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Home My WebLink About11-25052105026 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 BARCLAYS BANK DELAWARE 125 S. WEST STREET WILMINGTON, DE 19801 VS. JOSEPH A ROEMER 132 E LOCUST ST MECHANICSBURG PA 17055-6274 ASSESSMENT OF l~ ? COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 1I- 7,5"65 ?)wll 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 16) d ?13 w-b"I'll 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 January 27, 2011 in the amount of $3,184.38. 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 12/21/2009. WHEREFORE, plaintiff claims of the defendant(s) the sum of $3,184.38 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDERIC I. WEI G, ESQUIRE JOEL M. FLINK, ESQUIRE Attorney for Plaintiff . 2105026 BARCLAYS BANK DELAWARE JOSEPH A ROEMER 5140218020514376 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 making false statements. (3 n., 9 6W CU'Kr K' A NAME EXHIBIT "A" 2105026 BARCLAYS BANK DELAWARE JOSEPH A ROEMER 5140218020514376 State of Delaware § County of New Castle § AFFIDAVIT I, j,l being duly served sworn according to law, depose and say that: 1. I am the authorized representative of the Plaintiff herein and I have custody and control of the files relating to this account; 2. Plaintiff's files are maintained in the usual and ordinary course of business; 3. This action is based on a claim for breach of contract and that damages are sought as a direct result of said breach; 4. There is now due and owing from defendant to plaintiff, the amount of $3,184.38 plus interest of $.00 at the rate of 0% less credits in the amount of $.00 totaling $3,184.38 as of January 11, 2011. 5. If called upon, affiant can testify at trial as to the facts pertaining to this matter. The above facts are true and correct to the best of my knowledge, information and belief. AFFIANT: Sworn to and Subscribed before me this A$l day of A , 201b T-X?NAN Notary Public P120 \,kELDON/ij '00 iss/o:.0 • • ;i _ r EXps X12 • Z w •'•Op?ipy PJ®•' 44 ..• ?1111,!N f O d. 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 ,LEU-0FFI T C'Ttio) QTAR t ' L. R 2011 MAR 21 PH 3: 14 rJIMBERMIfm PENNSYLVANIA BARCLAYS BANK DELAWARE VS. JOSEPH A ROEMER COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 11-2505 CIVIL PRMCIPE FOR ENTRY OF JUDGNMT BY AGREENEr1T TO THE PROTHONOTARY: Enter judgment by agreement for plaintiff and against defendant(s) JOSEPH A ROEMER above named only and assess damages certified to be calculable as a sum certain from the complaint, as follows: Principal Total: $3,376.38 $3,376.38 Understanding the false statements made herein are subject to penalty under 18 Pa.C.S.A. §4904, Unsworn Falsification to Authorities, I verify that: 1. The last known addresses of the parties are: BARCLAYS BANK DELAWARE and that the last known address of defendant, JOSEPH A ROEMER, 63 W MAIN STREET APT 3, MECHANICSBURG PA 17055. 2. The annexed notice(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 date of filing of this praecipe. ?oh?e ?V I cu ?e?l 3. The said defendant(s) is (are) not in the military service of the United States or otherwise within the coverage of the Soldiers and Sailors Civil Relief Act and is (are) over 18 years of age. n,?. l 2011 Judgment AND NOW, this day of 01 UVI-'n By Agreement is entered in favor of the plaintiff(s) and against defendant(s) at the sum of';^?,$3,376.38 as per the above certification. Prnot GORDON & WEINBERG, P.C. G BY: FREDERIC I. UK, RG, ESQUIRE JOEL M. FLI QUIRE Attorney fontiff 2105026 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 BARCLAYS BANK DELAWARE Vs. JOSEPH A ROEMER COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 11-2505 CIVIL NOTICE Pursuant to Pa.R.Civ.P. 236 of the Supreme Court of Pennsylvania, you are hereby notified that a judgment has been entered against you in the above proceeding as indicated below. Judgment by Agreement $3,376.38 Money Judgment $ Judgment on Award of Arbitrators$ ?L Judgment on Verdict$ IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL ATTORNEYS: FREDERIC I. WEINBERG OR JOEL M. FLINK, ESQUIRES AT THIS TELEPHONE NUMBER: 484/351-0500 ??«? PRO N T Y r " 2105026 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 BARCLAYS BANK DELAWARE COURT OF COMMON PLEAS CUMBERLAND COUNTY VS. DOCKET NO. 11-2505 CIVIL JOSEPH A ROEMER JUDGICENT ]BY AGREEMENT AND NOW, this -JL?day of 2011, it is hereby stipulated and agreed to by and between, JOSEPH A ROEMER, his successors and assigns and Frederic I. Weinberg, Esquire, counsel for BARCLAYS BANK DELAWARE that the Court enter a determination in the above-captioned case as follows: 1. Judgment shall be entered in the amount of Three Thousand Three Hundred Seventy Six and 38/100 ($3,376.38) plus 6% post judgment interest and court cost in favor of BARCLAYS BANK DELAWARE and against, JOSEPH A ROEMER, his successors and assigns; 2. Plaintiff, BARCLAYS BANK DELAWARE, will agree to accept the sum of $75.00 per month from, JOSEPH A ROEMER, his successors and assigns. The first payment of $75.00 per month shall become due and payable on April 5, 2011 and then on the 5th of every month thereafter until the Stipulated Judgment is paid in full; 3. In the event that JOSEPH A ROEMER, his successors and assigns do not make payments as prescribed in paragraph 2, they will be considered in default and the Plaintiff, BARCLAYS BANK DELAWARE shall be allowed to exercise any and all remedies available at law. 4. The Parties to this action have authorized their respective counsel and agent to enter into this agreement on their behalf and by doing so this agreement will be binding on both that JOSEPH A ROEMER, his successors and assigns and, BARCLAYS BANK DELAWARE its successors and assigns. Date: ?0 II _ JO PH A ROEMER De endant .3- y-// Date FREDEFI??'L. I BERG, Esquire JOEL INK, Esquire Attor or Pl aintiff I.D. #41360 I.D. #41200 1001 E. Hector Street, Suite 220 Conshohocken, PA 19428 484/351-0500 2 2105026 L r tcOTH tOTft, ,x;. GORDON & WEINBERG, P.C. BY: FREDERIC I . WEINBERG, ESQUIRE U11BERLAN�l PEN CUT ' Identification No. : 41360 Y .VANIA — JOEL M. FLINK, ESQUIRE Identification No. : 41200 1001 E. Hector Street, Ste 220 ag Conshohocken, PA 19428 484/35.1-0500 BARCLAYS BANK DELAWARE COURT OF COMMON PLEAS CUMBERLAND COUNTY vs . DOCKET NO. : 11-2505 CIVIL HEE MEE JOSEPH . A ROEMER ORDER TO SATISFY JUDGMENT =NM= TO ' THE PROTHONOTARY: Kindly mark the judgment entered March 21, 2011 in the above-captioned matter satisfied upon payment of your costs only. GORDON & WEINBERG, P.C. amm mam BY: FREDERIC I EINBERG, ESQUIRE JOEL M. FLINK, ESQUIRE ggE Attorney for Plaintiff P005 A S, 56$ Cldfl W " .e--AODon