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HomeMy WebLinkAbout11-01582101956 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 Alpharetta GA Patricia Erb 207 Neil Rd Shippensburg PLAZA DRIVE 30005 vs. PA 17257 COURT OF COMMON PLEAS CUMBERLAND COUNTY p c DOCKET N0. :abl ~- ~~o rn~ w ~'Ui/7G1'l~z~ ~~ -<?~ ,.~ ~~ ~~ ~_ o D ~ -+ -< NOTICE 0 c~ .-F~. a --~ .ter ~: o , O -n on ~~ D -~: YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEE'END 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 ~- w,, ~' ©~a pp ~~ fC ,~~y~ 33g~ X25 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 i:he 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 12/16/10 in the amount of $3,462.27. 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 5/19/10. WHEREFORE, plaintiff claims of the de:fendant(s) the sum of $3,462.27 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY : ~- FREDERIC I. EI ERG, ESQUIRE JOEL M. FLI ESQUIRE Attorney for Plaintiff POlA 2101956 30-41488-0 G8 ~8Y BAIQlC Patricia Barb 430598249SS60917 I hereby state that I am the agent for the plaintiff herein, and that the facts set forth in the attached Affidavit xhioh is incorporated by references in the foregoing Complaint is Civil Ration are true and correct to the best of my knoxledge, information and belief and is based upon infcermatioa xhiah plaintiff has furnished to counsel. The laagnage is the Cosrplaint is that of aouasel and not of plaintiff. To the extent that the contents of the Ccaplaiat are that of counsel, plaintiff has relied upon counsel in making this verification. This verification is made subject to 18 Pa.C.S. X4904 xhiah provides for certain penalties for making false sta.tamsnts. !~~ 2244 Patricia 8sb 4305982495560917 2101956 10-41488-0 Q~8 ~NEY BANK _, Frankie Dunn ,being duly served aMOrn aaaording to laM, depose and say that: 1. I am the agent for the Plaintiff herein and I have custody aad control of the files relating to this account; 2. I have personal knoNledge of the facts and circumatancss in connection Kith this teas; 3. plaintiff's files are maintained in the usual and ordinary aoursa of buaineas; 4. This action is based oa a claim for breach of contrast and that damages are sought as a direst result of said breaoh; 5. Theta is now due and owing from defendant to plaintiff, the aaount of $3,462.27 plus interest of $.00 at the rate of 08 less credits in the amount of $.00 totaling $3,462.27 as of November 17, 2010. 6. If called upon, affiant can testify at trial as to the feats pertaining to this matter. The above facts are true and orrect to the bast of my knoMledge, information arsd belief . Scorn to and Subscribed before m~ this ~ day , 200 ~ta~q.a s~',,d ~ r. Y~ i~c . ~~4 .~ ~ ~ `;, ,~ K_~ ~~i ~~ ~~ ~~ ~'~~ ,. ._.t~., ~ 1~ `,,; a :- r ,. rr ,c l ~ ':. 4~ G ~ 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 1942 484/351-0500 "56 R Ia, i ;? C r GE MONEY BANK vs. Patricia Erb TO THE PROTHONOTARY: COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 2011-158 Enter judgment for want of an answer for plaintiff and against defendant(s) above named only and assess damages certified to be calculable as a sum certain from the complaint, as follows: Pr ncipal $3,462.27 Le s: Payments on Account ( $1,020.00) • $2,442.27 Understanding the fals statements made herein are subject to penalty under 18 Pa.C. A. §4904, Unsworn Falsification to Authorities, I verify hat: 1. The last kno n addresses of the parties are: GE MONEY BANK and that the las known address of defendant, Patricia Erb, 207 Neil Rd, Shippensbur PA 17257. 2. The annexed otice(s) of intention to file this praecipe was (were) mailed to all parties, defendant and to their record attorneys, if any, after default occurred, and. at least ten days prior to the ate of filing of this praecipe. Pd ?/?1 •o?' ?y w?r,? hlry 3. The said def ndant (s) is (are) not in the military ey1t )t1073J service of the United tates or otherwise within the coverage of 9,%/00 the Soldiers and Sailo s Civil Relief Act and is (are) over 18 years of age. ?L?GhT?Gu AND NOW, this ? day of _MAK/,17 , 2011 Judgment is entered in favor of the plaintiff(s) and against defendant(s) by default for want of an answer and damages assessed at the sum of , $2,442.27 as per the above cer if ation. Prdtho GORDON & WEINBERG, P.C. BY: FREDERIC I(_ WWNBERG, ESQUIRE JOEL M. FLINK, ESQUIRE Attorney for Plaintiff 2101956 GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBE G, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ES UIRE Identification No.: 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 1942 484/351-0500 GE MONEY BANK Patricia Erb 207 Neil Rd Shippensburg VS. PA 17257 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO 2011-158 NOTICE Pursuant to Pa.R.Civ.P. 236 of you are hereby notifie that a you in the above proce ding as the Supreme Court of Pennsylvania, judgment has been entered against indicated below. Judgment by Default $2,442.27 Money Judgment $ Judgment on Award of Arbitrators$ Judgment on Verdict$ IF YOU HAVE ANY QUESTION CONCERNING THIS NOTICE, ATTORNEYS: FREDERIC I. W T INBERG OR JOEL M. FLINK, TELEPHONE NUMBER: 484/3 1-0500 S/'7 1 PLEASE CALL ESQUIRES AT THIS - a"7?1'w PROTH RY GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG,ESQUIRE I Identification No.: 41360 JOEL M. FLINK, ESQUIR Identification No.: 4 200 1001 E. Hector Street, Ste 20 Conshohocken, PA 19428 484/351-0500 2101956 GE MONEY BANK Patricia Erb TO/PARA vs. Patricia Erb 207 Neil Rd Shippensburg A 17257 DATE OF NOTICE/FECHA DEL AVIiSO: COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 2011-158 February 4, 2011 IMPORTANT NOTICE YOU ARE IN DEFAULT BEC USE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY AN ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS ET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS N =CE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MA LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS P PER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE T E OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT H RING A LAWYER. IF YOU CANNOT AFFORD T HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCE FEE OR NO FEE. LAND COUNTY BAR ASSOCIATION 32 S. BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 GORDON & WEINBERG, P.C. P10D-2 BY: FREDERIC/ . WEINBERG, ESQUIRE JOEL M. ` LINK, ESQUIRE 2101956 GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 81894 ? ? a -. 1001 E. Hector Street, Ste 220 CCn r`n Conshohocken, PA 19428 N Ca 484/351-0500 -0 ? ° C"J GE MONEY BANK COURT OF COMMON PLEAS N? CUMBERLAND COUNTY VS. DOCKET NO. : 2011-158 Patricia Erb SUGGESTION OF BANKRUPTCY OF DEFENDANT TO THE PROTHONOTARY: AND NOW, this May 6, 2011, it is suggested of record that Defendant, Patricia Erb, filed a petition in bankruptcy under Chapter 13 of the Bankruptcy Code on or about April 29, 2011, in the United States Bankruptcy Court for the Middle District of Pennsylvania, docket number 11-03125-M. Therefore, this matter should be stayed until further notice. GORDON & WEINBERG, P.C. r BY: 7? FREDERIC I. IN RG, ESQUIRE JOEL M. FLIN , ESQUIRE Attorney for Plaintiff