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Home My WebLink About12-09452121914 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 ' 1 'U3 - r 1001 E. Hector Street, Ste 220 -- Conshohocken, PA 19428 f- p --? 484/351-0500 , BARCLAYS BANK DELAWARE COURT OF COMMON PLEAS ;y.. 125 S. West Street CUMBERLAND COUNTY Wilmington, DE 19801 avviFRM VS. DOCKET NO. Jot - Qq,5 ANGELA L ANDY 207 E CLEARVIEW DR CAMP HILL PA 17011-4011 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 G ?1a3.'I5 P? ATr/ ,2 01001 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 merchandise 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 statements or Affidavit of Account, if available, is attached hereto made part hereof and marked 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 February 1, 2012 in the amount of $2,899.65. 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 1/21/2011. WHEREFORE, plaintiff claims of the defendant(s) the sum of $2,899.65 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY FREDERIC _- EINBERG, ESQUIRE JOEL M. FLINK, ESQUIRE Attorney for Plaintiff P01A 2121914 BARCLAYS BANK DELAWARE ANGELA L ANDY 5140218899165136 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. EXHIBIT "A" 2121914 BARCLAYS BANK DELAWARE ANGELA L ANDY 5140218899165136 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 $2,899.65 plus interest of $.00 at the rate of 0% less credits in the amount of $.00 totaling $2,899.65 as of 1/12/12. 5. If called upon, affiant can testify at trial aso the facts pertaining to this matter. 7 \ The above facts are true and correct to the best of my. I knowledge, information and belief. r AF IANT: Sworn to and Subscribed before me this day of 2012 otary Public P120 ????11111i11?/1 PF, If 0 AA 'C A)ii y 110 ?"?r/?? of ?°C`...;'''d"`?e•'+' _. , SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ??an a of cvjntirr{,t r{d a. i 2012 FEB 27 AM B: 29, CUMBERLAND COUNTY PENNSYLVANIA Barclays Bank Delaware vs. Angela L. Andy Case Number 2012-945 SHERIFF'S RETURN OF SERVICE 02/16/2012 11:07 AM - Ronald Hoover, Deputy Sheriff, who being duly sworn according to law, states that on February 16, 2012 at 1107 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Angela L. Andy, by making known unto herself personally, at 207 E. Clearview Drive, 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: $43.00 February 23, 2012 RONALD HOOVER, DEPUTY SO ANSWERS, RON R ANDERSON, SHERIFF ?ci Couriy5ulte b!?e?i$ ie?,?osr°;?.Inc. 2121914 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. ANGELA L ANDY C-- cr, C?' ' e T7 T-3 _ rv 4_ ...0 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 12-945 CIVIL TERM PRAECIPE FOR ENTRY OF JUDGMMT FOR PANT OF AN ANSWER ASSESSMENT 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) ANGELA L ANDY above named only and assess damages certified to be calculable as a sum certain from the complaint, as follows: Principal Interest from 07/28/2011 @0% Costs (Complaint & Service) Less: Payment on Account Total: $2,899.65 $.00 $146.75 ( $1,000.00) $2,046.40 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, ANGELA L ANDY, 207 E CLEARVIEW DR, CAMP HILL PA 17011-4011. 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. 110.50 P A A 7T1 ??`I fo39q 2,0 413 'IS-(v NAee k.6it d . , 3. 111. 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. AND NOW, this 64 day of ADM- I , 2012 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 of , $2,046.40 as per the above certifica on. ORA Prothonotary GORDON & WEINBE BY: FREDERIC I. WE NB G, ESQUIRE JOEL M. FLINK, QUIRE Attorney for Plaintiff 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 2121914 BARCLAYS BANK DELAWARE COURT OF COMMON PLEAS CUMBERLAND COUNTY ANGELA L ANDY TO/PARA vs. DOCKET NO. : 12-945 CIVIL TERM NOTICE OF INTENTION TO TAKE DEFAULT ANGELA L ANDY 207 E CLEARVIEW DR CAMP HILL PA 17011-4011 DATE OF NOTICE/FECHA DEL AVISO: March 8, 2012 IMPORTANT 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: Q FREDERIC I. W P10 NBERG, ESQUIRE JOEL M. FLIN ESQUIRE D-2 i` 2121914 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. : 12-945 CIVIL TERM ANGELA L ANDY 207 E CLEARVIEW DR CAMP HILL PA 17011-4011 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. LXL Judgment by Default $2,046.40 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 JOEL FL K, E UIRES AT T S TELEPHONE NUMBER: 484/351-0500 PROTHONOTARY