HomeMy WebLinkAbout06-0058
I
NC007740
THIS IS AN ARBITRATION MATTER. ASSESSMENT OF
DAMAGES HEARING REQUIRED.
GORDON & WEINBERG, P.C.
BY: FREDERIC I. WEINBERG, ESQUIRE
Identification No.: 41360
PAUL M. SCHOFIELD, JR., ESQUIRE
Identification No.: 81894
21 SOUTH 21ST STREET
PHILADELPHIA, PA 19103
215/988-9600
AMERICAN EXPRESS
RISK INFORMATION & BANKIN
NEW YORK, NY 10285--441
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
vs.
DOCKET NO.
o!- - ~p
C?1~JT tfl.~
EUGENE NELSON
75 MARE RD
CARLISLE PA 17013
and
DAWN NELSON
75 MARE RD
CARLISLE PA 17013-0000
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 TvlENTY (20) DAYS AFTER
THIS COMPLAINT AND NOTICE ARE SERVED, BY ENTERING A WRITTEN A,PPEARANCE 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
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.
4. All the credits to which the defendant(s)is entitled have
been applied and there remains a balance due in the amount of
$1,801.55.
5. Plaintiff has made demand upon the defendant(s)for
payment of the balance due of $1,801.55 but the defendant(s)has
failed and refused and still refuses to pay the same or any part
thereof.
WHEREFORE, plaintiff claims of the defendant (s) the sum of
$1,801.55 at the rate of 0% from the date of September 16, 2003,
I
together with costs and attorney fees.
GORDON & WEINBERG, P.C.
BY:
FREDERIC I. WG, ESQUIRE
PAUL M. SCHOF ,JR., ESQUIRE
Attorney for Plaintiff
POlE
~
VERIFICATION
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.
INBE~, ESQUIRE
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SHERIFF'S RETURN - REGULAR
CASE NO: 2006-00058 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
AMERICAN EXPRESS RISK INFORMAT
VS
NELSON EUGENE ET AL
DOUGLAS RUZANSKI
Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE
was served upon
NELSON EUGENE
the
DEFENDANT
at 1515:00 HOURS, on the 20th day of January
2006
at 75 MARE ROAD
CARLISLE, PA 17013
by handing to
EUGENE NELSON
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
Service
Affidavit
Surcharge
So Answers:
18.00
6.16
.00
10.00
.00
34.16
",-/.,'-f' ,.;:./~
-? ~..,J~"; - "-__'-',,'~ ,P ~/'-d
7 ,/;...~;:.~:)"__t--:;>:r:.."_',.__,,. .'1" ...-t_~
R. Thomas Kline !
A.D.
01/23/2006
GORDON & WEINBER~//
By: I.
~{A
Dep(J
Sworn and Subscribed to before
me this )..(" ~
day of
..
SHERIFF'S RETURN - NOT FOUND
CASE NO: 2006-00058 P
COMMONTWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
AMERICAN EXPRESS RISK INFORMAT
VS
NELSON EUGENE ET AL
R. Thomas Kline ,Sheriff or Deputy Sheriff, who being
duly sworn according to law, says, that he made a diligent search and
inquiry for the within named DEFENDANT
NELSON DAWN
but was
unable to locate Her in his bailiwick. He therefore returns the
COMPLAINT & NOTICE
, NOT FOUND , as to
the within named DEFENDANT
, NELSON DAWN
75 MARE ROAD
CARLISLE, PA 17013
DEFENDANTS ARE DIVORCED. EUGENE IS NOT SURE
WHERE DAWN LIVES.
Sheriff's Costs:
Docketing
Service
Not Found
Surcharge
6.00
.00
5.00
10.00
.00
21.00
so~
:::~
~ ~
R. Thomas Kline
Sheriff of Cumberland County
GORDON & WEINBERG
01/23/2006
Sworn and subscribed to before me
this
.;1.l.L
day of M
'"'"tAD "
Pr h~
,
.
GORDON & WEINBERG, P.C.
BY: FREDERIC I. WEINBERG, ESQUIRE
Identification No.: 41360
PAUL M. SCHOFIELD, JR., ESQUIRE
Identification No.: 81894
21 SOUTH 21ST STREET
PHILADELPHIA, PA 19103
215/988-9600
AMERICAN EXPRESS
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
vs.
DOCKET NO.
06-58 CIVIL
EUGENE NELSON
and
DAWN NELSON
PRAECIPE FOR JUDGMENT
The Prothonotary will please enter Judgment in the above matter
by default for want of an answer against the Defendant, EUGENE NELSON,
and assesses the damages as per statement below.
FREDERIC I. WE , ESQUIRE
PAUL M. SCHOFI ,JR., ESQUIRE:
Attorney for Plaintiff
Principal
Interest from December 9, 2004
@O%
Total:
$1,801.55
$ .00
$1,801. 55
I hereby certify that written notice of the intention to file
this Praecipe was mailed or delivered to the parties against whom
judgment is to be entered and to his attorney of record, if any, after
the default occurred and at least ten (10) days prior to the date of
the filing of this Praecipe. ~
FREDERIC I. WE G, ESQUIRE
PAUL M. SCHOFIELD, JR., ESQUIRE
Attorney for Plaintiff
Filed:
By the Prothonotary:
AND NOW, this .-J.0cl day of fYl ~Ji? r ~ , 200b Judgment
is entered in favor of the p1aintiff(s) and against defendant, for
want of an answer and damages assessed at the ~~m of , $1,801.55 as
per the above certification. /
Prothon
.
,
NC007740
GORDON & WEINBERG, P.C.
BY: FREDERIC I. WEINBERG,
Identification No.:
PAUL M. SCHOFIELD, JR.,
Identification No.:
21 SOUTH 21ST STREET
PHILADELPHIA, PA 19103
215/988-9600
ESQUIRE
41360
ESQUIRE
81894
AMERICAN EXPRESS
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
Vs.
DOCKET NO.
06--58 CIVIL
EUGENE NELSON
and
DAWN NELSON
NOTICE OF INTENTION TO TAKE DEFAULT
TO/PARA
EUGENE NELSON
75 MARE RD
CARLISLE PA 17013
DATE OF NOTICE/FECHA DEL AVISO:
February 10, 2006
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 J~Y BE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFE:< 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
PAUL M. SC
G, ESQUIRE
JR., ESQUIRE
P10D-2
.
GORDON & WEINBERG, P.C.
BY: FREDERIC I. WEINBERG, ESQUIRE
Identification No.: 41360
PAUL M. SCHOFIELD, JR., ESQUIRE
Identification No.: 81894
21 SOUTH 21ST STREET
PHILADELPHIA, PA 19103
215/988-9600
AMERICAN EXPRESS
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
vs.
DOCKET NO.
06-58 CIVIL
EUGENE NELSON
and
DAWN NELSON
CERTIFICATION OF ADDRESS
I hereby certify that the precise residence of the holder of the
within judgment is; AMERICAN EXPRESS
and that the last known
address of defendant, EUGENE NELSON, 75 MARE RD, CARLISLE PA 17013.
GORDON & WEINBERG, P.C.
BY:
-
FREDERI
PAUL M.
Attorney
INBERG, ESQUIRE
FIELD, JR. ,ESQUIRE
for Plaintiff
GORDON & WEINBERG, P.C.
BY: FREDERIC I. WEINBERG, ESQUIRE
Identification No.: 41360
PAUL M. SCHOFIELD, JR., ESQUIRE
Identification No.: 81894
21 SOUTH 21ST STREET
PHILADELPHIA, PA 19103
215/988-9600
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
AMERICAN EXPRESS
vs.
DOCKET NO.
06-58 CIVIL
EUGENE NELSON
and
DAWN NELSON
AFFIDAVIT OF NON-MILITARY SERVICE
FREDERIC I. WEINBERG, ESQUIRE, being duly sworn according to law,
deposes and says that he represents the plaintiff in the above-
entitled case; that he is authorized to make this affidavit on behalf
of the plaintiff; and that the above-named defendant is over twenty-
one years of age; that the address of the defendant is, 75 MARE RD,
CARLISLE PA 17013; that the occupation of the defendant is unknown;
and that the defendant is not in the Military Service of the United
States, nor any State or Territory thereof or its allies as defined in
the Soldiers' and Sailors' Civil Relief Act of 1940 and the amendments
thereto.
Sworn to and Subscribed
- c/cA
Before me this c! Day
~.o2;:-
Notary Public
COMMONWEALTH OF PENNSVLVANIA
NOTARIAL SEAL .
CHRISTINE M, COLON, NDtary Public
City bf Philadelphia, Phlla. Cour~ 2000
'"" Q .
M .-
.~
FREDERIC I. ~~ ESQUIRE
PAUL M. SCHOFIELD, JR. ESQUIRE
Attorney for Plaintiff
.
GORDON & WEINBERG, P.C.
BY: FREDERIC I. WEINBERG, ESQUIRE
Identification No.: 41360
PAUL M. SCHOFIELD, JR., ESQUIRE
Identification No.: 81894
21 SOUTH 21ST STREET
PHILADELPHIA, PA 19103
215/988-9600
AMERICAN EXPRESS
vs.
EUGENE NELSON
and
DAWN NELSON
NOTICE
NC007740
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
DOCKET NO.
06-58 CIVIL
PURSUANT TO RULE 236 OF THE SUPREME COURT OF PENNSYLVANIA, YOU ARE
HEREBY NOTIFIED THAT A JUDGMENT BY DEFAULT HAS BEEN ENTERED AGAINST
YOU IN THE ABOVE PROCEEDING IN THE AMOUNT OF $1,801.55. IF YOU HAVE
ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL GORDON & WEINBERG,
P.C. AT 215/988-9600.
GORDON & WEINBERG, P.C.
BY:
Dated:
February 22, 2006
FREDERIC
PAUL M.
Attorney
WE~BERG, ESQUIRE
LD, JR. ,ESQUIRE
for Plaintiff
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