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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
Genesis Financial Solutions,
Inc. as Successor in Interest
to Conseco Finance Corp. as
Successor in Interest to Bank
of New York
8405 SW Nimbus Ave. #A
Beaverton, OR 97008
VS.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
DOCKET NO. : DL -?3
CC)
James D Mader
109 Allen CT
Camp Hill PA 17011
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, 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
k
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 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 in the amount of
$5,529.40.
5. Plaintiff has made demand upon the defendant(s)for
payment of the balance due of $5,529.40 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
$5,529.40 at the rate of 0% from the date of July 21, 2004,
together with costs and attorney fees.
GORDON & WEINBERG, P.C.
BY:
FREDERIC IOFIEL RG, ESQUIRE
PAUL M. SC JR., ESQUIRE
Attorney ftiff
POLE
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. WE
, ESQUIRE
From: 612 684 8222 Page: 21/35 Date: 4/25/200612:3756 PM
PLAINTIFF'S AFFIDAVIT OF CLAIM
STATE OF Ore1104 l
89.
COUNTY OF bUQS?it/!cj jD/) 1
vu
Jame/ $rowri being first duly sworn, deposes and states that She is the _
'4A"L ?A? of Genesis Financial Solutions, Inc. and has the responsibility in the ordinary
course of businesa of maintaining plaintiffs books and records herein. That a review of the records
indicates as follows:
11 That GenesisFinancialSolutions,Inc. is the assignee of BANK OF NEWYORK, that there is
now due and owing to Genesis Financial Solutions Inc. byJames DMader aprincipal amount of
55,529.40 plus interest atthe contractual rate orstatutoryratewhicheverispermittedbylaw from
and after September 19,2005;
2. That no part thereof has been paid or satisfied, and that there are no set offs, or counterclaims
thereto to the knowledge or belief of deponent.
C" L yncxk-?
Subscribed and sw to before me
this Qfhaayof rr I/J2006.
Notary Public
Janel Brown
Agicy and Attotuq Network Uordlnator
Genesis Financial Solutions, Inc,
Client file: 00000080800000380791
Fwdr file: 127278
Co file: 2024222
This fax was received by GFI FAXmaker fax server. For more information, visit: http://www.gfi.com
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SHERIFF'S RETURN - NOT FOUND
CASE NO: 2006-03338 P
,COMMONTWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
GENESIS FINANCIAL SOLUTIONS IN
VS
MADER JAMES D
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
MADER JAMES D but was
unable to locate Him in his bailiwick. He therefore returns the
COMPLAINT & NOTICE ,
the within named DEFENDANT
MADER JAMES D
NOT FOUND , as to
109 ALLEN COURT
CAMP HILL, PA 17011
DEFENDANT HAS NOT LIVED AT GIVEN ADDRESS FOR OVER A YEAR.
Sheriff's Costs: So a
Docketing 18.00
Service 12.32
Not Found 5.00 Thomas Kline
Surcharge 10.00 eriff of Cumberland County
.00
45.3 ? GORDON & WEINBERG
p /q?aG 06/19/2006
Sworn and Subscribed to before
me this day of ,
A. D.
Curtis R. Long
Prothonotary
office of the vrotbonotarp
Cumber[aub Cauntp
Renee K. Simpson
Deputy Prothonotary
John E. Slike
Solicitor
OL -333k CVIL TERM
ORDER OF TERMINATION OF COURT CASES
AND NOW THIS 28TH DAY OF OCTOBER, 2009, AFTER MAILING NOTICE OF
INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE
CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA
R C P 230.2.
BY THE COURT,
CURTIS R. LONG
PROTHONOTARY
One Courthouse Square - Carlisle, Pennsylvania 17013 - (717) 240-6195 - Fax (717) 240-6573