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Home My WebLink About11-00132087529 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 Alpharetta,GA Plaza Drive 30005 VS. Lorie Foor 87 Hummel Ave Lemoyne PA 17043 COURT OF COMMON PLEAS ~ o CUMBERLAND COUNTY ~ N ° ~ ~ w . s rn-_t DOCKET NO .: a b ~~ • ~ 3 ,~ ~' ~ ~ D ~ ~ m ~. ~ C ~ J~ 1 r-- ac c ~ --ao 'r'e-r~M -c o ~ o -ti ~ = ~ ~ "'i Z ~ -{ GJ ~ ~ C7~ -.~': 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 GBJECTIONS 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 aoD~~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 December 17, 2010 in the amount of $2,703.52. 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 9/8/2009. WHEREFORE, plaintiff claims of the defendant(s) the sum of $2,703.52 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDERIC I. IN G, ESQUIRE JOEL M. FLINK, ESQUIRE Attorney for Plaintiff 2087529 10-19775-0 G8 FI1tANCS-POST Lorin Foor 6008893472675739 V~RIFICJlTIODZ I hereby state that I am the agent for the plaintiff herein, sad that the fasts sat forth in the attached Affidavit xhich is incorporated by reference is the foregoing Ca~laiat in Civil Action are true sad correct to the beat Of ~ kaONledge, information sad belief sad is based upon iaformatioa shish plaintiff has furnished to counsel. The laagaage is the Complaint is that of counsel sad not of plaintiff. To the eztent that the contests of the Ca®plsiat are that of counsel, plaintiff has relied upon counsel in making this verification. This verification is made subject to 18 Pa.C.S. 54904 xhich provides for certain penalties for making false statements. EXHIBIT "A" L 2244 Lorin Poor 5008893472675739 AFFID]-VIT I, Frankie Dunn lax, depose and say that: 2087529 10-19775-0 G~ FINANCE-POST being duly served sr-orn 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 csse; 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 dun and owing frog defendant to plaintiff, the amount of $2,703.52 plus interest of $.QO at the rate of O~i less credits in the amount of $.00 totaling $2,703.52 as of November 23, 2010. 6. If called upon, affiant can testify at trial as to the faata pertaining to this matter. The above facts are t ree and aosrect to the best of my knowledge inforatation and belief . , ,'~fi~.'~.: ~~. Sworn to and Subscribed ~, '' <-, ^, J ' e ' ~•' . r . s; '` ~~ ,';~`o ~ " before this day '' P , ° ,.~,. .y ~ ' ~ ~ e ~ , . ~ 5 ~ . ,~ ,,: o \~ .. .. d ~ r`> ~ t 7 . . a , , ~~' ~r q ~f ~ . ¢ _ . s_ ''fi'L ~ C.. is ' '~;,~~ Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY ????.tt? of ?un+Grr??t - co M M .10rn ?° o C) -n za oM D r Ge Finance-Post Case Number vs. Lorie A. Foor 2011-13 SHERIFF'S RETURN OF SERVICE 01/10/2011 08:07 PM - Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on January 10, 2011 at 2007 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Lorie A. Foor, by making known unto herself personally, at 87 Hummel Avenue, Lemoyne, Cumberland County, Pennsylvania 17043 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $42.40 January 11, 2011 , - - z Z= ?;;; ?; o,::; ?? DENIK FRY, D!P SO ANSWERS, a RON R ANDERSO ,4i1EFWF iTt -- _? -vrn o, Z Cncl) :4ry't r- - ;:o (.;cun•-Sid Stl@I `t fF Lorie A. Foor 87 Hummel Ave Lemoyne, Pa. 17043 Defendant in Pro Per Court of Common Pleas Cumberland County, Pennsylvania Civil Action-Law GE Money Bank Plaintiff VS. Lorie A. Foor Defendant OF THE PROTHONOTARY 2011 JAN 19 pM i .36 CUP-10 TY r A No. 2011-13 Civil Term Lorie A. Foor (Defendant), hereby answers the complaint of GE Money Bank ("Plaintiff") for it's self alone as follows and generally denies the allegations due to the complaint based on lack of information and belief. Due to a serious financial crisis, defendant does not have sufficient funds to pay the full amount of disputed debt, if any. I cannot pay this amount because of a serious financial issue. I am making an effort to get some money and will let you know when I can pay. I am confident this matter will get resolved. Wherefore, Defendant requests that: 1. Defendant takes nothing by way of his complaint, and 2. For Defendant's cost of suit January 11, 2011 Defendant in Pro Per 40 GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M FLINK, ESQUIRE Identification No.: 41200 1001 E. HECTOR STREET CONSHOHOCKEN, PA 19428 484/351-0500 GE MONEY BANK VS. LORIE FOOR 2087529 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO.: 2011-13 STIPULATION OF SETTLEMENT C= cc rn. a rn= ? _-^ N -Orn C) -T w --{ 6 .?. G w = _T1 C:) =o ac' C CO --d It is HEREBY STIPULATED AND AGREED that the above-entitled action is settled by agreement of the parties under the following terms and conditions: 1. Defendant and Plaintiff desire to settle the above captioned matter and stipulate that Defendant will pay to the order of Gordon and Weinberg, P.C., attorneys for the Plaintiff, at their offices at 1001 E. Hector Street, Conshohocken, Pennsylvania 19428, for the sum of One Thousand Five Hundred and 00/100 ($1,500.00)Dollars in the following matter: a. Six (6) equal and consecutive payments of Two Hundred Fifty and 00/100 (250.00) Dollars to be received on or before the 2011 of each month beginning February 20 2011. 2. Defendant appears generally herein and submits to the jurisdiction of the Court. 3. In the event of a default of any of the above listed conditions and payments, Plaintiff may, upon 10 days notice enter judgment for the relief demanded in the Complaint filed in this matter plus judicial interest of 6% running from the date of filing. 4. Upon full and final compliance with this stipulation, this action shall be deemed fully settled, discontinued and/or satisfied. 5. In accordance with the terms of this agreement there appears to be a related consent order for judgment held in escrow which will automatically extinguish upon compliance with the above mentioned terms. Joel M. quire Gordon and Weinberg, P.C. Lorie Foor