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Home My WebLink About11-50812112111 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. DONNA S LANDIS 3507 MARGO RD CAMP HILL PA 17011-1544 ASSESSMENT OF j7 'LED-OFFICE E Tf F P=ROT#,O 0T R t 20111 JUN 20 PM I: 25 C J7'{BL_t U,A. ,) OoUfj E y ,?F1I.1" SYLVA I COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : // - SOS ( 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 (Z) -19-2.6b ?GL n4 ?? -2L67q141 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(slthe 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 6/3/11 in the amount of $12,027.16. 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 4/14/2010. WHEREFORE, plaintiff claims of the defendant(s) the sum of $12,027.16 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDERIC I. WE RG, ESQUIRE JOEL M. FLINK, ESQUIRE Attorney for Plaintiff 2112111 BARCLAYS BANK DELAWARE DONNA S LANDIS 5140218021779879 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. W ,?ni'nv??i??? NAW: EXHIBIT "A" 2112111 BARCLAYS BANK DELAWARE DONNA S LANDIS 5140218021779879 State of Delaware § County of New Castle § AFFIDAVIT I, 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 $12,027.16 plus interest of $.00 at the rate of 0% less credits in the amount of $.00 totaling $12,027.16 as of May 16, 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 f my knowledge, information and belief. F T: Sworn to and Subscribed before me this U0 day of 2011 Notary Public P120 ???\\111 11111???? ??? ?1E \NqR ?i?i Qom: vO i0 .• 4; w i •,4b Q -Z? SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy -FILEO-OFFICE OF THE PFOTHONO IAR ' 2011 JUL I I AM 11: 21 Richard W Stewart Solicitor Barclays Bank Delaware vs. Donna S. Landis cj? CUMBERLAND COUNTY PENNSYLVANIA Case Number 2011-5081 SHERIFF'S RETURN OF SERVICE 07/07/2011 05:49 PM - Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on July 7, 2011 at 1749 hours, she served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Donna S. Landis, by making known unto herself personally, at 3507 Margo Road, Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $43.00 July 08, 2011 AMANDA COBAUGH, DEPU SO ANSWERS, RON R ANDERSON, SHERIFF !ci CourtysuHe She,.". (E?!eoSOft . InC. 2112111 GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 -yJ JOEL M. FLINK, ESQUIRE -vm v 2-rt Identification No.: 81894 T M Dr mF G- -a rn 1001 E. Hector Street, Ste 220 ?r?'- ' Conshohocken, PA 19428 -< 484/351-0500 -' ? -c, (.:)-n BARCLAYS BANK DELAWARE COURT OF COMMON PLEASw ,, ti.VNrt= CUMBERLAND COUNTY VS. DONNA S LANDIS DOCKET NO. : 11-5081 PRAECIPE FOR ENTRY OF JVDG MNT FOR NANT OF AN ANSWZR, ASSESSMNT OF DAMAGES VERIFICATION OF ADDRESS AND NON-MILITARY SERVICE TO THE PROTHONOTARY: 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: Principal $12,027.16 Less: Payments on Account ( $.00) Total: $12,027.16 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, DONNA S LANDIS, 3507 MARGO RD, CAMP HILL PA 17011-1544. 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. 3. The said defendant(s) is (are) not in the military service of the United States or otherwise within the coverage the Soldiers and Sailors Civil Relief Act and is (are) over 18 years of age. of $ I4.OD PDAIT1 Of WOR e,+?a?3x53 AND NOW, this day of f 2011 Judgment is entered in favor of the plaintiff(s) an against defendant(s) by default for want of an answer and damages assessed at the sum of $12,027.16 as per the above certification. Prothonotary GORDON & WEINBERG, P.C. BY: FREDE C I. WEINBERG, ESQUIRE JOEL F NK, ESQUIRE Attorn for Plaintiff 2112111 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. DONNA S LANDIS 3507 MARGO RD CAMP HILL PA 17011-1544 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 11-5081 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 Default $12,027.16 Money Judgment $ Judgment on Award of Arbitrators$ Judgment on Verdict$ IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL ATTORNEYS: FREDERIC I. WEINBERG OR JJOEM . FLINK, ESQUIRES AT IS TELEPHONE NUMBER: 484/351-0500 PROTHON 2112111 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. : 11-5081 DONNA S LANDIS TO/PARA NOTICE OF INTENTION TO TARE DEFAULT DONNA S LANDIS 3507 MARGO RD CAMP HILL PA 17011-1544 DATE OF NOTICE/FECHA DEL AVISO: July 28, 2011 114PORTANT NOTICE YOU ARE IN DEFAULT BECAUSE 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 SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO 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 REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 GORDON & WEINBERG, P.C. BY. FREDERIC I.. WEINBERG, ESQUIRE JOEL M. FLINK, ESQUIRE P10D-2 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 11-5081 Civil CIVIL ACTION -- LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due BARCLAYS BANK DELAWARE, Plaintiff (s) From DONNA S. LANDIS, 3507 MARGO ROAD, CAMP HILL, PA 17011 (I) You are directed to levy upon the property of the defendant (s)and to sell (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: PNC BANK, 105 NOBLE BLVD., CARLISLE, PA 17013 and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $12,027.16 Interest Atty's Comm % Atty Paid $180.50 Plaintiff Paid Date: 4/26/12 (Seal) L.L. $.50 Due Prothy $2.25 Other Costs David D. Buell, Prothonotary Deputy REQUESTING PARTY: Name FREDERICK 1. WEINBERG, ESQUIRE Address: GORDON & WEINBERG, P.C. 1001 E. HECTOR STREET, SUITE 220 CONSHOHOCKEN, PA 1.9428 Attorney for: PLAINTIFF Telephone: 484-351-0500 Supreme Court ID No. 41360 GORDON & WEINBER.G, 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 defendant(s)and garnishee(s) $12,027.16 $.00 BARCLAYS BANK DELAWARE 125 S. West Street Wilmington, DE 19801 Vs. DONNA S LANDIS 3507 MARGO RD CAMP HILL PA 17011-1544 and PNC BANK. 105 NOBLE BLVD CARLISLE PA 17013 GARNISHEE TO THE PROTHONOTARY: vw r ? ??(3t. YL V4, COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 11-5081 PRAECIPE FOR WRIT OF EXECUTION Issue writ of execution in the above matter, directed to the Sheriff of Cumberland County; (1) against DONNA S LANDIS (2) against PNC SANK (3) AMOUNT DUE INTEREST from August 15, 2011 COSTS Prothonotary fee Sheriff fee (4) Less: Payments on Account TOTAL DqXX 14?3) ? . a" 14 ? - 3. oo C6 1.2.00 , 114. oo U 4t a' Sso f? 2112111 ( $.00) FREDERIC I. INB RG, ESQUIRE JOEL M. FLINK, QUIRE Attorney for Plaintiff #.2.z s 00 OL 4 Was SHERIFF'S OFFICE OF CUMBERLAND COUNTING -? M MM i= Ronny R Anderson err-`- ,-?? Sheriff r" - Jody S Smith yam; ? ?; cam- Chief Deputy c 3 C) - ? rte, c Richard W Stewart Solicitor OFF C-' OF - ;" RIFF C, -w, Barclays Bank Delaware Case N umber vs. 2011- 5081 Donna S. Landis SHERIFF'S RETURN OF SERVICE 05/03/2012 12:29 PM - Shawn Harrison, Deputy, who being duly sworn according to law, states that on May 3, 2012 at 1226 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Donna S. Landis, in the hands, possession, or control of the within named garnishee, PNC Bank, 105 Noble Boulevard, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Susan Casale, Financial Sales consultant personally three copies of interrogatories together witt three true and attested copies of the writ of execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on May 8, 2012 to Donna S. Landis at 3507Margc Road, Camp Hill, PA 17011-1544. SO ANSWERS, May 08, 2012 , SHERIFF wn Napfison, Deputy (ci GountySutte Shenfr. Teleosoft. Inc. 2112111 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 F a y .. W 12 fU] pff U11 ERLANO C0UNT PENNSYLVANIA BARCLAYS BANK DELAWARE VS. DONNA S LANDIS and PNC Bank Garnishee COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 11-5081 PRAECIPE TO DISSOLVE ATTACHMENT TO THE PROTHONOTARY: Kindly dissolve the attachment of the defendant's bank account with PNC Bank, as Garnishee in the above entitled matter. GORDON & WEINBERG, P.C. BY: FREDERI I. INBERG, ESQUIRE JOEL M. K, ESQUIRE Attorney for Plaintiff Poll Qy?y s?i.5opd Q? Ckkt ?1? la 11 L a-,?s9s