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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
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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
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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 ®~`'~ -~
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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