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Home My WebLink About10-7872i c.. a 2092945 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 GE MONEY BANK 4125 WINDWARD PLAZA DRIVE Alpharetta GA 30005 Vs. COURT OF COMMON PLEAS CUMBERLAND COUNTY rn o .i Cn e r> prn ti -?: c"I Michael Obrien 520 Reno St Apt 7 New Cumberland PA 17070 DOCKET NO. Ci+1 I 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 ,qa ctTl? ao?r ayj CL4 1-14102 L %. 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 December 8, 2010 in the amount of $4,782.79. 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 12/2/09. ti WHEREFORE, plaintiff claims of the defendant(s) the sum of $4,782.79 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDERI Qeiti*K, INBERG, ESQUIRE JOEL M. ESQUIRE Attorney for Plaintiff P01A 2092945 10-33712-0 GE Dino T BANK Michael Obrien 6032207460775901 VERIFICATION I hereby state that I am the agent for the plaintiff herein, and that the facts set forth in the attached Affidavit which is incorporated by reference in the foregoing Complaint in Civil Action are true and correct to the best of my knowledge, information and belief and is based upon information which plaintiff has furnished to counsel. The language in the Complaint is that of counsel and not of plaintiff. To the extent that the contents of the Complaint are that of counsel, plaintiff has relied upon counsel in making this verification. This verification is made subject to 18 Pa.C.S. §4904 which provides for certain penalties for mak NAME false statements. EXHIBIT "A" 2244 2092945 10-33712-0 GE MNEY BANK Michael Obrien 6032207460775901 law, depose and say that: AFFIDAVIT being duly served sworn according to 1. I am the agent for the Plaintiff herein and I have custody and control of the files relating to this account; 2. I 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. There is now due and owing from defendant to plaintiff, the amount of $4,782.79 plus interest of $.00 at the rate of 0% less credits in the amount of $.00 totaling $4,782.79 as of November 15, 2010. 6. If called upon, affiant can testify at trial as to the facts pertaining to this matter. The above facts are true and co rest to the best of my knowledge, information and belief. AF IAN Sworn to and Subscribed before me.4 1this da of , I/ I V V, 2010 Nota*v 10ubllic SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor c F @4f..[j-"74 1 1•.? . 2011 JAN -7 P,'112:40 GE Money Bank vs. Michael Obrien Case Number 2010-7872 SHERIFF'S RETURN OF SERVICE 12/28/2010 04:55 PM - Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on December 28, 2010 at 1655 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Michael Obrien, by making known unto himself personally, at 520 Reno Street, Apartment 7, New Cumberland, Cumberland County, Pennsylvania 17070 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $43.30 January 04, 2011 DENNI FRY, DEP SO ANSWERS, RON R ANDERSON, SHERIFF GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 81894 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 C C= 3 20929w c- C:) . CD ? o? 2p D? or -' GE MONEY BANK COURT OF COMMON PLEAS CUMBERLAND COUNTY VS. DOCKET NO. : 10-7872 CIVIL Michael Obrien SUGGESTION OF BANMUPTCY OF DEFENDANT TO THE PROTHONOTARY: AND NOW, this 04Febll, it is suggested of record that Defendant, Michael Obrien, filed a petition in bankruptcy under Chapter 7 of the Bankruptcy Code on or about January 25, 2011, in the United States Bankruptcy Court for the Middle District of Pennsylvania, docket number 11-00461. Therefore, this matter should be stayed until further notice. GORDON & WEINBERG, P.C. BY: FREDERIC I JOEL M. FL Attorney f EITBERG, ESQUIRE ESQUIRE Plaintiff David D. cBuel Protfionotary Office of the Prothonotary Cum6erfand County, KPennsyfvania �irkS. Sofionage, ESQ Solicitor /U r ?S /Z 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 PROTHO NOTARY One Courthouse Square • Suite100 • Cal -tide, TA • (Phone 717 240-6195 0 'Ta, 717 240-6573