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Home My WebLink About02-0135GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 21 S. 21ST STREET PHILADELPHIA, PA 19103 215/988-9600 THIS IS AN ARBITRATION PLATTER. ASSESSMENT OF DAMAGES HEARING REQUIRED. American Express Centurion Bank Suite 0002 Chicago, IL 60679 vs. Mary B. Henderson 600 Echo Dr. Camp Hill, PA 17011 NOTICE COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO.:O~ 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. COURT ADMINISTRATOR CUMBERLAND COUNTY COURT HOUSE, 4TH FLOOR 1 COURTHOUSE SQUARE CARLISLE, PA 17013-3387 717-240-6200 GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 21 S. 21ST STREET PHILADELPHIA, PA 19103 215/988-9600 THIS IS AN ARBITRATION MATTER. ASSESSMENT OF DAMAGES HEARING REQUIRED. American Express Centurion Bank Suite 0002 Chicago, IL 60679 vs. Mary B. Henderson 600 Echo Dr. Camp Hill, PA 17011 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO.:63~ --I~ 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 is attached hereto as Exhibit "A". 4. Ail the credits to which the defendant(s)is entitled have been applied and there remains a balance due in the amount of $7,526.52. 5. Plaintiff has made demand upon the defendant(s)for payment of the balance due of $7,526.52 but the defendant(s)has failed and refused and still refuses to pay the same or any part thereof. 6. Plaintiff is also entitled to reimbursement of the court costs in the amount of $145.50. W~IER~FORE, plaintiff claims of the defendant(s)the principal amount of $7,526.52, plus court costs in the amount of $145.50 totaling the sum of $7,672.02, plus interest and attorney's fees all of which is justly due and owing from defendant(s) to plaintiff. P01A GORDON & WEINBERG, P.C. BY: FRED~QUIRE Attorney for Pl~f V~RIFICATION FREDERIC I. WEINBERG, ESQUIRE, hereby states that he is the attorney for the Plaintiff(s) in this action and verifies that the statements made in the foregoing pleading are true and correct to the best of his knowledge, information and belief. The undersigned understands that the statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities. FREDERIC I. WEI~iE EXHIBIT "A " Monthly Activity Summary Minumum Past Due Payment Due Amount 724.08 573.08 MARY B HENDERSON 6OO ECHO ROAD CAMP HILL PA 17011 Payment Due Date 05/16/01 /-~[.;L;UUl I[ Statement YOUR ACCOUNT IS CANCELLED AND HAS BEEN REFERRED FOR COLLECTIONS. PLEASE REMIT PAYMENT IMMEDIATELY. New Account Please write in Balance Number amount of payment ?, 526.52 3737-529976-3300& $ enclosed Make check payable to: AMERICAN EXPRESS CENTURTON BANK SUITE 0002 CHTCAG0 TL 60679-0002 hlh,lh,,,Ih,h,,Ihh,lh,,Ih,,Ih,,,,hlhl,,hl,,,,hll 0000373752997633008 000752652000072408 22HH Cardmember Mother's Day is May 13th - Why not use your Optima(R) Card to save 20% on a handmade box of chocolates from News www.eDelights.com * just enter code "amex20" at check out...or save 20% on fresh cut flowers from www.proflowers, com/amex. Or find discounts on gifts for mom at http://www, americanexpress.com/offerzone. Cardmember Name Account Number MARY B HENDERSON 3737-529976-33008 Am. Exp. Date of Date of Transaction Charges Reference No. Transaction Posting Description 431111-0 04/21 04/21 DELINQUENCY FEE ASSESSMENT M[N PAYMENT NOT RECEIVED BY DUE DATE ACCOUNT TOTAL EFFECTIVE IMMEDIATELY, THE TIMIN~OF WHEN THE DELINQ. FEE IS IMPOSED IS BEING CHANGED. IF WE DO NOT RECEIVE THE MINIMUM AMOUNT DUE BY PAYMENT DUE DATE, A DELINQ. FEE WILL BE IMPOSED. ACCOUNT GRACE PER[OD=STANDARD GRACE (SEE STATEMENT BACK FOR DETAILS). Page 1 of Credits 29. O0 29.00 .00 Account Previous Summary Balance 7,351 .22 Bill Closing Da~4/21/01 Finance Charge PURCHASES CASH ADVANCES + New - Payments - Credits Charges 29. O0. O0 Payment Credit Available Due Date Limit Credit 05/16/01 7,400 Number of Days x Daily x Average this Billing Period Periodic Rate Daily Balance 3O 3O + FINANCE CHARGE .O0 146.30 Amount Over Credit Limit 0 .0657% 7,422.65 .0657% .00 FINANCE ~HARGE 146.30 .00 + Debit Adjustments Past Due Amount 573.08 = New Balance .00 7,526.52 Minimum i Payment Due 724.08 .~URRENT ANNUAL PERCENTAGE RATE 23. 990% 23. 990% thank YOU Customer Service The OptimaS"Card Account Charges Cardmember Name MARY B HENDERSON Am. Exp. I Date of Date of I Transaction Reference No.ITransaction Post ng I Description Account Number 3737-529976-33008 Bill Closing Date 04-21-01 tCharges FOR EASY ACCESS TO SELECTED INFORMATION, CALL 1-800-423-1414, THEN ENTER: -1 FOR BALANCE,PAYMENT OR AVAILABLE CREDIT -2 FOR LOST, STOLEN OR DAMAGED CARD -3 FOR CARD BENEFITS OR SERVICES Page 2 ~redits of The OptimaS~ard SHERIFF'S RETURN - CASE NO: 2002-00135 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND AMERICAN EXPRESS CENTRUION BAN VS HENDERSON MARY B REGULAR DAVID MCKINNEY , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon HENDERSON MARY B the DEFENDANT , at 1828:00 HOURS, on the 30th day of January , 2002 at 600 ECHO DR CAMP HILL, PA 17011 MIKE WEAVER, HUSBAND by handing to a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 10.35 Affidavit .00 Surcharge 10.00 .00 38.35 Sworn and Subscribed to before me this 9~-~ day of ! t~othonotary So Answers: R. Thomas Kline 01/31/2002 GORDON & WEINBERG Deputy Sheriff