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Home My WebLink About11-50822112123 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 r FILED-OFFICE 1g?Fvq1F24 017 u BARCLAYS BANK DELAWARE 125 S. West Street Wilmington, DE 19801 Vs. NICOLE E LANDRY 3810 MOUNTAIN VIEW RD MECHANICSBURG PA 17050-2130 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. - Soa"I", 01 U l 1.??2.''?'? 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 9 q? IL,44,f ce 11,5LI? 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 June 3, 2011 in the amount of $2,296.72. 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 4/15/2010. WHEREFORE, plaintiff claims of the defendant(s) the sum of $2,296.72 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDERIC I. WLR-$ERG, ESQUIRE JOEL M. FLINK, ESQUIRE Attorney for Plaintiff 2112123 BARCLAYS BANK DELAWARE NICOLE E LANDRY 5140218898345317 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. r N . EXHIBIT "A" NICOLE E LANDRY 5140218898345317 State of Delaware § County of New Castle § 2112123 BARCLAYS BANK DELAWARE 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 $2,296.72 plus interest of $.00 at the rate of 0% less credits in the amount of $.00 totaling $2,296.72 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 bes f my knowledge, information and belief. AF AN : Sworn to and Subscribed before me this 7 CA day of -PA LA , 2011 61)11 Iq Notary Public P120 oW i l two// ?V GOMMIS`4i ••y < g pMES Z pE . 30.20V SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor D-OMOhr IWE 20,1 JUL 26 APB 6: LI CUIMBERLANO CGL i .x PDWYLVAN1A Barclays Bank Delaware vs. Case Number Nicole E. Landry 2011-5082 SHERIFF'S RETURN OF SERVICE 07/20/2011 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that on July 20, 2011 at 0840 hours, he was unable to serve a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Nicole E. Landry. After several attempts the Complaint and Notice has expired. SHERIFF COST: $68.00 SO ANSWERS, July 20, 2011 RON R ANDERSON, SHERIFF CCLIP',- -r. tE ntt Inc. i yI. 7ri-pw.i (7. 2112123 its"t t GORDON & WEINBERG, P.C. 2013 MAR PM 2: 4 ty BY: FREDERIC I . WEINBERG, ESQUIRE �$ � Identification No. : 41360E �5r�G COUNTY AP11A 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. : 11-5082 NICOLE E LANDRY PRAECIPE TO WITSDRAN COMPLAINT TO THE PROTHONOTARY: Kindly withdraw the above-captioned action, without prejudice. GORDON & WEINBERG, P.C. BY: FREDERIC I . NBERG, ESQUIRE JOEL M. FLIN , ESQUIRE Attorney for Plaintiff P006 CERTIFICATION OF SERVICE I, FREDERIC I . WEINBERG, ESQUIRE, hereby certify that I, on the date below, served a copy of the Praecipe to Withdraw Complaint to Pa.R.C. P. 1028 (c) (1) , via First Class Mail, postage pre-paid, to all other parties or their counsel of record. FREDEikEliVEINBERG, ESQUIRE Dated