitor ID -1377 ORDER OF TERMINATION OF COURT CASES CIVIL TERM 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 • CarfisCe, (PA • (Pone 717 240-6195 • 'Fa.K717 240-6573