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HomeMy WebLinkAbout11-00312093450 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 ~'iL~'D-~~c l ., m ~ ~n~ -+, ~, , C:; r"~~: ~~;~T.~ ~ ~~,.k ; Cl~~RLA~~~ ui,~'~~ i "~' GE MONEY BANK COURT OF COMMON PLEAS 4125 Windward Plaza Drive CUMBERLAND COUNTY Alpharetta GA 30005 vs . DOCKET NO. ~ ~ - 3) l~~Vt~ ~l°.1"MI Connie Wetzel 37 Fox Hill Rd Shippensburg PA 17257 I E 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 LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 YOU DO NOT HAVE A SET FORTH BELOW TO ~4a.oo Qp ~~ e* ~ uo'1-tvs ~,~ a s3r~lo 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 $2,007.23. 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 1/5/2010. WHEREFORE, plaintiff claims of the defendant(s) the sum of $2,007.23 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE JOEL M. FLINK, ESQUIRE Attorney for Plaintiff 2093450 10-35421-0 GS 1i0N8Y BANK Coru~ie Weisel 6018596505902001 VERIFICJITICN I hereby state that I am the agent for the plaintiff herein, and that the faata sat forth in the attached Affidavit which is incorporated by reference in the foregoing Camplaiat in Civil Action are true and correct to the best of my knorledge, information and belief and is based upon information Mhich plaintiff has furnished to conceal. The language in the Complaint is that of counsel cad not of plaintiff. To the extent that the aoatsnta of the Ccseplaint are that of counsel, plaintiff has relied upon counsel in making this verification. Thin verification is made subject to 18 Pa.C.B. X4904 Mhich provides for aertaia penalties for making false statameats. r , 2244 Connie Retasl 6018596505902001 2093450 10-33421-0 GE ~ONSY SANK ]1FFIDAVIT I , Fralll(ie Dunn , being duly served scorn according to law, depose cad say-that: 1. I am the agent for the Plaintif! harain and I haw custody and control of the fibs ralatinq to this account; 2• I have personal kaowladge of tha facts cad circumataaces in connection with Chia case; 3. Plaintiff's files are maintained in the usual and ordinary comae of business; 4. This action is based oa a claim for breach of contract sad 'that damages arc saught as a direct result of said bre:ch; 5. There is non duo and o~-inq frog cLfendant to plaintiff, the amount of $2,007.23 plus interest of $.00 at the rata of 0~ less oredits is the amount of $.00 totaling $2,007.23 as of Nov~eber 23, 2010. 4 6. If called upon, affiant can testify at trial sa to the facts pertaining to Chia matter. The above facts are true and rreat to the beat of my knowladgs, information cad belief. .~ ]1FFIANT Sworn to and Subsc/ribed o°°°~~~Aj J~~t:'°`, before thin day ti ~~,~Poa~„sio:, ` ' ; '- ~~~` C~®~~• Ag of 2010 '" 'i ®~`'~ -~ ~ ~- p : e;- .~~ ~/ , i ~ °°, `~. EELEO-OFFICE Or THE PROTHO OTAR'r' Tracy L. Updike, Esquire PA Supreme Court ID # 88680 2011 FEB -2 PM 12: 54 CUNNINGHAM & CHERNICOFF, P.C. 2320 North Second Street f"'U MBERLAND COlli°?T'?. PENNSYLVANIA P.O. Box 60457 Harrisburg, PA 17106-0457 (717) 238-6570 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GE MONEY BANK, Plaintiff, VS. CONNIE Y. WETZEL, Defendant CIVIL ACTION - LAW : No. I1-31 NOTICE OF STAY NOTICE IS HEREBY GIVEN that Connie Y. Wetzel, above-named Defendant, has filed a Petition under Chapter 13 of the United States Bankruptcy Code to Case No. 1-11-00572 and as a result thereof, the above-captioned action is stayed until further Order of the United States Bankruptcy Court. The undersigned executes this Notice for purposes of giving notice only; and the providing of this Notice is not intended to enter an appearance in the within case. Respectfully submitted, CUNNINGHAM & CHERNICOFF, P.C. Date: January 31, 2011 By: "U? U, A Lik V.I.ra. L. p dike, squire 88680 2320 North Second Street P.O. Boa: 60457 Harrisburg, PA 17106-0457 (717) 238-6570 Tracy L. Updike, Esquire PA Supreme Court ID # 88680 CUNNINGHAM & CHERNICOFF, P.C. 2320 North Second Street P.O. Box 60457 Harrisburg, PA 17106-0457 (717) 238-6570 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GE MONEY BANK, CIVIL ACTION - LAW Plaintiff, No. 11-31 VS. CONNIE Y. WETZEL, Defendant CERTIFICATE OF SERVICE I, Lisa Fuge, do hereby certify that a true and correct copy of the NOTICE OF STAY was sent by first class mail, postage prepaid on this day to the following: Frederic Weinberg, Esquire Joel Flink, Esquire 1001 E. Hector Street, Suite 220 Conshohocken, PA 19428 Respectfully submitted, Date: January 31, 2011 F:\Home\LFUGE\WETZEL-CONNIE\NOTICEBK-GE Money.wpd CUNNINGHAM & CHERNICOFF, P.C. By: RQ ?-A Lisa Fuge, Paraleg 2 FILED-OF FIC 03" THE PROTHOEdOTA'IR 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 2011 FEBJO?141a: I I CUMBERLAND COUNTY PENNSYLVANIA GE MONEY BANK COURT OF COMMON PLEAS CUMBERLAND COUNTY VS. DOCKET NO. : 11-31 Connie Wetzel SUGGESTION OF BANKRUPTCY OF DEFENDANT TO THE PROTHONOTARY: AND NOW, this 04Febll, it is suggested of record that Defendant, Connie Wetzel, filed a petition in bankruptcy under Chapter 13 of the Bankruptcy Code on or about January 28, 2011, in the United States Bankruptcy Court for the Middle District of Pennsylvania, docket number 11-00572. Therefore, this matter should be stayed until further notice. GORDON & WEINBERG, P.C. BY: FREDERIC I. WEI BERG, ESQUIRE JOEL M. FL NK, SQUIRE Attorney fo aintiff David -D. BueCC Prothonotary Office of the Prothonotary Cum6erfand County, Pennsylvania /I-0031 ORDER OF TERMINATION OF COURT CASES xyrkS. Sohonage, ESQ, Solicitor 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 • CarCisfe, TA • (Phone 717 240-6195 0 Fax 717 240-6573