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06-1328
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION GREAT SENECA FINANCIAL CORP. A MARYLAND CORPORATION Assignee of MERCHANT MANAGEMENT Assignee of CHASE Plaintiff vs. TIM J. PANAGOS Defendant ARBITRATION DOCKET NO. Ct. - /3;v Hearing NOTICE TO DEFEND 1U ? 21 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 judgment 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. LAWYER REFERRAL SERVICE - CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDORD STREET CARLISLE, PA 17013 (717) 249-3166 / (800) 990-9108 HEARING NOTICE YOU HAVE BEEN SUED IN COURT. The above Notice to Defend explains what you must do to dispute the claims made against you. If you file the written response referred to in the Notice to Defend, a hearing before a board of arbitrators will take place in Room of the Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania, on at 9:00 am. IF YOU FAIL TO FILE THE RESPONSE DESCRIBED IN THE NOTICE TO DEFEND, A JUDGMENT FOR THE AMOUNT CLAIMED IN THE COMPLAINT MAY BE ENTERED AGAINST YOU BEFORE THE HEARING. DUTY TO APPEAR AT ARBITRATION HEARING If one or more of the Parties is not present at the hearing, THE MATTER MAY BE HEARD AT THE SAME TIME AND DATE BEFORE A JUDGE OF THE COURT WITHOUT THE ABSENT PARTY OR PARTIES. THERE IS NO RIGHT TO A TRIAL DE NOVO ON APPEAL FROM A DECISION ENTERED BY A JUDGE. NOTICE: YOU MUST RESPOND TO THIS COMPLAINT WITHIN TWENTY (20) DAYS OR A JUDGMENT FOR THE AMOUNT CLAIMED MAY BE ENTERED AGAINST YOU BEFORE THE HEARING. IF ONE OR MORE OF THE PARTIES IS NOT PRESENT AT THE HEARING, THE MATTER MAY BE HEARD IMMEDIATELY BEFORE A JUDGE WITHOUT THE ABSENT PARTY OR PARTIES. THERE IS NO RIGHT TO A TRIAL DE NOVO ON APPEAL FROM A DECISION ENTERED BY A JUDGE. EN LA CORTE DE ALEGATCS CC),AUN DEL CONDADO DE CUMBERLAND, PENNSYLVANIA GREAT SENECA FINANCIAL CORP. A MARYLAND CORPORATION Assignee of MERCHANT MANAGEMENT Assignee of CHASE Plaintiff NO, VS. CIVIL ACTION - LAW TIM J. PANAGOS Defendant NOTICIA USTED HA SIDO DEMANDADO/A EN LA CORTE. Si usted desea defender conta la demanda puestas en las siguientes paginas, usted tienen que tomar acci6n dentro veinte (20) dial despu6s que esta Demanda y Aviso es servido, con entrando por escrito una aparencia personalmente o por un abogado y archivando por escrito con la Corte sus defensas o objeciones a las demandas puestas en esta contra usted. Usted es advertido que si falla de hacerlo el caso puede proceder sin usted y un juzgamiento puede ser entrado conta usted por la Corte sin mas aviso por cualquier dinero reclamado en la Demanda o por cualquier otro reclamo o alivio solicitado por Demandante. Usted puede perder dinero o propiedad o otros derechosimportante para usted. USTED DEBE LLEVAR ESTE PAPEL A SU ABOGADO ENSEGUIDA. SI USTED NO TIENE UN ABOGADO, VAYA O LLAME POR TELEFONO LA OFICINA FIJADA AQUI ABAJO. ESTA OFICINA PUEDE PROVEERE CON INFORMACION DE COMO CONSEGUIR UN ABOGADO. SI USTED NO PUEDE PAGARLF A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS. QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS. SERVICIO DE REFERIDO A ABOGADO COLEGIO DE ABOGADOS DEL CONDADO DE LEHIGH ABOGACIA DEL CONDADO DE CUMBERLAND Cumberland County Bar Association 32 South Bedford Street Carlisle, Pa 17013 717-249-3166 LAW OWRCES WOLPOFF & ABRAMSON, L.L.P. ATTORNEYS IN TOP PRACTICE OF DEBT COLLECTION 4660 TRINDLE ROAD THIRD FLOOR CAMP HILL, PA 17011 717-303-6700 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREAT SENECA FINANCIAL CORP. A MARYLAND CORPORATION Assignee of MERCHANT MANAGEMENT Assignee of CHASE Plaintiff NO. C) - 13 a,? l [ UC vs. TIM J. PANAGOS Defendant CIVIL ACTION - LAW COMPLAINT AND NOW, TO WIT, comes the Petitioner/Plaintiff, GREAT SENECA LAW OFFICES WOLPOFF & ABRAMSON, L.L.P. ATTORNEYS INTHE PRACT/CE OFDEBTCOLLECTION 4660TRINDLE ROAD THIRD FLOOR CAMP HILL, PA 17011 717-303-6700 FINANCIAL CORP., A MARYLAND CORPORATION, Assignee of MERCHANT MANAGEMENT, Assignee of CHASE, by and through its attorneys, and the law firm of Wolpoff & Abramson, LLP, and hereby avers as follows: 1. Plaintiff, GREAT SENECA FINANCIAL CORP., A MARYLAND CORPORATION, Assignee of MERCHANT MANAGEMENT, Assignee of CHASE, is a corporation doing business within the Commonwealth of Pennsylvania, and the other states of the United States, with its principal place of business situated at P.O. BOX 1651, ROCKVILLE, MD 20849. 2. Defendant, TIM J. PANAGOS, is an adult individual with a last known address of 100 EAST KING ST., SHIPPENSBURG, CUMBERLAND County, PA 17257. 3. It is averred that Defendant was issued an open ended credit account by Plaintiff's assignor (hereinafter "Account"). 4. Defendant, by using the Account, agreed to pay Plaintiff for all charges made to the Account. 5. At all relevant times material hereto, Defendant has been a regular user of said Account for the purchase of products, goods and/or for obtaining services and/or funds. 6. Defendant has been provided with copies of statements accurately showing all debits and credits for transactions on the aforementioned Account. 7. Defendant did not ob ec! kc :!1c. aoove-mentioned statements submitted by Plaintiff and/or its assignors to Defendant. True and correct copies of the monthly statements are attached herein as Exhibit "A" and incorporated by reference as if set forth in full below. 8. As of the date of filing the within Complaint, the principal due and payable by Defendant to Plaintiff as a result of charges made by said Defendant and/or any authorized users is the sum of Two Thousand Seven Hundred Twenty-Four Dollars and Seventy-Seven Cents, ($2,724.77). 9- The amount of pre-judgment interest which has accrued from the charge off date is the sum of One Thousand Six Hundred Sixteen Dollars and Fifty Cents, ($1,616.50). 10. Despite reasonable and repeated demands for payment, Defendant has failed, refused and continues to refuse to pay all sums due and owing on the aforementioned Account to the detriment of Plaintiff. 11. Plaintiff has retained the services of the law firm of Wolpoff & Abramson, L.L.P. in the collection of the amount due from Defendant. 12. As of the filing of this Complaint, Plaintiff has incurred reasonable attorneys' fees in the amount of Five Hundred Forty-Four Dollars and Ninety-Five Cents, ($544.95) in the collection of the amounts due from Defendant. Plaintiff shall continue to incur such attorneys' fees throughout the conclusion of this proceeding. 13. Plaintiff performed any and all conditions precedent to the bringing of this action, 14. The amount in controversy is within the jurisdictional amount requiring compulsory arbitration. LAW OFFICES WOLPOFF & ABRAMSON, L.L.P. ATTORNEYS IN THE PRACTICE OFDEBTCOLLECTION 4 60TRINDLE ROAD THIRD FLOOR CAMP HILL, PA 17011 717-303-6700 WHEREFORE, Plaintiff GREAT SENECA FINANCIAL CORP. A MARYLAND CORPORATION, Assignee of MERCHANT MANAGEMENT, Assignee of CHASE , respectfully requests this Honorable Court enterjudgment in its favor and against Defendant TIM J. PANAGOS for Two Thousand Seven Hundred Twenty-Four Dollars and Seventy-Seven Cents, ($2,724.77) plus pre-judgment interest in the amount of One Thousand Six Hundred Sixteen Dollars and Fifty Cents, ($1,616.50), collection and attorneys' fees in the amount of Five Hundred Forty-Four Dollars and Ninety-Five Cents, ($544.95), costs of suit and such other relief as the Court deems proper and just. Respectfully submitted, au Amy F. Doyle #87062 Daniel F. Wolfson #20617 Philip C. Warholic #86341 Andrew C. Spears #87737 David R. Galloway #87326 Tonilyn M. Chippie #87852 Sarah E. Ehasz #86469 Robert N. Polas, Jr. #201259 Ronald M. Abramson #94266 Ronald S. Canter #94000 Bruce H. Cherkis #18837 WOLPOFF & ABRAMSON, LLP Attorneys in the Practice of Debt Collection 4660 Trindle Rd., 3`d Floor Camp Hill, PA 17011 (717) 303-6700 LAW OFWCES WOLPOFF & ABRAMSON, L.L.P. ATTORNEYS 1NTH£ PRACTICE' OF DEBT COIL CPION 46W TRINDLE ROAD THIRD FLOOR CAMP HILL, PA 17011 717-303-6700 VLMFICATION The undersigned hereby states that he/she is the attorney for Plaintiff, GREAT SENECA FINANCIAL CORP.. A MARYLAND CORPORATION, Assignee of MERCHANT MANAGEMENT, Assignee of CHASE, who is located outside of this jurisdiction and in order to file the within document in an expedient and timely manner, he/she is authorized to execute this verification on behalf of said Plaintiff in the within action and verifies that the statements made in the foregoing Complaint are true and correct to the best of his/her knowledge, information, and belief. based upon information provided by the Plaintiff. The undersigned understands that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904, relating to unswom falsification to authorities. Amy F. Doyle #87062 Daniel F. Wolfson #20617 Philip C. Warholic #86341 Andrew C. Spears #87737 David R. Galloway #87326 Tonilyn M. Chippie #87852 Sarah E. Ehasz #86469 Robert N. Polas, Jr. #201259 Ronald M. Abramson #94266 Ronald S. Canter #94000 Bruce H. Cherkis #18837 WOLPOFF & ABRAMSON, LLP Attorneys in the Practice of Debt Collection 4660 Trindle Rd., 3`d Floor Camp Hill, PA 17011 (717) 303-6700 LAW OF 1CFS WOLPOFF & ABRAMSON, ELY.. ATTORNEYS INTNE PRACTICE OFDFBTCOLLECTION J 60TRINDLE ROAD THIRD FLOOR CAMP HILL, PA 17011 717-303-6700 LAW OFFICES WOLPOPF & ABRAMSON, L.L.P. ATTORNEYS INTNE PRACTICE OF DEBT COELECTION C 60TRINDLE ROAD THIRD FLOOR EXHIBIT "A" CAMP HILL, PA 17011 717-303-6700 . Page 1 of 14 PAYMENT DUE DATE NEW BALANCE MINIMUM DUE 121072001 $2,199.40 I $424.40 Feb 70 ?006 ACCOUNT NUMBER: 4226 6106 5386 9152 Facsimile` TIM J PANAGOS oxc 100 E KING ST SHIPPENSBURG PA 17257-1326 Copy 10 CHASE Chace Viaa- ACCOUNT NUMBER: 4226 6106 53116 9152 NEW PAYMENT TOTAL TOTAL STATEMENT BALANCE DUE DATE CREDIT LINE AVAILABLE CREDIT CLOSING DATE $2,199.40 10720DI 12 $1.900 $0.00 11/132001 Here is vour Account Summary: TOTAL Previous Balance $2,101.75 (-) Payments, Credits 86 (+) Purchases, Cash, Debits 5800 (+) FINANCE CHARGES 40.51 (_) New Balance 2.199.40 Minimum Due 43.00 Past Due - Pay Immediately 82.00 Over Line - Pay Immediately 299.40 Minimum Payment Due $424.40 17o.w ara vnnr ('hnraae and Credits At A glance[ TRAN. DATE POST DATE REF. NO ?ESCRIP110N OF TRANSACTIONS CREDITS CHARGES 11111 11111 11 Claes Action Refund Credit .86 11113 11113 01/ERLIMIT FEE 28.00 LATE CHARGE - MIN PY1v17 NOT RECD BY DATE 29.00 Total of your credits and charges .86 58.00 YOU ARE TWO PAYMENTS PAST DUE. FAILURE TO PAY PROMPTLY COULD SERIOUSLY DAMAGE YOUR CREDIT RATING. IF YOU'VE ALREADY PAID-THANK YOU. Here's how we determined vom' Finance Charge*: Days in Billing Cycle: 29 NOMINAL DAILY AVERAGE PERIODICIMIN. TOTAL ANNUAL ANNUAL PERIODIC DAILY FINANCE FINANCE PERCENTAGE PERCENTAGE RATE BALANCE CHARGE CHARGE RATE RATE Cash 0.06573% $0.00 $0.00 $0.00 23.99% 0.00% Purchases 0.06573% $2.125.12 $40.51 $40.51 23.99% 23.99% Please see reverse side for balance computation method and other imponant mtormason. Questions about your account? Credit Card lost or stolen? Call Chase Customer Service 24 hours a Day, 7 days a vveek. tall-free, at 1-800-334-6350 or vrtie PO BOX 15919. WILMINGTON, DE 15850-5919. Para Servicio al Clicme en Espa5c4-800-545-0484. Page 1 of 1 6 , Peke 2 of 14 PAYMENT DUE DATE NEW BALANCE MINIMUM DUE 0110712002 I $2,301.30 I $572.30 Feb 10 7406 ACCOUNT NUMBER: 4226 6106 5386 9152 Facsimile TIM J PANAGOS 100 E KING ST SHIPPENSBURG PA 1 725 7-1 326 Copy O CHASE Chase vtsa- A000UNT NUM HER: 4226 6106 5386 9152 NEW BALANCE $2,301.30 PAYMENT DUE DATE 01/07/2002 TOTAL CREDIT LINE $1,900 TOTAL AVAILABLE CREDIT $0-00 STATEMENT CLOSING DATE 1211312001 Here is your Account Summary: TOTAL Previous Balance $2,199.40 (-) Payments, Credits 0.00 (t) Purchases. Cash, Dehlfs 5800 (.) FINANCE CHARGES 43.90 (_) New Balance 2.301.30 Mlnlmum Due 46.00 Past Due - Pay Immediately 125.00 Over Line - Pay Immediately 401 30 Minimum Payment Due $572.30 Here are your •.narges anu %_reuus at a gaauco: 12113 12113 OVERLIMIT FEE 29.00 LATE CHARGE - MIN PYMT NOT RECD BY DATE 29.00 Total of your credits and charges 0.00 58.00 YOUR ACCOUNT I$ SERIOUSLY DELINQUENT. WE WANT TO WORK WITH YOU TO RESOLVE THIS MATTER. CALL IMMEDIATELY TO DISCUSS YOUR PAYMENT OPTIONS. IMPORTANT MESSAGE ABOUT AN IMMEDIATE PHONE PAYMENT FEE. WE MAY IN OUR DISCRETION PERMIT YOU TO MAKE PAYMENTS BY AUTHORIZING US ON YOUR BEHALF TO TRANSFER FUNDS FROM A DEPOSIT OR OTHER ACCOUNT TO YOUR ACCOUNT. FOR EACH SUCH PAYMENT, YOU WILL BE CHARGED AN IMMEDIATE PHONE PAYMENT PROCESSING FEE OF $12. Here's how we determined your Finance Charge*- Days in Billing Cycle: 30 NOMINAL DAILY AVERAGE PERIODIC/MIN. TOTAL ANNUAL ANNUAL PERIODIC DAILY FINANCE FINANCE PERCENTAGE PERCENTAGE RATE BALANCE CHARGE CHARGE RATE RATE Cash 0.06573% $0.00 Y0.00 $0.00 23.99% 0.00% Purchases 0.06573% $2,226.30 $43.90 $43.90 23.99% 23.99% ' Please see reverse side for balance computation method and other important information. Questions about your account? Credit Card lost or stolen? Call Chase Customer Service 24 hours a Day, 7 days a week, toll-free, at 1-800-334-6350 or %,nte PO BOX 15919, WILMINGTON, DE 19850-5919. Para Servicio al Cliente en EspeRol:-800-545-0464. Page 1 of 1 .Pale 3of 14 Feb 10 2006 ACCOUNT NUMBER: 4226 6106 5386 9152 PAYMENT DUE DATE NEW BALANCE MINIMUM DUE 02/0812002 I $1,946.88 I $84.88 Facsimile TIM J PANAGOS 0565 100 E KING ST SHIPPENSBURG PA 17257-1326 Copy O CHASE Chase Vtsa- ACCOUNT NUMBER: 4 226 61116 53136 9152 NEW PAYMENT TOTAL TOTAL STATEMENT BALANCE DUE DATE CREDIT LINE AVAILABLE CREDIT CLOSING DATE E7 946.88 02/062002 $1,900 $0.00 011142002 Here is your Account Summary: TOTAL Previous Balance $2,301 30 (-) Payments, Credits 42500 (?) Purchases. Cash, Debits 2900 l FINANCE CHARGES 41.58 (_) NM Balance 1.94688 Minimum Due 35 DO Over Line - Pay Immediately 48.88 Minimum Payment Due $84.83 Here are your l,narttes HaU LfeLLIIS ALL a KlauCC: 0 y14I 01214 I XLP6 I OPAYMENT VERLIMIT FEE THANK YOU Total of your credits and charges JUST A REMINDER: YOUR ACCOUNT IS OVER ITS CREDIT LIMIT. PLEASE PAY NOW TO PROTECT YOUR CREDIT PRIVILEGES. IFYOU'VE ALREADY PAID-THANK YOU. NOTICE: CREDITS ON YOUR ACCOUNT (SUCH AS REFUNDS FOR STORE PURCHASES) WILL NOT BE APPLIED AS A PAYMENT. PLEASE MAKE AT LEASTYOUR REQUIRED MINIMUM PAYMENTTO AVOID LATE FEES AND OTHER CHARGES. ENROLL IN CHASE PAYMENT PROTECTOR PLAN TODAY. THE PLAN THAT HELPS PROTECT YOUR CREDIT RATING. 425.00 29.00 29.00 Here's how we determined your Finance Charge": Dale in Billing; Cycle: 32 NOMINAL DAILY AVERAGE PERIODICIMIN. TOTAL ANNUAL ANNUAL PERIODIC DAILY FINANCE FINANCE I PErROEMTAGE PERCENTAGE RATE BALANCE CHARGE CHARGE RATE RATE Cash 0.06573% $0.00 1-11 $0.00 23.99% D.110% Purchases 0.06573% $1,976.73 $41.58 $41.58 1 2399% 23.99% Please sce reverse side for balance computation method and other important information. Questions about your account? Credit Card lost or stolen? Call Chase Customer Service 24 hours a Day, 7 days a week, toll-free, at 1-800-441-7681 orwnte PO BOX 15919. WILMINGTON, DE 198512.5D19. Para Servicio al Cliento en Espahol:-800-545-0464. Page 1 of 1 i Page 4 .1 `14 Feb 10 2006 ACCOUNT NUMBER: 4226 6106 5386 9152 PAYMENT DUE DATE NEW BALANCE MINIMUM DUE 03/1 (Y2002 I $2.043.73 I $221.73 Facsimile TIM J PANAGOS osso 100 E KING ST SHIPPENSBURG PA 17257-1326 Copy ID CHASE Chace Ytsa- A000UNT NUMBER: 4226 6106 5386 9152 NEW PAYMENT TOTAL TOTAL STATEMENT BALANCE DUE DATE CREDIT LINE AVAILABLE CREDIT CLOSING DATE $2,043.73 03/702002 $1,900 $0.00 0211312002 Here is your Account Summary: TOTAL Previous Balance $1.946.68 (-) Payments, Credits D.DD (+) Purchases. Cash, Debits fia 00 (+) FINANCE CHARGES 38.85 (_) New Balance 2,043.73 Minimum Due 40,00 Past Due - Pay Immediately 35.00 Over Line - Pay Immediately 143.73 Minimum Payment Due $221.73 Here are your t.narges anu t 11 CUINS aL a 02;13 I 02113 I I LATE CHMARGEE MIN PYMT NOT RECD BY DATE I I 29.00 Total of your credits and charges 0.00 5800 YOUR ACCOUNT IS PRESENTLY PAST DUE. YOU MUST SEND PAYMENT TO AVOI D LOSING YOUR CREDIT PRIVILEGES. IF YOU'VE ALREADY PAID- THANKYOU. ENROLL IN CHASE PAYMENT PROTECTOR PLAN TODAY. THE PLAN THAT HELPS PROTECT YOUR CREDIT RATING. Here's how we determined your Finance Charge*: Days in Riving Cycle: 30 NOMINAL DAILY AVERAGE PERIODIClMIN. TOTAL ANNUAL ANNUAL PERIODIC DAILY FINANCE FINANCE I PE I PERCENTAGE RATE BALANCE CHARGE CHARGE RATE RATE Cash 0.06573% $0.00 $0.00 $0.00 23.99% 0.00% Purchases 0.06573% $1.970.38 $38.85 $30.&5 23.99% 23.99% Please see roverse side for balance computation method and other important information. Questions about your account? Credit Card lost or stolen? Call Chase Customer Service 24 hours a Day, 7 days a vreek, toll-free, at 1-800-441-7661 orvrtite PO BOX 15919. WILMINGTON, DE 19850-5919. Para Servicio at Cliente en Espanol:-800-545-0464. Page 1 of 1 r A . PKge 5 of 14 Feb 10 2006 ACCOUNT NUMBER: 4226 6106 5386 9152 PAYMENT DUE DATE NEW BALANCE MINIMUM DUE 0410712002 1 $2,139.73 I $359.73 Facsimile TIM J PANAGOS ma 100 E KING ST SHIPPENSBURG PA 17257-1326 Copy J CHASE Cnaswe Vill ACCOUNT NUMBER: 4226 6106 5386 9152 NEW PAYMENT TOTAL TOTAL STATEMENT BALANCE DUE DATE CREDIT LINE AVAILABLE CREDIT CLOSING DATE $2,139.73 n"72002 $1,900 $0-00 0311312002 Here is your Account Summary: TOTAL Previous Balance $2.043 73 (-) Payments, Credits 0.00 (+) Purchases, Cash, Debits 5H 00 (+) FINANCE CHARGES 38DO (_) New Balance 2.13973 Minimum Due 42.00 Past Due - Pay Immediately 78.00 Over Line - Pay Immediately 239.73 Minimum Payment Due $359.73 tiere are your l,Darges anU •.reulrs al a 03,113 03113 OVE RLIMIT FEE 29.00 LATE CHARGE - MIN PYMT NOT RECD BY DATE 29.00 Total of your credits and charges 0.00 58,00 YOU ARE TWO PAYMENTS PAST DUE. FAILURE TO PAY PROMPTLY COULD SERIOUSLY DAMAGE YOUR CREDIT RATING. IF YOU'VE ALREADY PAID-THANK YOU. Here's how we determined your Finance Charge": Da" in Billing Cycir, 28 NOMINAL DAILY AVERAGE PERIODICIMIN. TOTAL ANNUAL ANNUAL PERIODIC DAILY FINANCE FINANCE PERCENTAGE PERCENTAGE RATE BALANCE CHARGE CHARGE RATE RATE Cash 0.06573% $0.00 50-00 $0.00 23.99% 0.00% Purchases 0.06573% $2,065.07 $38.00 $38.00 23.99% 23.99% Please see reverse side for balance computation method and other important information. Questions about your account? Credit Card lost or stolen? Call Chase Customer Service 24 hours a Day, 7 days a vroek, toll-free, at 1-800-334-6350 or wito PO BOX 15919. WILMINGTON, DE 19850-5919. Para Servicio at Clierne en Espantll:-800-545-0464. Page 1 of 1 .. J P$ge6of14 Feb 10 2006 ACCOUNT NUMBER: 4226 6106 5386 9152 PAYMENT DUE DATE NEW BALANCE MINIMUM DUE 05106/2002 I $1,983.90 I $122-90 Facsimile TIM J PANAGOS 100 E KING ST SFIIPPENSBURG PA 1 725 7-1 326 Copy O CHASE Chase v1sa- ACCOUNT NUMBER: 4226 6106 5356 9152 NEW PAYMENT TOTAL TOTAL STATEMENT BALANCE DUE DATE CREDIT LINE AVAILABLE CREDIT CLOSING DATE $1,983.90 05106/2002 $1,900 $0-00 0411112002 Here is your Account Summary: TOTAL Previous Balance $2,139.73 (-) Payments, Credits 221.73 (+) Purchases, Cash. Doting 2900 (+) FINANCE CHARGES 36.90 (_) New Balance 1.983.90 Minimum Due 39.00 Over Line - Pay Immediately 83.90 Minimum Payment Due $122.90 here are your i-narges ana ii-real[s at a 03/14 041111 003/ 471 16G0W I OPAYMENT VERLIMIT FEEK YOU 221.73 Total of your credits and charges 221.73 JUST A REMINDER: YOUR ACCOUNT IS OVER ITS CREDIT LIMIT. PLEASE PAY NOW TO PROTECTYOUR CREDIT PRIVILEGES. IFYOU'VE ALREADY PAID-THANK YOU. ENROLL IN CHASE PAYMENT PROTECTOR PLAN TODAY. THE PLAN THAT HELPS PROTECT YOUR CREDIT RATING. 29.00 29.00 Here's how we determined your Finance Chal-L7I Days in Billing Cycle: 29 NOMINAL DAILY AVERAGE PERIODIC/MIN. TOTAL ANNUAL ANNUAL PERIODIC DAILY FINANCE FINANCE PERCENTAGE PERCENTAGE RATE BALANCE CHARGE CHARGE RATE RATE Cash 0.06573% $0.00 $0.00 $0.00 23.99% D.00% Purchases 006573% $1.935.75 $36.90 (36.90 23.99% 1 23.99% Please see reverse side for balance computation method and other important information. QueS5or s about your account? Credit Card lost or stolen? Call Chase Customer Service 24 hours a Day, 7 days a week, toll-free, at 1-800-441-7681 or write PO BOX 15919, W ILMINGTON, DE 19850-5919. Para Servlclo al ClieMe en Espado1r800-545-0464_ Page 1 of 1 . r Pgge 7 of 14 PAYMENT DUE DATE NEW BALANCE MINIMUM DUE 06107/2002 I $2,064.19 I $264.19 Feb 10 2806 ACCOUNT NUMBER: 4226 6106 5386 9152 Facsimile TIM J PANAGOS also 100 E KING ST SHIPPENSBURG 1 17257-1326 Copy O CHASE Cll vlsa- ACCOUNT NUMBER: 4226 6106 5386 9112 NEW PAYMENT TOTAL TOTAL STATEMENT BALANCE DUE DATE CREDIT LINE AVAILABLE CREDIT CLOSING DATE $2,084,19 061072002 $1,900 $0.00 0511312002 Here is vour Account Summary: TOTAL Previous Balance $1.98390 (-) Payments, Credits 0 00 (+) Purchases, Cash, Debits 58.00 (*) FINANCE CHARGES 42.29 (_) New Balance 2084.19 Minimum Due 41.00 Past Due - Pay Imir lely 39.00 Over Line - Pay Immediately 184.19 Minimum Payment Due $264.19 Here are your f-marges anu ti-recurs at a 05/19 I 05113 I I LAOVERLIMIT FE 29.001 TE CHARGE- MIN PYMT NOT RECD BY DATE I I 29.00 Total of your credits and charges 0.00 58.00 YOUR ACCOUNT IS PRESENTLY PAST DUE. YOU MUST SEND PAYMENT TO AVOID LOSING YOUR CREDIT PRIVILEGES. IF YOU'VE ALREADY PAID- THANKYOU, ENROLL IN CHASE PAYMENT PROTECTOR PLAN TODAY. THE PLAN THAT HELPS PROTECT YOUR CREDIT RATING. Here'c how we determined vol Finance Chatve*: Day's in Billhls Cycle: 32 NOMINAL DAILY AVERAGE PERIODIC/MIN. TOTAL ANNUAL ANNUAL PERIODIC DAILY FINANCE FINANCE 1 PERCENTAGEI PERCENTAGE RATE BALANCE CHARGE CHARGE RATE RATE Cash 0.06573% $0.00 $0.00 $0.00 23.99% 0.00% Purchases 0,06573%1 $2,010.60 $42.29 $42.29 23 23.99% ` Please see reverse side for balance computation method and other important information. Questions about your account? Cresdt Card lost or stolen? Call Chase Customer Service 24 hours a Day, 7 days a week, toll-flee, at 1-800-441-7681 or write PO BOX 15919, WILMINGTON, DE 19850-5919. Para Servicio al ClieMe on Espanol:-800-545-0464. Page 1 of 1 a P$Se 8 of 14 Feb 10 2006 ACCOUNT NUMBER: 4226 6106 5386 9152 PAYMENT DUE DATE NEW BALANCE MINIMUM DUE 0710812002 I $2,185.19 I $408.19 Facsimile TIM J PANAGOS ossa 100 E KING ST SHIPPENSBURG PA 17257-1326 Copy O CHASE Chase vlaa__ ACCOUNT NUMBER: 4226 6106 5386 9112 NEW PAYMENT TOTAL TOTAL STATEMENT BALANCE DUE DATE CREDIT LINE AVAILABLE CREDIT CLOSING DATE $2,185.19 07/0812002 $1,900 $0.00 0611312002 Here is your Account Summary: TOTAL Previous Balance S2,084,19 (-) Payments, Credits 0.00 (+) Purchases, Cash, Debts 58.00 I-) FINANCE CHARGES 43. DO (_) New Balance 2.185.19 Minimum Due 43.00 Past Due - Pay Immediately 80.00 Over Line - Pay Immediately 285.19 Minimum Payment Due $408.19 Here are vour t;narees ana t-reOl[s at a 06113 06,13 OVERLI MIT FEE 29.00 LATE CHARGE - MIN PYMT NOT RECD BY DATE 29.00 Total of your credits and charges 0.00 58.00 YOU ARE TWO PAYMENTS PAST DUE. FAILURE TO PAY PROMPTLY COULD SERIOUSLY DAMAGE YOUR CREDIT RATING. IF YOU'VE ALREADY PAID-THANKYOU. ENROLL IN CHASE PAYMENT PROTECTOR PLAN TODAY. THE PLAN THAT HELPS PROTECTYOUR CREDIT RATING. Here's bow we determined your Finance Charge*: Days in BlUffig Cvcle: 31 NOMINAL DAILY AVERAGE PERIODICIMIN. TOTAL ANNUAL ANNUAL PERIODIC DAILV FINANCE FINANCE PERCENTAGE PERCENTAGE RATE BALANCE CHARGE CHARGE RATE RATE Cash 0.06573 % $0.00 $0A0 $0.00 23.99% 0.00% Purchases 0.06573% $2,110.49 $43.00 $43.00 23.99% 23.99% ` Please see reverse side for balance computation method and other important information. Questions about your account? Credit Card lost or stolen? Call Chase Customer Service 24 hours a Day, 7 days a week, toll-free, at 1-800-334-6350 or write PO BOX 15919. WILMINGTON, DE 1 9 850-5 91 9. Para Servicio al Cliente on Espanol:-800-545-0464. Page 1 of 1 . u Pp. 9 of 14 Feb 10 2006 ACCOUNT NUMBER: 4226 6106 5386 9152 PAYMENT DUE DATE NEW BALANCE MINIMUM DUE 08109/2002 I $2,269.76 I $557-76 Facsimile TIM J PANAGOS 06v 100 E KING ST SHIPPENSBURG PA 17257-1326 Copy O CHASE Chase Vtsa- A000UNT NUMBER: 4226 6106 5386 91i2 NEW PAYMENT TOTAL TOTAL STATEMENT BALANCE DUE DATE CREDIT LINE AVAILABLE CREDIT CLOSING DATE $2,289.76 08/092002 $1,900 $0.00 070`1512002 Here is your Account Summary: TOTAL Previous Balance $2,185.19 (-) Payments, Credits D00 (+) Pumhasea. Cash, Debits 58.00 (+) FINANCE CHARGES 46.57 (_) New Balance 2.289.76 Minimum Due 4500 Past Due - Pay Immedialely 123.00 Over Line - Pay Immediately 309.76 77 Minimum Payment Due 17777$557 Mere are your %-narges aau 11.1euu5 ar, a gLaucc: 07/15 I 07115 I I LAOVE FE 29.001 TE CIHARGEE MIN PYMT NOT RECD BY DATE I I 29.00 Total of your credits and charges 0.00 56.00 YOUR ACCOUNT IS SERIOUSLY DELINQUENT. WE WANTTO WORK WITH YOU TO RESOLVE THIS MATTER. CALL IMMEDIATELY TO DISCUSS YOUR PAYMENT OPTIONS. PLEASE REMEMBER TO FOLLOW OUR PAYMENT INSTRUCTIONS WHEN MAILING YOUR PAYMENT. PAYMENT MUST BE RECEIVED BY US AT OUR POST OFFICE BOX DESIGNATED FOR RECEIPT OF PAYMENT ON YOUR BILLING STATEMENT BY 12:00 NOON. EASTERN TIME. ON A BANK BUSINESS DAY IN ORDER TO BE CREDITEDTOYOUR ACCOUNT AS OF THAT DAY. ENROLL IN CHASE PAYMENT PROTECTOR PLAN TODAY. THE PLAN THAT HELPS PROTECT YOUR CREDIT RATING. Here's how we determined vour Finance Chami Days in Billing Cycle: 32 NOMINAL DAILY AVERAGE PERIODIC/MIN. TOTAL ANNUAL ANNUAL PERIODIC DAILY FINANCE FINANCE PERCENTAGE PERCENTAGE RATE BALANCE CHARGE CHARGE RATE RATE Cash 0.00573% $0.00 $O-DO $0.00 23.99% 0.00% Purchases 0.06573% $2,213.95 $46.57 $46.57 23.99% 23.99% ' Please see reverse side for balance computation method and other important information. Quesfio0s about your account? Credit Card lost or stolen? Call Chase Customer Service 24 hours a Day, 7 days amok, tell-Iree, at 1-800-794-1396 or write PO BOX 15919. WILMINGTON, DE 19850-5919. Para Servicio al Cliente en EspaRal:-800-545-0464. Page 1 of 1 a Pgge 10 of 14 Feb 10 2006 ACCOUNT NUMBER: 4226 6106 5386 9152 PAYMENT DUE DATE NEW BALANCE MINIMUM DUE 091108/2002 I $2,393.44 I $708.44 Facsimile TIM J PANAGOS osw 100 E KING ST SHIPPENSBURG PA 17257-1326 Copy O CHASE Chase visa- ACCOUNT NUMBER: 4226 6106 5386 9152 NEW PAYMENT TOTAL TOTAL STATEMENT BALANCE DUE DATE CREDIT LINE AVAILABLE CREDIT CLOSING DATE $2,393.44 09/0812002 $1,900 $0.oo 08!14/2002 Here is your Account Summary: TOTAL Previous Balance S2,26936 (-) Payments, Credits 0.00 (+) Purchases, Cash, Debits 58.00 (?) FINANCE CHARGES 45.68 (_) New Balance 2.393.44 Minimum Due 47,00 Past Due - Pay Immediately 168.00 Over Line - Pay Immediately 493.44 Minimum Payment Duc $708.44 Here are your cnarges ana 4- reaas ar a glance: 0814 I 08!14 I I LAOVERL FE 29.00 1 TE CIHARGEE MIN PYMT NOT RECD BY DATE I I 29.00 Total of your credits and charges 0.00 58.00 YOUR ACCOUNT IS CLOSEDAND THE CREDIT BUREAUS HAVE BEEN NOTIFIED. PLEASE MAKE YOUR MINIMUM PAYMENT DUE NOW TO AVOID POSSIBLE LEGAL ACTION. ENROLL IN CHASE PAYMENT PROTECTOR PLAN TODAY. THE PLAN THAT HELPS PROTECT YOUR CREDIT RATING. Here's how we determined your Finance Charge*: Days I Billing Cycle: 30 NOMINAL DAILY AVERAGE PERIODICIMIN. TOTAL ANNUAL ANNUAL PERIODIC DAILY FINANCE FINANCE PERCENTAGE PERCENTAGE RATE BALANCE CHARGE CHARGE RATE RATE Cash 0.06573% $0.00 $0.00 E0.00 23.99% DAO% Purchases 0.06573% $2.316.55 $45.68 1)5.58 23..% 23.99% Please see reverse side for balance computation method and other important information. Questions about your account? Credit card lost or stolen? Call Chase Customer Service 24 hours a Day, 7 days a week, toll-free, at 1-800-794-1396 or write PO BOX 15919. WILMINGTON, DE 19850-5919. Para Servicio at Cliente en Espanol. 800-545-0464. Page 1 of 1 . A PjIrge 11 of 14 Feb 10 2006 ACCOUNT NUMBER: 4226 6106 5386 9152 PAYMENT DUE DATE NEW BALANCE MINIMUM DUE 10/0812002 I $2,499.18 I $863.18 Facsimile TIM J PANAGOS Gsm 100 E KING ST SHIPPENSBURG PA 17257-1326 Copy rjCHASE Chase Vlxa- ACCOUNT NUMBER: 4226 6106 5386 91i2 NEW PAYMENT TOTAL TOTAL STATEMENT BALANCE DUE DATE CREDIT LINE AVAILABLE CREDIT CLOSING DATE $2,499.18 10/08/2002 $1,900 $0.00 09!13(2002 Here is your Account Summary: TOTAL Previous Balance $2,393,44 (-) Payments, Credits 0.00 (?) Purchases, Cash, Debits 58.00 (ai FINANCE CHARGES 47.74 (_) New Balance 2.499.18 Minimum Due 4900 Past Due - Pay Immediately 215.00 Over Line - Pay Immediately 599.18 Minimum Payment Due $883.18 Here are your %.narge5 anu LreLLl at a 09113 09113 a ERLIMIT FEE 29.00 LATE CHARGE - MIN PYMT NOT RECD BY DATE 29.00 Total of your credits and charges 0.00 58.00 ITS NOT TOO LATE TO RESOLVE YOUR SERIOUS DELINQUENCY. CALL US FOR PAYMENT OPTIONS THAT WILL HELP YOU IMPROVE YOUR CREDIT RATING. IMPORTANT: PLEASE READ ENCLOSED INSERT FOR NEW ARBITRATION AGREEMENT AND OTHER CHANGES TO YOUR ACCOUNT TERMS. Here's how we determined your Finance Charge*: Days in BlUing Cycle: 30 NOMINAL DAILY AVERAGE PERIODIC/MIN. TOTAL ANNUAL ANNUAL PERIODIC DAILY FINANCE FINANCE PERCENTAGE PERCENTAGE RATE BALANCE CHARGE CHARGE RATE RATE Cash 0.06573% $0.00 $0.00 S0 23.99% 0.00% Purchases 0.08573 % $2.421.23 $47.74 1 y17.74 23.99% 23.99% Please see reverse side for balance computation method and other important information. Questions about your account? Credit Card lost or stolen? Call Chase Customer Service 24 hours a Day, 7 days a week, toll-free, at 1-800-794-1396 orvrtite PO BOX 15919. WILMINGTON, DE 1 9 850-5 91 9. Para Servicio al Cliente en Espanol:-800-545-0464. Page 1 of 1 r a, Ri 12 of 14 Felt tg 2006 ACCOUNT NUMBER: 4226 6106 5386 9152 PAYMENTDUE DATE NEW BALANCE MINIMUM DUE 1110812002 I $2,608.72 I $1,024.72 Facsimile TIM J PANAGOS 0e5a 100 E KING ST SHIPPENSBURG PA 17257-1326 Copy J CHASE Chase Visa ACCOUNT NUMBER: 4226 6106 5386 9152 NEW BALANCE $2,608.72 PAYMENT DUE DATE 11108!2002 TOTAL CREDIT LINE $1,900 TOTAL AVAILABLE CREDIT $0.00 STATEMENT CLOSING DATE 1oH4Y20o2 Here is your Account Summary: TOTAL Previous Balance $2,499,18 (-) Payments, Credits 0.00 (+) Purchases, Cash, Denits 58.00 (+) FINANCE CHARGES St 54 (_) New Balance 2.605.72 Minimum Due 52.00 Past Due - Pay Immediately 264.00 Over Line - Pay Immediately 70872 Minimum Payment Due $1,024.72 Here are your Charges and Credits at a glance: TRAN. DATE POST DATE REF. NO DESCRIPTION OF TRANSACTIONS CREDITS CHARGES 10;14 1004 OVERLIMIT FEE 29.00 LATE CHARGE - MIN PYMT NOT RECD BY DATE 29.00 Total of your credits and charges 0.00 58.00 THIS IS THE LAST CHANCE TO PREVENT LONG-TERM DAMAGE TO YOUR CREDIT RATING. CONTACT US NOW TO MAKE IMMEDIATE PAYMENT ARRANGEMENTS. IN PLACE OF THE PURCHASES GRACE PERIOD DESCRIBED UNDER "PURCHASES GRACE PERIOD" SECTION OF THIS STATEMENT. PAY THE NEW BALANCE (LESS ANY CASH ADVANCE BALANCE) IN FULL ON OR BEFORE THE PAYMENT DUE DATE TO AVOID ADDITIONAL FINANCE CHARGES ON PURCHASES. ENROLL IN CHASE PAYMENT PROTECTOR PLAN TODAY. THE PLAN THAT HELPS PROTECT YOUR CREDIT RATING. Here's how we determined your Finance Charge": Days in Billing Cycle: 31 NOMINAL DAILY AVERAGE PERIODICIMIN. TOTAL ANNUAL ANNUAL PERIODIC DAILY FINANCE FINANCE PERCENTAGE PERCENTAGE RATE BALANCE CHARGE CHARGE RATE RATE Cash 0.06573% I $0.00 -00 - $0.00 23.99% 0.00% Purchases 0.06573% $2,529.59 $Si54 1 $57.54 23.99% 23.99% Please see reverse side for balance computation method and other important information. Qu96tlon8 about your account? Credit Card lost or stolen? Call Chase Customer Service 24 bows a Day, 7 days a week, toll-free, at 1-800-794-1396 or write PO BOX 15919, WILMINGTON, DE 19850-5919. Pena Servicio al Cliente en Espanol:-800-545-0464. Page 1 of 1 y. .. Pyage 13 of 14 Feb 10 2006 ACCOUNT NUMBER: 4226 6106 5386 9152 PAYMENT CUE DATE NEW BALANCE MINIMUM DUE 12/0812002 I $2,724.77 I $1.194.77 Facsimile TIM J PANAGOS wm 100 E KING ST SHIPPENSBURG PA 1 72 5 7-1 326 Copy O CHASE Chase Visa_ ACCOUNT NUMBER: 4226 6106 5386 9112 NEW PAYMENT TOTAL TOTAL STATEMENT BALANCE DUE DATE CREDIT LINE AVAILABLE CREDIT CLOSING DATE $2,724.77 12/082002 $1,900 $0.00 11113l20D2 Here is your Account Summary: TOTAL Previous Balance $2,608.72 (-) Payments, Credits 0.00 (+) Purchases, Gash, Debits 64.00 1+) FINANCE CHARGES 52.05 (_) Nev? Balance 2.724.77 Minimum Due 54.00 Past Due - Pay Immediately 316.00 Over Line - Pay Immediately B24.77 Minimum Payment Due $1,194.77 here are your 1.,narges anu •.reulls at a 11113 11113 OVERLIMIT FEE 29.00 LATE CHARGE -MIN PYMT NOT RECD BY DATE OD035DO Total of your credits and charges 0.00 64.00 FAILURE TO MAKE PAYMENT HAS DAMAGED YOUR CREDIT RATING. WE WANTTO WORK WITH YOU TO REBUILD YOUR CREDIT. CALL TODAY TO GET STARTED. Here's how we determined your FI1lance Charges: Days in Billing Cycle: 30 NOMINAL DAILY AVERAGE PERIODIClMIN. TOTAL ANNUAL ANNUAL PERIODIC DAILY FINANCE FINANCE pERCENTAGE PERCENTAGE RATE BALANCE CHARGE CHARGE RATE RATE Cash 0.06573% $0.00 SO.oO $0.00 23.99% 0.00% Purchases 0.06573% $2,639.57 $52 05 $52.05 23.99% 23.99% Please see reverse side for balance computation method and other important information. Questions about your account? Credit Card lost or stolon? Call Chase Customer Service 24 hours a Day, 7 days a vmek, toll-free, at 1-800-794-1396 or wdle P.O. BOX 15583, Wilmington, DE 19886-1194. Para Se"icio al Cliente en Espanol: 1-800-545-0464. Page 1 of 1 . PZsge 14 of 14 Feb 10 2006 ACCOUNT NUMBER: 4226 6106 5386 9152 PAYMENT DUE DATE NEW BALANCE MINIMUM DUE 12109/2002 I $0.00 I $0.00 Facsimile TIM J PANAGOS 0659 100 E KING ST SHIPPENSBURG PA 1 72 5 7-1 326 Copy O CHASE Chaxe Visa- ACCOUNT NUMBER: 4226 6106 5386 91n2 NEW 1 BALANCE $0.00 PAYMENT DUE DATE 1210912002 TOTAL CREDIT LINE $1,900 TOTAL AVAILABLE CREDIT $0.00 STATEMENT CLOSING DATE 111140002 Here is your Account Summary: TOTAL Previous Balance $2,72477 (-) Payments, Credits 2.724.77 (t) Purchases, Cash, Debits 0.00 (-) FINANCE CHARGES 0 00 (_) New Balance 0.00 Mirtimum Payment Due $0.00 Here are your Charges and Credits at a glance: TRAN. DATE POST DATE REF. NO DESCRIPTION OF TRANSACTIONS CREDITS CHARGES Total of your credits and charges 2,724.77 0.00 Here's how we determined your Finance Charge*: Days in Billing Cycle: 30 NOMINAL DAILY AVERAGE PERIODICIMM. TOTAL ANNUAL ANNUAL PERIODIC DAILY FINANCE FINANCE PERCENTAGE PERCENTAGE RATE BALANCE CHARGE CHARGE RATE RATE Cash 0.06573% $0.00 $0.00 $0-t10 23.99% D.OD% Purchases 0.06573% $0.00 $0-00 $0.00 23,99% D.00% Please see reverse side for balance computation method and other important information. Questions about your account? Credit Card lost or stolen? Call Chase Customer Service 24 hours a Day, 7 days a vmek, toll free, at 1-800-441-7681 or write P.O. BOX 15654, Wilmington, DE 19886-5654. Para Servicio at Ctente an Espanol: 1-800-545-0464. Page 1 of 1 ? -bg. ? ? ? ?i ? ? ,. ?' -c `-_L., IN THE COURT OF COMMON PLEAS OF CUMBELRAND COUNTY - PENNSYLVANIA GREAT SENECA FINANCIAL CORP. : No. 06-1328 Civil Term A MARYLAND CORPORATION Assignee of MERCHANT MANAGEMENT : Civil Action - Law Assignee of CHASE Plaintiff vs Tim J. Panagos 100 E. King Street Shippensburg, PA 17257 Defendant NOTICE YOU ARE HEREBY NOTIFIED TO FILE A WRITTEN RESPONSE TO THE ENCLOSED NEW MATTER WITHIN TWENTY (20) DAYS FROM SERVICE HEREOF OR A JUDGMENT MAY BE ENTERED AGAINST YOU. H. Anthony Adams, Esquire (25502) Attorney for Defendant 49 W. Orange Street, Suite 3 Shippensburg, PA 17257 (717) 532-3270 IN THE COURT OF COMMON PLEAS OF CUMBELRAND COUNTY - PENNSYLVANIA GREAT SENECA FINANCIAL CORP. : No. 06-1328 Civil Term A MARYLAND CORPORATION Assignee of MERCHANT MANAGEMENT : Civil Action - Law Assignee of CHASE Plaintiff vs Tim J. Panagos 100 E. King Street Shippensburg, PA 17257 Defendant ANSWER Now come the Defendant, Tim J. Panagos, by and through his Attorney, H. Anthony Adams and sets forth the following: 1. Denied, Defendant is without sufficient knowledge or belief to form an opinion as to the truth of the matter averred. Further, Plaintiff has not attached any assignments of interest. 2. Admitted 3. Admitted 4. Denied, Defendant agreed to abide by the terms and conditions contained within the contract with Chase. 5. Denied, the account as attached to the complaint clearly demonstrates that no charge has been made to the account since December 2001. 6. Denied, Defendant believes that he has not received any statement on account since November 2004. 7. Admitted 8. Denied, Defendant is without sufficient knowledge or information to form a belief as to the truth of the matter averred. Defendant avers that the principal amount in question would not exceed $1,900.00. 9. Denied, Defendant is without sufficient knowledge or information to form a belief as to the truth of the matter averred. 10. Denied, demand for the amount due has not been made. 11. Admitted 12. Denied, the sum requested is neither reasonable nor has Defendant any statutory or contractual obligation to pay attorney's fees. 13. Denied, Defendant is without sufficient knowledge or information to form a belief as to the truth of the matter averred. 14. Admitted New Matter 15. The action brought by the Plaintiff is barred by the statute of limitations. 16. The action brought by the Plaintiff is res judicatce having been the subject of an action filed November 15, 2004 in the Office of the District Justice in Shippensburg, Pennsylvania said action being withdrawn on December 8, 2004 after Defendant gave notice of intent to defend. Wherefore, Defendant prays your Honorable Court dismiss the complaint of Plaintiff. Respectfully submitted, Anthony Adams, Esquire Attorney for Defendant 49 W. Orange Street, Suite Shippensburg, PA 17257 (717)-532-3270 VERIFICATION I verify that the statements made in this answer are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date:-3 kq 1016 hY OS ^? (T t^? T C. F --1 -t' _.,? - :. ???? 4 ^??'a: C.? -n ?`i-:: ;i ? t .T U3 ORU INAL IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREAT SENECA FINANCIAL CORP., No. 06-1328 Civil Term A MARYLAND CORPORATION, ASSIGNEE OF MERCHANT MANAGEMENT, ASSIGNEE OF CHASE, Plaintiff vs. CIVIL ACTION - LAW TIM J. PANAGOS, Defendant REPLY TO NEW MATTER AND NOW, this ???ay of c 2006, comes the Plaintiff, Great Seneca Financial Corp., a Maryland Corporation, Assignee of Merchant Management, Assignee of Chase, by and through its attorneys, the law firm of Wolpoff & Abramson, L.L.P., and files the within Reply to New Matter and in support avers as follows: 15. Conclusion of law, no response required. If a response is required, all allegations or insinuations of wrongdoing on the part of Plaintiff are hereby denied. By way of further response, a payment was made in maintenance of this account on March 14, 2002. Therefore, the statute of limitations would not expire until march 14, 2006. Plaintiff filed its Complaint on March 9, 2006, within the applicable statute of limitations. 16. Conclusion of law, no response required. If a response is required, LAW OFFICES WOLPOFF & ABRAMSON, L.L.P. ATTORNEYS IN THE PRACTICE OF DEBT COLLECTION 4660 TRINDLE ROAD THIRD FLOOR all allegations or insinuations of wrongdoing on the part of Plaintiff are hereby denied. By way of further response, clearly Plaintiff may withdraw its prior CAMP HILL, PA 17011 71]-303-6700 action without prejudice and re-file a complaint. There can be no res judicata as there has been no prior final determination of this case on the merits. WHEREFORE, Plaintiff respectfully requests that this Honorable Court dismiss Defendant Tim J. Panagos' New Matter with prejudice and enter judgment in favor of Plaintiff and against Defendant, along with the allowable costs of this action, and such further relief as the Court deems just and appropriate. Respectfully submitted, ?Yta Andrew C. Spears squire ID No. 87737 Wolpoff & Abramson, LLP Attorneys in the Practice of Debt Collection 4660 Trindle Road, 3'd Floor Camp Hill, PA 17011 (717) 303-6700 Counsel for Plaintiff LAW OFFiCHS WOLPOFP & ARRAMSON, L.L.P. ATTORNEYS IN THE PRALYICE OF DEBT COLLECTION 4620 TRINOLE ROAD THIRD FLOOR CAMP HILL, PA 17011 717-303-6700 VERIFICATION The undersigned hereby states that he/she is the attorney for the Plaintiff, Great Seneca Financial Corp., a Maryland Corporation, Assignee of Merchant Management, Assignee of Chase, who is located outside of this jurisdiction and in order to file the within document in an expedient and timely manner, he/she is authorized to take this verification on behalf of said Plaintiff in the within action and verifies that the statements made in the foregoing Reply to New Matter are true and correct to the best of his/her knowledge, information, and belief, based upon information provided by the Plaintiff. The undersigned understands that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Ito 6? Andrew C. Spears, Esquire ID No. 87737 Wolpoff & Abramson, LLP Attorneys in the Practice of Debt Collection 4660 Trindle Road, 3'a Floor Camp Hill, PA 17011 (717) 303-6700 Counsel for Plaintiff LAW OFFICDS VOLPOFF & ABRAMSON, L.L.Y 47TORNEYS IN THE PRACTICE OF DEBT COLLECTION 46W TRINDLE ROAD THIRD FLOOR CAMP HILL, PA 17011 71]-36367W IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREAT SENECA FINANCIAL CORP., No. 06-1328 Civil Term A MARYLAND CORPORATION, ASSIGNEE OF MERCHANT MANAGEMENT, ASSIGNEE OF CHASE, Plaintiff vs. TIM J. PANAGOS, Defendant CIVIL ACTION - LAW CERTIFICATE OF SERVICE The undersigned does hereby certify that I served a copy of the foregoing Reply to New Matter on counsel for Defendant, by First Class Mail, Postage Pre- Paid, a copy thereof on this IC day of i 2006, to: H. Anthony Adams, Esquire 49 W. Orange Street, Suite 3 Shippensburg, PA 17257 Andrew C. Spear Esquire ID No. 87737 Wolpoff & Abramson, LLP Attorneys in the Practice of Debt Collection 4660 Trindle Road, 3"1 Floor Camp Hill, PA 17011 (717) 303-6700 Counsel for Plaintiff LAW OFFICES WOLPOFF & ABRAMSON. L.I.Y. ATTORNEYS INTHE PRACTICE OF OF,BT COLLECTION 4660 TRWIDLE ROAD THIRD FLOOR CAMP HILL, PA 17011 717-303-6700 r, ,, r» ;, ._? ,, , s ., ?. SHERIFF'S RETURN - REGULAR CASE NO: 2006-01328 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND GREAT SENECA FINANCIAL CORP VS PANAGOS MICHAEL BARRI , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon PANAGOS TIM J the DEFENDANT at 1918:00 HOURS, on the 14th day of March 2006 at 100 EAST KING STREET SHIPPENSBURG, PA 17257 TIM PANAGOS by handing to 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 18.00 Service 18.48 Postage .39 Surcharge 10.00 .00 46.87 Sworn and Subscribed to before me this of la-E day of ,Yvuk") q cro 4 A . D . L, .07 rr-Protherffdtaty So Answers: R. Thomas Kline 03/15/2006 WOLPOFF & ABRAMSON By. Deputy S e f Great Seneca Financial Corp., IN THE COURT OF COMMON PLEAS OF A Maryland Corporation CUMBERLAND COUNTY, PENNSYLVANIA Assignee of Merchant Management, Assignee of Chase NO. 06-1328 CIVIL Term 19 V. Tim J. Panagos RULE 1312-1. The Petition for Appointment of Arbitrators shall be substantially in the following form: PETITION FOR APPOINTMENT OF ARBITRATORS TO THE HONORABLE, THE JUDGES OF SAID COURT: Andrew C. Spears , counsel for the plaintiff/defendant in the above action (or actions), respectfully represents that: 1. The above-captioned action (or actions) is (are) at issue. 2. The claim of the plaintiff in the action is $5346.84 The counterclaim of the defendant in the action is The following attorneys are interested in the case(s) as counsel or are otherwise disqualified to sit as arbitrators: WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. Respectfully submitted, CXQI'?/ ORDER OF COURT AND NOW, , 19 , in consideration of the foregoing petition, Esq Esq., and , Esq., are appointed arbitrators in the above captioned action (or actions) as prayed for. By the Court, P.J. w 0 c F h? i I1; i -? ~-7 4? IN THE COURT OF COMMON PLEAS OF CUMBELRAND COUNTY - PENNSYLVANIA GREAT SENECA FINANCIAL CORP. A MARYLAND CORPORATION Assignee of MERCHANT MANAGEMENT Assignee of CHASE Plaintiff vs Tim J. Panagos 100 E. King Street Shippensburg, PA 17257 Defendant No. 01n- 13ag Civil Term Civil Action - Law ANSWER 1. Admitted 2. Admitted 3. Denied, Defendant is without sufficient knowledge or information to form a belief as to the truth of the matter averred. 4. Denied, Defendant is without sufficient knowledge or information to form a belief as to the truth of the matter averred. Defendant further answers that nothing in Exhibit A demonstrates a transfer of the Defendant's account. 4 5. Denied, Exhibit B does not contain any language, signature or agreement between Plaintiff, or Plaintiff's predecessor and Defendant. 6. Denied, Defendant does not have any particular recollection of the account. Strict proof of the existence of the account and its use is demanded. 7. Denied, Defendant has no particular recollection of payment to the account and after reasonable investigation including checking credit reports he is without knowledge or information sufficient to form a belief as to the truth of the matter averred. 8. Denied, Defendant believes his last payment on account was in 1999 if it was on this account. 9. Denied, if the credit check run by Defendant is correct and if the account of Defendant is, as stated, it is believed there was a balance of $4,759.00. 10. Paragraph 10 does not require response. 11. Admitted that based upon the numbers in Plaintiffs complaint the mathematics are correct. It is denied that an amount is owed. 12. Denied, Defendant denies that my money is owed to Plaintiff. NEW MATTER 13. The action of the Plaintiff is barred by the applicable statute of limitations. Respectfully submitted, H. Anthony Adams, Esquire Attorney for Defendant 49 W. Orange Street, Suite 3 Shippensburg, PA 17257 (717)-532-3270 VERIFICATION I verify that the statements made in this answer are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date:?10 (' TIM iJ 5` s-t-s 1 ; C'< 3 ?`t T t i rtl ?.. & Fw?o, c,-7j In The Court of Common Pleas of Cumberland V. Plaintiff County, Pennsylvania No. 04 - 13 2-&- "'Defendant Civil Action - Law. Oath We do solemnly swear (or affirm) that we will support, obey and defend the Constitution of the United States and the Constitution of this Commonwealth and that we will discharge the duties of our office with fidelity. Signature Signature A Name (Chairman) Name Law Firm P.O. 6-,c ;?-61 Address eQ-t&? 17V/-3 City, zip 4 161ril X-ru rN ?-Assess., P.L. Law Firm Address CArIIS&¢ / 70 l City, -* Zip i ?a os Award r ignature MiC41I& /P TM/M Name -ruko L-,g4d 611f/ee-3 Law Firm Address ,? ?dli g le / ?70 -3 City, zip 4 1018M . Arbitrator, dissents. (Insert name if applicable.) Date of Hearing: (Chairman) Date of Award: /2-/ - D? ----------- - 77. Notice of Entry of Award Now, the _ day of MRr h , 20-Da_, at Ins, -a -.M., the above award was entered upon the docket and notice thereof given by mail to the parties or their attorneys. Arbitrators' compensation. to be paid upon appeal: $ AD . 00 By: ell Prothonotary Deputy We, the undersigned arbitrators, having been duly appointed and sworn (or affirmed), make the following award: (Note: If damages for delay are awarded, they shall be separately stated.) .4. a V''G- ??A? pn? ?,8'?1 P A? pct, _i? Dada - 1 . ?F 1.4 1-.? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREAT SENECA FINANCIAL CORP. NO. 06-1328 Plaintiff vs. TIM J PANAGOS Defendant CIVIL ACTION - LAW PRAECIPE FOR JUDGMENT ON ARBITRATION AWARD PURSUANT TO PA.R.CIV.P.1307(C) TO THE PROTHONOTARY: Enter Judgment on the arbitration award entered in these proceedings in favor of Great Seneca Financial Corp., and against Tim J Panagos in the amount of $1500.00 with interest of six percent (6%) from 3-8-2007 and costs. Respectfully Submitted, Amy F. Doyle 1#87062 / Daniel F Wo n # 0617 Philip C. Warholic #863 avid R. Galloway #87'11; --'-% Tonilyn M. Chippie #8 a . Ehasz #86469 Robert N. Polas, Jr. #201259 / Ronald M. Abramson #94266 Ronald S. Canter #94000 / Bruce H. Cherkis #18837 WOLPOFF & ABRAMSON, LLP / Counsel for Plaintiff Attorneys in the Practice of Debt Collection 4660 Trindle Road, Suite 300, Camp Hill, PA 17011 (717) 303-6700 W&A FILE NO. 124733198 V. Plaintiff o-5 "'Defendant In The Court of Common Pleas of Cumberland County, Pennsylvania No. 04 --/ 3 ZS' Civil Action - Law. Oath We do solemnly swear (or affirm) that we will support, obey and defend the Constitution of the United States and the Constitution of this Commonwealth and that we will discharge the duties of our office with fidelity. r Signature Signature ignature , AIC9.1--s ?caVq Nl. Si U lfz. Name (Chairman) Name Law Firm vx a G P .o. Address 6,t"- l701-3 City, zip K-U) y- 4-Asacs-r ?.+G. Law Firm 11 I !!• /?.1Q!i .Sv+ a Address CrlISIZ /701 S City, zip 1111C41f ee-- je Sri Name -Tako 1-4ud a fie&-s Law Firm 7- Address ? X !?le / ?7,0/3 City, zip . Arbitrator, dissents. (Insert name if applicable.) Date of Hearing: lZ -/J-- ©,r.. -- (Chairman) art ""r ?'"S' ? h Date of Award: t Z -l S - D ?7 151 Notice of Entry of A ?a4-1331q6 Now, they' day of MQWh, 20_x, at? M the above entered upon the docket and notice thereof given by mail to the parties or their attorneys. Arbitrators' compensation to be paid upon appeal: $ AD - 00 FRM RE V oA!?whuneof, t here unto at my two, the of said Court at Carle, Pe. By' 400 Prothonotary ty Award We, the undersigned arbitrators, having been duly appointed and sworn (or affirmed), make the following award: (Note: If damages for delay are awarded, they shall be separately stated.) ..r -.., IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREAT SENECA FINANCIAL CORP. NO. 06-1328 Plaintiff VS. CIVIL ACTION - LAW TIM 3 PANAGOS Defendant CERTIFICATE OF SERVICE I, Amy R Wise , an authorized agent of Wol off & Abramson, LLP, hereby certify that a copy of the foregoing order was served this -, day of r , 2007, by depositing same in the Post Office at Camp Hill, PA, first class mail, postage prepaid, addressed as follows: ANTHONY H ADAMS 49 W ORANGE ST. SUITE 3 SHIPPENSBURG, PA 17257 WOLPOFF & ABRAMSON, LLP By (?. ", ?-I ? 4660 Trindle Rd., 3`d Fl. Camp Hill, PA 17011 (717) 303-6700 Q 1J w a t Cl) .J . `..t IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREAT SENECA FINANCIAL CORP. NO. 06-1328 Plaintiff VS. CIVIL ACTION - LAW TIM J PANAGOS Defendant(s) NOTICE OF JUDGMENT ( x ) Notice is hereby given that a FINAL JUDGMENT in the above-captioned matter has been entered against you in the amount of $ 1500.00 , plus interest, on _ I --------- 20_aT ( x ) A copy of all documents filed with the Prothonotary in support of the within judgment is/are attach If you have any questions regarding this Notice, please contact the filing party. ---------------- --------------------------------------- Amy F. Doyle #87062 / Dal.' ter-; Philip C. Warhol' #8634 David R. Galloway #87326 Tonilyn M. Chippie #87?s? / c^her X259 Sarah E. Ehasz #86469 / Bruce H. Cherkis #18837 Ronald S. Canter #94000 / Ronald M. Abramson #94266 WOLPOFF & ABRAMSON, L.L.P. / Counsel for Plaintiff Attorneys in the Practice of Debt Collection 4660 Trindle Road, Suite 300, Camp Hill, PA 17011 Telephone: (800) 830-2793 Fax: (866) 281-9028 (This Notice is given in accordance with Pa.R.C.P. 236.) NOTICE SENT TO: TIM J PANAGOS 100 E KING ST SHIPPENSBURG PA 17257-1326 STNTC/PANOJ W&A FILE NO. 124733198 F,;,,, c.? e,)a In The Court of Common Pleas of Cumberland V. Plaintiff .? County, Pennsylvania No. 04 - 13 ZS" efendant Civil Action - Law. Oath We do solemnly swear (or affirm) that we will support, obey and defend the Constitution of the United States and the Constitution of this Commonwealth and that we will discharge the duties of our office with fidelity. Signature Signature Z&)A4 4.- ? acs . ?1 Jam[ • st v fZ Name (Chairman) Name Law Firm ?skf +'slsse?(,5., PSG. Law Firm P.O. t6d) ;?-64 Address 6ta - / 70,, 3 city, zip 4 161 ri 1 r?"a Address CArIIS? . /?o t city, -* zip ? ?a os Award ignature /ki ck??? to IMI M Name -Two L.?9uJ 611fieleS Law Firm S, to, 7 Address ? X ,gle / ;701-3 city, zip :# 1420M . Arbitrator, dissents. (Insert name if applicable.) Date of Hearing: 12 -/S-- 0,6 t; Date of Award: 12--15--06 Notice of Entry of Award Now, the day of 20-0at it 6,K A, .M., the above award was entered upon the docket and notice thereof given by mail to the parties or their attorneys. Arbitrators' compensation to be paid upon appeal: $ Jt. DO By: Prothonotary Deputy We, the undersigned arbitrators, having been duly appointed and sworn (or affirmed), make the following award: (Note: If damages for delay are awarded, they shall be separately stated.) ?(Ok 6.11 Vh