HomeMy WebLinkAbout12-35092123794
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 -0;7
1001 E. Hector Street, Ste 220
77
Conshohocken, PA 19428'
484/351-0500
BARCLAYS BANK DELAWARE COURT OF COMMON PLEAS -`?
125 S. West Street CUMBERLAND COUNTY t
Wilmington, DE 19801
vs. DOCKET NO. . /pl - -x" Oivd-Prm
MARK J CARSON
622 MILL RACE CT
CARLISLE PA 17013-2531
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
OS
411,15 PO p'fT?
C# 11651
0'a-7 1, / (?
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
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 5/23/12 in the
amount of $1,827.03.
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 2/25/2011.
WHEREFORE, plaintiff claims of the defendant(s) the sum of
$1,827.03 plus applicable costs, interest and attorney's fees.
GORDON & WEINBERG, P.C.
BY:
FREDERIC . VEINBERG, ESQUIRE
JOEL M. IESQUIRE
Attorney or Plaintiff
2123794
BARCLAYS BANK DELAWARE
MARK J CARSON
5140218009927763
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.
I 'A"
I - X;?
NNAME: NJ
2123794
BARCLAYS BANK DELAWARE
MARK J CARSON
5140218009927763
State of Delaware §
County of New Castle §
AFFIDAVIT
I, fX.'eAle jF_ ??iC61 GC#j 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
$1,827.03 less credits in the amount of $.00 totaling $1,827.03 as of April 6,
2012.
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 ?? day
of 12
Notary Public
P120
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SHERIFF'S OFFICE OF CUMBERLAND COUNT';
Ronny R Anderson = T
Sheriff "--
Jody S Smith _-
Chief Deputy '
Richard W Stewart
Solicitor OFF CE n: T>~ S-rRIFr
Barclays Bank Delaware
vs.
Mark J. Carson
Case Number
2012-3509
SHERIFF'S RETURN OF SERVICE
06/07/2012 07:30 PM - Michael Barrick, Deputy Sheriff, who being duly sworn according to law, state's that on June 7,
2012 at 1930 hours, he served a true copy of the within Complaint and Notice, upon the Within named
defendant, to wit: Mark J. Carson, by making known unto Melissa Katsifis, adult in charge at 622 Mill Race
Court, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to her
personally the said true and correct copy of the same.
A ABARRICICK, DEPUTY
SHERIFF COST: $34.00
June 08, 2012
SO ANSWERS,
(;" Y. 2x??
RON R ANDERSON, SHERIFF
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