HomeMy WebLinkAbout06-4529x? tea- P/ti/4010
OF COMMON PLEAS
Cumberland
Judicial District, County Of
NOTICE OF APPEAL
Notice is given that the appellant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the District Justice on
the date and in the case referenced below.
7-24-06
LLC.
NOTICE OF APPEAL
FROM
DISTRICT JUSTICE JUDGMENT
COMMON PLEAS No.
Paula P. Cort
V. John
CV-083-06 I-A
This block will be signed ONLY when this notation is required under Pa.
R.C.P.D.J. No. 10088.
This Notice of Appeal, when received by the District Justice, will operate as a
SUPERSEDEAS to the judgment for possession in this case.
Signature of Prothonotary or Deputy
was
No.
before a District Justice, A COMPLAINT MUST BE FILED within twenty
(20) days after (ling the NOTICE of APPEAL.
PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE
(This section of form to be used ONLY when appellant was DEFENDANT (see Pa.R.C.P.D.J. No. 1001(7) in action before District Justice. IF
NOT USED, detach from copy of notice of appeal to be served upon appellee.
PRAECIPE: To Prothonotary
Enter rule upon
Name o/ appelle(s)
appellee(s), to file a complaint in this appeal
(Common Pleas No. ) within twenty (20) days after service of rule or suffer entry of judgment of non pros.
Signature of appellant or atfomey or agent
RULE: To
Name of appellee(s)
appellee(s)
(1) You are notified that a rule is hereby entered upon you to file a complaint in this appeal within twenty (20) days after the date of service
of this rule upon you by personal service or by certified or registered mail.
(2) If you do not file a complaint within this time, a JUDGMENT OF NON PROS MAYBE ENTERED AGAINST YOU.
(3) The date of service of this rule if service was by mail is the date of the mailing.
Date: 20
Signature of Prothonotary or Deputy
YOU MUST INCLUDE A COPY OF THE NOTICE OF JUDGMENT/TRANSCRIPT FORM WITH THIS NOTICE OF APPEAL.
AOPC 312-02
COURT FILE TO BE FILED WITH PROTHONOTARY
PROOF OF SERVtC?E OF OTICE OF APPEAL AND RULE TO FILE COMPLAINT
(This proof of service MUST BE FILED WITHIN (10) DAYS AFTER filing of the notice of appeal. Check applicable boxes.)
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF ss
4
AFFIDAVIT: I hereby (swear) (affirm) that I served
? a copy of the Notice of Appeal, Common Pleas No. , upon the District Justice designated therein on
(date of service) , 20 ? by personal service ? by (certified) (registered) mail,
sender's receipt attached hereto, and upon the appellee, (name) on
20 ? by personal service ? by (certified) (registered) mail,
sender's receipt attached hereto.
(SWORN) (AFFIRMED) AND SUBSCRIBED BEFORE ME
THIS DAY OF .20
- Signature ofaffianl
Signature of official before whom affidavit "a made
Title of oRclal
My commission expires on 20
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AOPC 312A-02
COMMONWEALTH OF PENNSYLVANIA NOTICE OF JUDGMENT/TRANSCRIPT
CIVIL CASE
PLAINTIFF: NAME and ADDRESS .,
rEIIDSON 4 BEYSE, LLC
107 N COMMERCE NAY
SETSLE88E, PA 18017
L J
VS.
DEFENDANT: NAME end ADDRESS
?DySOX JOHff
8 FILL DIVE
CARLISLE, PA 17013
L -J'
CIO AYATO & ASSOCIATES P.C.
107 `•N COW=CZ NAY DocketNo.: C4-0000083-06
BWhHJ EEIiI, PA 18017 Date Filed: 6105106
THIS IS TO NOTIFY YOU THAT:
Judgment: FOR DEFENDANT (Date of Judgment) 7/24/06
® Judgment was entered for:' (Name) DYSON, JOHN'
0 Judgment was entered against: (Names) EDDSOlf A KEYSE, LLC
in the amount of $ 00
Amount of Judgment $
? Defendants are jointly and severally liable. Judgment Costs $ .0
Damages will be assessed on. Date & Time Interest on Judgment $-S
0
Attorney Fees $ .0
This case dismissed without prejudice. Total $ .00
Amount of Judgment Subject to Attachment/42 Pa.C.S. § 8127 Post Judgment;Credits
$ Post Judgment Go'sts • .: $
0 Portion of Judgment for physical damages arising out of
residential lease R Certified Judgment Total $
ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS/
OF APPEAL WITH THE PROTHONOTARY/CLERK.OF THE COU
MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENTrrRA
EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVII
JUDGEMENT HOLDER ELECTS TO ENTER THE JUDGMENT IN
COME FROM THE COURT. OF'COMMON PLEAS AND NO FURT
THE ENTRY OF?JUDG
COMMON PLEAS, CIV
PT FORM WITH YOUR
COURT OF
PROCESSI
Y FILING A NOTICE
ION. YOU
OF APPEAL.
ISTRICT JUDGES, IFTHE
LL FURTHER PROCESS MUST
THE MAGISTERIAL DISTRICT JUDGE. `
iEJUDGMENT.
- Rd7nicTaatial f)ickraM our
L? .. ...
26i2 ?. ° Sr i
My commissionezpires first Monday" Of January,
AOPC 315-06
DATE PETERED: 7/24106 2-55:00 PM
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PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FILE COMPL
w
(This proof of service MUST BE FILED WITHIN TEN (10) DAYS AFTER filing of the notice of appeal. CheclL "Plic8le b
--GG Oi
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF as
AFFIDAVIT: I hereby (swear) (affirm) that I served
a copy of the Notice of Appeal, Common Pleas No. 06-4529, upon the District Justice designated therein on
(date of service) 8/9/06 , 20 ? by personal service 70 by (certified) (registered) mail,
sender's receipt attached hereto, and upon the appellee, (name) John Dyson . on
8/9/06 20 ? by personal service by (certified) (registered) mail,
sender's receipt attached hereto.
(SWORN) (AFFIRMED) AND SUBSCRIBED BEFO E ME
THIS k M DAY OF A?.?.??( 20
J _
signature of ic"before wh s made ?-
My commission expires on Z? ° \ 20 6-&
NOTARIAL MEAL
ORONO" O SCHOEN M
Publle
MANOIIl11 TONMSti1 NOfITHAMPTON CNTT
My com""Ien Met % 2M
Signature ofaPo'ani
I
AOPC 312A-02
COMMONWEALTH OF PENNSYLVANIA
N
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COURT OF COMMON PLEAS
Judicial Distounty Of
P
Cusbarlaud
ic?- dp/ti/v4v
NOTICE OF APPEAL
FROM
DISTRICT JUSTICE JUDGMENT
COMMON
APPEAL
I
Notice is given that the appellant has filed in the above Courtof Common Pleas an appeal from the judgment rendered by the District Justice on
the date and in the case referenced below.
Hudson & e. LLC. 09-2-01 I Paula Be Correal
ADDRESS OF APPELLAN CITY STATE ZIP CODE
D F 1 HE OF (Plalnaln., j4 fentla(tt)' .. _.
-24-06 iudaon &;
DOCKET N. e, LLC.. , Jobe"Dyson "
SIGNATURE AM AGIDIT
CV-083-06
This block will be signed ONLY when this notation is required under Pa.
R.C.P.D.J. No. 1008B.
This Notice of Appeal, when received by the District Justice, will operate as a
SUPERSEDEA$ to the judgment for possession in this case.
c,
was
before a District Justice, A COMPLAINT MUST BE FILED within twenty
(20) days after filing the NOTICE of APPEAL.
?. ? Spnfun or..Pioalarlotery ar DaPaY
PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE
(This section of form to be used ONLY when appellant was DEFENDANT (see Pa.R.C.P.D.J. No. 1001(7) i tion be stri'I;Wastice. IF
NOT USED, detach from copy of notice of appeal to be served upon appellee.
PRAECIPE: To Prothonotary
,.,?''"
Enter rule upon appellee(s), to file a complaint in this appeal
Name of appeffee(s)
(Common Pleas No. ) within twenty (20) days after service of rule or suffer entry of judgment of non pros.
Signature ofappeaant or attomey or agent
RULE: To , appellee(s)
Name of appellee(e)
(1) You are notified that a rule is hereby entered upon you to file a complaint in this appeal within twenty (20) days after the date of service
of this rule upon you by personal service or by certified or registered mail. -.. - _----
(2) If you do not file a complaint within this time, a JUDGMENT OF NON PROS MAY BE.ENTERED AGAINST YOU.
(3) The date of servicef this rule if service was by mail is the date of the mailing.
Date ' 20 swietura otpromonptdry or Deputy
YOU xNSNNCLUDE A COPY OF THE NOTICE OF JUD61ENTfTRANSCRiPT FORM WITH THIS NOTICE OF APPEAL.
AOPC 312-02
COURT FILE
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ul 8 HILL DRIVE
M1 CARLISLE, PA 17013
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?L#*7EVSrATj3 RECEIPT ?FO?R,r.ERTIF?IEpD? MAIL
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$0.39 0041111 OR DATE
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HONORABLE PAULA P. CORREAL o?96
MAO. DIST. CT. 09-2-01 (CUMBERLAND)
2260 SPRING ROAD
CARLISLE, PA 17013-3322
P5 POHM 33M
0 UNnWSTAnM RECEIPT FOR ffgnNqED MAIL
PCISTALIMU.
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
HUDSON & KEYSE, LLC
Plaintiff : No. 06-4529 Civil
vs.
JOHN DYSON
Defendant
CIVIL ACTION
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
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, 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 South Bedford Street
Carlisle, PA 17013
(717) 249-3166
AMATO AND ASSOCIATE P.C.
By:
Ronald Amato, Esq., Atty ID #32323
Michael J. Kennedy, Esq., Atty ID #72412
Attorneys for Plaintiff
107 North Commerce Way
Bethlehem, PA 18017
(610) 866-0400
A DEBT COLLECTION LAW FIRM
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
HUDSON & KEYSE, LLC
Plaintiff
VS.
JOHN DYSON
Defendant(s)
No. 06-4529 Civil
CIVIL ACTION
COMPLAINT
The above Plaintiff brings this action against the above Defendant to recover the sum
of $5,141.89, with interest thereon as hereinafter stated, upon the following cause of action:
1. The Plaintiff, HUDSON & KEYSE, LLC is located at 382 Blackbrook Road,
PAINESVILL OH 44077.
2. The Defendant, JOHN DYSON is located at 8 Hill Drive, CARLISLE PA
17013.
3. At the special instance and request of the Defendant, Bank of America, N.A.,
issued to Defendant its Visa credit card, and from time to time thereafter, Defendant made
various purchases, in which transactions Defendant made use of said Visa credit card. A true
and correct copy of a Statement of Defendant's Account, is attached hereto, made a part hereof
and marked Exhibit "A".
4. Plaintiff believes and therefore avers that the original credit application was in
writing but at the time of filing of this suit Plaintiff is not in possession of said application.
5. For value received, Bank of America, N.A. assigned, transferred and set over
to Plaintiff all its rights, title and interest in this claim.
6. By virtue of said assignment, Plaintiff acquired legal title to said Account, and
became the legal holder of the claim against the Defendant.
7. Defendant has not adhered to the agreed repayment obligations that govern the
aforesaid Visa credit card account, by reason of which Defendant is in default thereof.
The Defendant received, accepted and made various purchases using the credit
card described in Exhibit "A", and a total amount which became due as a result thereof, after
allowance for all proper credits for payments and/or adjustments, if any, was $2,960.47.
9. Plaintiff is entitled to receive interest on the above amount determined by
applying the agreed interest rate of 21.99% per annum to the past due balance. As of August
10, 2006 the total amount of interest due to plaintiff is $2,181.42.
10. Plaintiff is entitled to have the 21.99% interest charge continue to accrue as set
forth above, from August 10, 2006 on down to the date of judgment in this matter.
11. The Plaintiff has made demand against the Defendant for the aforesaid sum, but
Defendant failed or refused to pay the same or any part thereof.
WHEREFORE, Plaintiff demands judgment against the Defendant fo$5,141.89together
with the continually accruing interest charge at the agreed rate of 21.99 % per annum from August
10, 2006, and cost of suit.
COUNT II
Alternative to Count I - Unjust Enrichment
12. Plaintiff incorporates the allegations of every paragraph enumerated above of
this Complaint as if said paragraphs were fully set forth here at length.
13. The goods, wares, merchandise, and/or services, described in the exhibits
attached hereto were purchased by Defendant, and Defendant received and accepted the benefit
of such goods, wares, merchandise, and/or services provided by Plaintiff.
14. At all times material hereto, Defendant was aware that Plaintiff was providing
the aforesaid goods, wares, merchandise, and/or services to Defendant, and that Plaintiff
expected to be paid for such.
15. At all times material hereto, Defendant, with the aforesaid knowledge,
permitted Plaintiff to provide and/or deliver said goods, wares, merchandise, and/or services,
and to incur damages.
16. At all times material hereto, Defendant was unjustly enriched by retaining the
benefit of receiving said goods, wares, merchandise, and/or services without paying Plaintiff
fair and reasonable compensation.
17. By reason of the aforesaid unjust enrichment of Defendant at Plaintiff's
expense, an implied contract exists between Plaintiff and Defendant, and Defendant is
obligated to pay Plaintiff the ua arim meruit value of the value of the goods, wares,
merchandise, and/or services described in the exhibits attached hereto, in the amount of
$2,960.47.
WHEREFORE, Plaintiff demands judgment against Defendant for $2,960.47 together
with the continually accruing interest charge at the statutory rate of 6.00% ner annum from
August 10, 2006, costs of suit and all other relief to which Plaintiff may be justly entitled.
AMATO AND ASSOCI S, P.C.
By:
onald Amato, Esq., Atty ID #32323
Michael J. Kennedy, Esq., Atty ID #72412
Attorneys for Plaintiff
107 North Commerce Way
Bethlehem, PA 18017
(610) 866-0400
A DEBT COLLECTION LAW FIRM
VERIFICATION
SUERg hereby states that he/she is the Lf-Sa/ AccT Mbse- of
?/un5o u &4Y461 L ?C Plaintiff in this action, and verifies that the statements
made in the attached Complaint are true and correct to the best of his/her knowledge, information and
belief. The undersigned understands that the statements herein are made subject to the penalties of
18 PA C.S. §4904 relating to unsworn falsification to authorities.
336 101431e0410D50640072Oma+1+
I I',
JOHN J DYSON
BukolAteork;s
0004582 0046047 0296047 4319041005064037
DANK OF AMERICA
PO BOX 5270
CAROL STREAM IL 60197-5270
BOHILL DYSON
CARLISLE PA 17013
Payment Coupon
Aoccunt Ntunbw 4319 0410 0506 4057
RM unzffi k
Past Due Amount 4 286.99
I Minimum Payment Due $ 460.47
Amount Enclosed
e
Make clack or money order payable to Bank of Amarka.
Account Number: 4319 0410 0505 4037
Your Bank of America Visa Account
Account Su
Previous Balance 8 2,823.40
Purdwmm + $24.90
Cash Advances + $0.00
Other DeWb + $64.00
Crests $ 0.00
FINANCE CHARGE + 648.17
-
payments 000
la
Now Balance nce ? $2,960,47
Corresponding Daly Periodic Average Daily Minimum (M) /
APR Rate(DPR) Balence(ADB) Periods : (P) Charge
Purchases 21.99% 0.06026%V $1,996.06 433.71P
Cash 21.99% 0.06025%v $666.97 $ 14.46P
ANNUAL PERCENTAGE RATE 21.99% v-Vad"
BBekolAmorka 4W
IN ACCORDANCE WITH YOUR
CARDHOLDER AGREEMENT,
YOUR ACCOUNT WILL REMAIN
IN PENALTY PRICING FOR
GOING OVERLIMIT ON YOUR
LAST STATEMENT. YOUR
ACCOUNT WILL RETURN TO
THE REGULAR INTEREST
RATE UPON RECEIVING
SEVEN (7) CONSECUTIVE
MONTHS OF ON-TIME
MINIMUM PAYMENTS
WITHOUT GOING OVERUMIT.
Thu Y w elhmor,le Nproawaim dawlraa etla d your nWnted eitl Eaw not CaMaN pr ewlwww which win ma" on the r
24-Hour Custorrw Service 1.900.792.9194 Pay ordinal Visit
For Lost or Stolen Cards 1.800.649.6090 www.bmkolemerice.com
TrWIMIDt10T18 View recenttransactions and Day vow bill onlne atwww.bankofamsdca.com.
POST. TPANS. REF. DESCRIPTION AMOUNT
DATE DATE NO. CA-CREDIT
1014312W 100 ORM720030914
BuillittAffierb +
Access your account online at rwrw.benkolemerice.com.
JOHN J DYSON
Pay online today. Enroll in Online Banidng at www.bankofamerica.oom
24 Tour customer service 1.800.732.9194
For lost or stolen cards 1.800.848.6090
YOUR ACCOUNT IS OVER 90 DAYS PAST DUE AND CLOSED TO FUTURE USE. THIS
PAST DUE RATING IS BEING REPORTED TO THE CREDIT BUREAUS. TO AVOID
FURTHER ACTION, REMIT THE -MIN PAYMENT DUE' IMMEDIATELY. CALL OUR
COLLECTIONS DEPARTMENT AT 1-(800)-898.6618.
rs.2d2
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Joseph K. Goldberg, Esquire
2080 Linglestown Road, Suite 106
Harrisburg, PA 17110
(717) 703-3600
jgoldberg@ssbc-law.com
PA ID #46782
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
HUDSON & KEYSE, LLC,
V.
JOHN DYSON,
Plaintiff NO. 06-4529 CIVIL TERM
CIVIL ACTION - LAW
Defendant JURY TRIAL DEMANDED
NOTICE TO PLEAD
TO: Hudson & Keyse, LLC
c/o Michael J. Kennedy, Esquire/Amato and Associates, P.C.
You are hereby notified to file a written response to the enclosed Preliminary
Objection within twenty (20) days from service hereof or a judgment may be
against you.
Attorney ID No.
2080 Linglesto%
Harrisburg, P/?
? Road, Suite 106
7110
Attorney
Date:
Joseph K. Goldberg, Esquire
2080 Linglestown Road, Suite 106
Harrisburg, PA 17110
(717) 703-3600
jgoldherg@ssbc-law.com
PA ID #46782
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
HUDSON & KEYSE, LLC,
Plaintiff NO. 06-4529 CIVIL TERM
V.
CIVIL ACTION - LAW
JOHN DYSON,
Defendant JURY TRIAL DEMANDED
DEFENDANT'S PRELIMINARY OBJECTIONS TO COMPLAINT
AND NOW COMES the Defendant, John Dyson, by and through his attorney,
Joseph K. Goldberg, Esquire, who files these Preliminary Objections to the Plaintiffs
Complaint, as follows:
1. In this matter, the Plaintiff is attempting to collect a debt it alleges the
Defendant originally owed to a credit card issuing bank, which debt was subsequently
purchased by the Plaintiff.
2. This matter is an appeal by Plaintiff of an judgment in favor of the
Defendant issued by Magisterial District Judge Paula P. Correal on July 24, 2006.
3. The Defendant was served with the Complaint in this case on August 10,
2006.
First Preliminary Objection - Pa. R.Civ. P. No. 1028(a)(2) - Failure to conform to
rule of court (failure to attach contract upon which claim is based)
4. The first claim of the Plaintiff in its Complaint is for breach of a written
contract between the Plaintiffs alleged predecessor and the Defendant.
5. The Plaintiff has failed to attach a copy of the contract between the
Defendant and any party in interest, including the assignor(s) of the Plaintiff. The only
document attached to the Plaintiffs Complaint is Exhibit A, an incomplete electronic
reproduction of a what appears to be a monthly statement issued by Bank of America,
which is undated, although it states that a payment due date is April 8, 2003. Exhibit A
states at the bottom of both pages that it does not contain language which was included
in the original of that document. The attachment is not a contract and does not indicate
that the Defendant entered into an agreement with any party. It does not provide the
contractual basis for the amounts claimed by the Plaintiff in its Complaint, including
interest it asserts is owed by the Defendant.
6. Pursuant to Pa. R.Civ. P. No. 1019(i), the Plaintiff is required to attach to
the Complaint copies of all writings upon which its claims are based.
7. By failing to attach a copy of the contract upon which the Complaint is
based, the Complaint does not comply with an express rule of court, in violation of Pa.
R.Civ. P. No. 1028(a)(2).
Second Preliminary Objection - Pa. R.Civ. P. No. 1028(a)(2) - Failure to conform to
rule of court (failure to attach written assignments of debts)
8. The Plaintiff asserts that it is the assignee of a predecessor to whom the
Defendant allegedly owed the debt. Since the Plaintiffs right to a judgment is
predicated upon a written assignment, that writing must be attached to the Complaint,
pursuant to Pa. R.Civ. P. No. 1019(i).
9. By failing to attach a copy of the assignment of the debt to the Plaintiff,
2
the Complaint does not comply with an express rule of court, in violation of Pa. R.Civ.
P. No. 1028(a)(2).
Third Preliminary Objection - Pa. R.Civ. P. No. 7028(a)(2) - Failure to conform
to rule of court (failure to provide sufficient details of amounts
allegedly owed to Plaintiff)
10. The Complaint contains only a bald assertion of the amount the Plaintiff
claims is owed by the Defendant. It provides no detail as to the date(s) on which the
debts were incurred, the amounts incurred on each date, the dates or amounts of
payments, nor dates of accrua, and amounts, of interest charges.
11. In Count II', the Plaintiff seeks recovery on a theory of unjust enrichment,
asserting the Defendant benefitted from items purchased through this account.
However, other than what appears to be a $24.90 charge for a magazine subscription
as listed on the Exhibit attached to the Complaint, the Plaintiff has not listed any items
or values for the same to substantiate its claim for unjust enrichment.
12. The document attached as Exhibit A does not contain any of the requisite
details of the account, as required by Pa. R.Civ. P. No. 1019(a).
13. By failing to provide the details of the items allegedly purchased and the
values of the same, the Complaint does not comply with an express rule of court, in
violation of Pa. R.Civ. P. No. 1028(a)(2).
'There is no Count I delineated in the Complaint.
3
WHEREFORE, the Defendant demands that his Preliminary Objections be
sustained, and the Plaintiffs Complaint be dismissed.
Respectfully submitted,
ID No.
Date: d-6"0
Harrisburg, PA 7110
(717)703-360
Attorney for De ndar
4
106
CERTIFICATE OF SERVICE
1, the undersigned, hereby certify that on the &/ ? day of , 2006,1
served a copy of the foregoing Defendant's Preliminary Objections to Complaint, by
first-class mail, postage prepaid, upon the following:
Michael J. Kennedy, Esquire
Amato and Associates, P.C.
107 North Commerce Way
Bethlehem, PA 18017
Attorney for Plaintiff
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COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
HUDSON & KEYSE, LLC
Plaintiff : No. 06-4529 Civil
VS.
JOHN DYSON
: CIVIL ACTION
Defendant(s)
CERTIFICATE OF SERVICE
The undersigned certifies that a true and correct copy of Plaintiff's Complaint was
served via first class mail; postage prepaid ow August 18, 2006:
Joseph K. Goldberg, Esq.
1080 Linglestown Road, Ste 106
"Harrisburg, PA 17110
AMATO AND ASSOCIATES .C.
By:
- - 11*??
onald Amato, Esq., Atty ID #32323
Michael J. Kennedy, Esq., Atty ID #72412
Attorneys for Plaintiff
107 North Commerce Way
Bethlehem, PA 18017
(610) 866-0400
A DEBT COLLECTION LAW FIRM
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COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
HUDSON & KEYSE, LLC
Plaintiff : No. 06-4529 Civil
VS.
JOHN DYSON
Defendant
CIVIL ACTION
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
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, 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 South Bedford Street
Carlisle, PA 17013
(717) 249-3166
AMATO AND ASSOCIATES, P.C.
By:
Ronald-Amato, q., Atty ID #32323
Michael J. Kennedy, Esq., Atty ID #72412
Attorneys for Plaintiff
107 North Commerce Way
Bethlehem, PA 18017
(610) 866-0400
A DEBT COLLECTION LAW FIRM
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
HUDSON & KEYSE, LLC
Plaintiff : No. 06-4529 Civil
vs.
JOHN DYSON
CIVIL ACTION
Defendant(s)
AMENDED COMPLAINT
The above Plaintiff brings this action against the above Defendant to recover the sum
of $5,970.82, with interest thereon as hereinafter stated, upon the following cause of action:
1. The Plaintiff, HUDSON & KEYSE, LLC is located at 382 Blackbrook Road,
PAINESVILL OH 44077.
2. The Defendant, JOHN DYSON is located at 8 Hill Drive, CARLISLE PA
17013.
3. At the special instance and request of the Defendant, Bank of America, N.A.,
issued to Defendant its Visa credit card, and from time to time thereafter, Defendant made
various purchases, in which transactions Defendant made use of said Visa credit card. A true
and correct copy of a Statement of Defendant's Account are attached hereto, made a part
hereof and marked Exhibit "A". A true and correct copy of the terms and conditions of said
account are attached hereto, made a part hereof and marked Exhibit "B".
4. Plaintiff believes and therefore avers that original request for credit was in
writing but that it is not in possession of the original credit application but same has been
requested from Bank of America, N.A.
5. Defendant opened said account on or about February 6, 2001.
6. Defendant's last payment on said account was made on or about October 14,
2002.
7. For value received, Bank of America, N.A. assigned, transferred and set over
to The Sagres Company all its rights, title and interest in this claim. A true and correct copy
of the Bill of Sale is attached hereto, made a part hereof, and marked Exhibit "C".
By virtue of said assignment, The Sagres Company acquired legal title to said
Account, and became the legal holder of the claim against the Defendant.
9. For value received, The Sagres Company assigned, transferred and set over to
Plaintiff all its rights, title and interest in this claim. A true and correct copy of the Bill of
Sale is attached hereto, made a part hereof, and marked Exhibit "D".
10. By virtue of said assignment, Plaintiff acquired legal title to said Account, and
became the legal holder of the claim against the Defendant.
11. Defendant has not adhered to the agreed repayment obligations that govern the
aforesaid Visa credit card account, by reason of which Defendant is in default thereof.
12. The Defendant received, accepted and made various purchases using the credit
card described in Exhibit "A", and a total amount which became due as a result thereof, after
allowance for all proper credits for payments and/or adjustments, if any, was $2,960.47.
13. Plaintiff is entitled to receive interest on the above amount determined by
applying the agreed interest rate of 21.99% per annum to the past due balance. As of August
10, 2006 the total amount of interest due to plaintiff is $2,181.42.
14. Plaintiff is entitled to have the 21.99% interest charge continue to accrue as set
forth above, from August 10, 2006 on down to the date of judgment in this matter.
15. Defendant further agreed to pay Plaintiff's reasonable attorneys' fees incurred in
the collection of any balance due Plaintiff. Presently, Plaintiff is due attorneys' fees in the
amount of $828.93, for a total due of $5,970.82.
16. The Plaintiff has made demand against the Defendant for the aforesaid sum, but
Defendant failed or refused to pay the same or any part thereof.
WHEREFORE, Plaintiff demands judgment against the Defendant for $5,970.82 together
with the continually accruing interest charge at the agreed rate of 21.99% per annum from August
10, 2006, and cost of suit.
COUNT II
Alternative to Count I - Unjust Enrichment
17. Plaintiff incorporates the allegations of every paragraph enumerated above of
this Complaint as if said paragraphs were fully set forth here at length.
18. The extension of credit described in the exhibits attached hereto was provided to
Defendant, and Defendant received and accepted the benefit of such extension of credit
provided by Plaintiff.
19. At all times material hereto, Defendant was aware that Plaintiff was providing
the aforesaid extension of credit to Defendant, and that Plaintiff expected to be repaid for
such.
20. At all times material hereto, Defendant, with the aforesaid knowledge,
permitted Plaintiff to provide the extension of credit and to incur damages.
21. At all times material hereto, Defendant was unjustly enriched by retaining the
benefit of receiving said credit without paying Plaintiff fair and reasonable compensation.
22. By reason of the aforesaid unjust enrichment of Defendant at Plaintiffs
expense, an implied contract exists between Plaintiff and Defendant, and Defendant is
obligated to pay Plaintiff the quantum mentit value of the value of the extension of credit
described in the exhibits attached hereto, in the amount of $2,960.47.
WHEREFORE, Plaintiff demands judgment against Defendant for $2,960.47 together
with the continually accruing interest charge at the statutory rate of 6.00% per annum from
August 10, 2006, costs of suit and all other relief to which Plaintiff may be justly entitled.
AMATO AND ASSOCIATES, P.C.
By:
Michael J. Kennedy, Esq., Atty ID #72412
Attorneys for Plaintiff
107 North Commerce Way
Bethlehem, PA 18017
(610) 866-0400
A DEBT COLLECTION LAW FIRM
VERIFICATION
Nancy A. Quere, hereby states that she is the Legal Account Manager of
Hudson and Keyse, L.L.C. Plaintiff in this action, and verifies that the
statements made in the attached Complaint are true and correct to the best of
her knowledge, information and belief. The undersigned understands that the statements
herein are made subject to the penalties of 18 PA C.S. 4904 relating to unsworn
falsification to authorities.
3 101431OD410050640372DO30314
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JJOH L DYSON
CAR SLE PA 17013
JOHN J DYSON
Account Number. 4319 0410 0506 4037
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PAST DUE RATING IS BEING REPORTED TO THE CREDIT BUREAU& TO AVOID
FURTHER ACTION, REMIT THE WIN PAYMENT DUE' IMMEDIATELY. CALL OUR
COLLECTIONS DEPARTMENT AT 1{800}833-5618.
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05/24/2006 13:49 14403541336 PAGE 02
11/89/2005 23:21 8583344493 THE SAGRES COMPANY PAGE 02
EXHIBIT A
. Bank of America, N.A. (USA) C Seller"), for value raosived and pursuant to the [Leine
and oaMitlons of a Aaccoyqqtt Sale Agr0eaid?t ('Agnmrdant' between Sella[ Wd The Sages
company murn, datad?TJ 7K Wi?/n ?5 . does herby sa assign and
convey to Ruyan, is oueceaso s and assigns, $ll right. title sad ufti t of SeMr in and to those
cauln Accounts as daSued in the Agreement and as ad forth on Eablbit B, within recourse and
without rapresarltation of or warranty of collectibility, or oth vhw, axe%* to the extant provided
for within the Agreement.
P7C6C[JTED this day of V?i, .iavc,
Bank of America, N.A. (USA)
By:__!
PritAed Name and Title
p? ACKNOWLEDGMENT
STATE OF J 1L1? & I vu,.
COUNTY OF CAM j d SS
before me on . a ,sx ?by
-- - as
of Bank of
Stgtuimm of Notarial officer
Ny?1 ?
Title sad Rook
ZC?
MyCommiWonExpiros jLLu 7,
EXHIBIT B
B DP
The Sagres Company, ("Seller"), for value received and pursuant to the terms and
conditions of 4 Account Sale Agreement ("Agreement") between Seller and Hudson 6t Key,
LLC ("Boyer"), dated October 3, 2105; does hereby sell, assign and convey to Bayer, its
successors and assigns, all right, title and interest of Seller in and to those certain Accounts as
defined its the Agreement and as set forth on Exhibit A, without recourse and without
representation of or warranty of collectibility, or otherwise, except to the extent provided for
within the Agreement.
EXECUTED this I? day of (C{ -t-b 8k k ,
The gre Colnpa
By.
r
Printed Ha and Title U P C ? d?t5• p>utJe? 0 t3
ACKNOWLEDGMENT
STATE DP t f} j; :7o 2 NJ I a
Ss
COUNTY m SAN b(C&
acknowledged before me on D C 1708c . 1' tZOO 5", by
tat ,aT7-t as
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Title and Bank.
My Commission Expires AN t4 Agz,
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048MYC CARF
CCF MUSIOn # 140301 8agm HOA Cvvtwt FINAL.jg 092W Nalafr Fub40-CdbM10 ''.
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Joseph K. Goldberg, Esquire
2080 Linglestown Road, Suite 106
Harrisburg, PA 17110
(717) 703-3600
j goldberg@ssbc-law. corn
PA ID #46782
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
HUDSON & KEYSE, LLC,
Plaintiff' NO. 06-4529 CIVIL TERM
V.
CIVIL ACTION - LAW
JOHN DYSON,
Defendant JURY TRIAL DEMANDED
?I
NOTICE TO PLEAD
TO: Hudson & KeYse LL
c/o Michael J. Kenne dy, Esquire/Amato and Associates, P.C.
You are ill
hereby notified to file a written response to the enclosed Preliminary
Objection within twenty (20)Idays from service hereof or a judgment may be entered
against you.
Date:
=-' h old r ,Esquire
ey ID No 782
080 Lingles n Road, Suite 106
Harrisburg, A 17110
(717)703- 600
Attorney for Defendant
Joseph K. Goldberg, Esquire
2080 Linglestown Road, Suite 106
Harrisburg, PA 17110
(717) 703-3600
jgoldberg@ssbc-law.com
PA ID #46782
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
HUDSON & KEYSE, LLC,
Plaintiff
NO. 06-4529 CIVIL TERM
V.
CIVIL ACTION - LAW
JOHN DYSON,
Defendant JURY TRIAL DEMANDED
DEFENDANT'S PRELIMINARY OBJECTIONS TO AMENDED COMPLAINT
III
AND NOW COMES the Defendant, John Dyson, by and through his attorney,
Joseph K. Goldberg, Esquire, who files these Preliminary Objections to the Plaintiff's
Amended Complaint, as folly ws:
1. In this matter, he Plaintiff is attempting to collect a debt it alleges the
Defendant originally owed t a credit card issuing bank, which debt was subsequently
purchased by the Plaintiff.
2. This matter is an appeal by Plaintiff of an judgment in favor of the
Defendant issued by Magisterial District Judge Paula P. Correal on July 24, 2006.
3. The Defendant was served with the original Complaint in this case on
August 10, 2006.
4. After the Defendant filed Preliminary Objections on August 22, 2006, the
Plaintiff filed its Amended Complaint on or about August 31, 2006.
First Preliminary Objection - Pa. R.C.P. No. 1028(a)(2) - Failure to conform to rule
of court (failure to attach contract upon which claim is based)
5. The first claim of the Plaintiff in its Amended Complaint is for breach of a
written contract between thle Plaintiff's alleged predecessor and the Defendant.
6. The Plaintiff has failed to attach a copy of the contract between the
Defendant and any party in' interest, including the assignor(s) of the Plaintiff.
7. The document attached to the Plaintiff's Amended Complaint as Exhibit A,
is an incomplete electronic reproduction of a what appears to be a monthly statement
issued by Bank of America,) which is undated, although it states that a payment due
date is April 8, 2003. Exhibit A states at the bottom of both pages that it does not
contain language which was included in the original of that document. The attachment
I
is not a contract and does not indicate that the Defendant entered into an agreement
with any party. It does not provide the contractual basis for the amounts claimed by the
Plaintiff in its Amended Corrhplaint, including interest it asserts is owed by the
Defendant.
8. The Plaintiff failed to attach a copy of the written agreement between the
parties. It attached as Exhibit B a generic form titled "Cardmember Agreement;"
however, it is not signed by the Defendant. The Plaintiff failed to attach the writing it
alleges was signed by the Defendant that purportedly forms the basis for the claim by
the Plaintiff.
9. Pursuant to Pa. R.C.P. No. 1019(i), the Plaintiff is required to attach to the
Amended Complaint copies f all writings upon which its claims are based.
10. By failing to aft ch a copy of the signed contract upon which the Amended
2
Complaint is based, the Amended Complaint does not comply with an express rule of
court, in violation of Pa. R.O.P. No. 1028(a)(2).
Second Preliminary Objection - Pa. R.C.P. No. 1028(a)(2) - Failure to conform to
rule of court (failure to attach written assignments of debts)
11. The Plaintiff asserts that it is the assignee of a predecessor to whom the
Defendant allegedly owed the debt. Since the Plaintiff's right to a judgment is
predicated upon a written assignment, that writing must be attached to the Amended
Complaint, pursuant to Pa. 'R.C.P. No. 1019(1).
12. Attached at Exhibits C and D are documents purported to be written
evidence of the sale of "certain Accounts" from predecessors to the Plaintiff.
I
13. Exhibits C is q Bill of Sale which states that it relates to accounts "as
defined in the Agreement and as set forth in Exhibit B...." However, no such Agreement
is attached, and there is no 'document that identifies the Defendant's account as one
that was part of the transaction evidenced by Exhibit C.
14. Exhibits D states that it is a Bill of Sale which relates to accounts "as
defined in the Agreement and as set forth in Exhibit A...." However, no such Agreement
is attached, and there is no document that identifies the Defendant's account as one
that was part of the transaction evidenced by Exhibit D.
15. By failing to attach a copy of the assignments of the Defendant's account
to the Plaintiff, the Amended Complaint does not comply with an express rule of court,
in violation of Pa. R.C.P. Nod 1028(a)(2).
3
Third Preliminary Objection - Pa. R.C.P. No. 1028(a)(2) - Failure to conform
to rule of court ((failure to provide sufficient details of amounts
allegedly owed to Plaintiff)
16. The Amended Complaint contains only a bald assertion of the amount the
Plaintiff claims is owed by the Defendant. It provides no detail as to the date(s) on
which the debts were incur?ed, the amounts incurred on each date, the dates or
amounts of payments, nor dates of accrual and amounts of interest charges.
17. In Count II', the Plaintiff seeks recovery on a theory of unjust enrichment,
asserting the Defendant bepefitted from items purchased through this account.
However, other than what appears to be a $24.90 charge for a magazine subscription
on Exhibit A, the Plaintiff he is not listed any items, or values for the same, to
substantiate its claim for un?ust enrichment.
18. The document attached as Exhibit A does not contain any of the requisite
details of the account, as required by Pa. R.C.P. No. 1019(a).
19. By failing to provide the details of the items allegedly purchased and the
values of the same, the Amended Complaint does not comply with an express rule of
court, in violation of Pa. R.C.P. No. 1028(a)(2).
I
'There is no Count I Delineated in the Amended Complaint.
4
WHEREFORE, the [?efendant demands that his Preliminary Objections be
sustained, and the Plaintiff's Amended Complaint be dismissed.
r
ly subm' d,
o ey ID No. 4678
2080 Linglestown ac , Suite 106
Harrisburg, PA 1/?l 1?}'
(717)703-360
Attorney for VeXi?lant
5
CERTIFICATE OF SERVICE
I, the undersigned, h reby certify that on thec ` day of ?4, 2006,
served a copy of the forego ng Defendant's Preliminary Objections to Amended
Complaint, by first-class m il, postage prepaid, upon the following:
Michael J. Kennedy, Esquire
Amato and Associates, P.C
107 North Commerce Way
Bethlehem, PA 18017
Attorney for Plaintiff
ci
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
HUDSON & KEYSE, LLC
Plaintiff No. 06-4529 Civil
VS.
JOHN DYSON
CIVIL ACTION
Defendant(s)
CERTIFICATE OF SERVICE
The undersigned certifies that a true and correct copy of Plaintiff's Amended
Complaint was served via first class mail, postage prepaid on September 7, 2006:
Joseph K. Goldberg, Esq.
2080 Linglestown Road, Ste 106
Harrisburg, PA 17110
AMATO AND ASSOCIATE P.C.
By:
R nald Amato, Esq., Atty ID #32323
Michael J. Kennedy, Esq., Atty ID #72412
Attorneys for Plaintiff
107 North Commerce Way
Bethlehem, PA 18017
(610) 866-0400
A DEBT COLLECTION LAW FIRM
t--, r?
i
'.`r -
C_
_,
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
HUDSON & KEYSE, LLC
Plaintiff
vs.
JOHN DYSON
No. 06-4529 Civil
CIVIL ACTION
Defendant(s)
PLAINTIFF'S ANSWER TO DEFENDANT'S PRELIMINARY OBJECTIONS TO
PLAINTIFF'S AMENDED COMPLAINT
The above Plaintiff files the within answer to Defendant's preliminary objections and
sets for the following:
1. Admitted.
2. Admitted.
3. Admitted.
4. Admitted that Defendant filed preliminary objections to Plaintiff's complaint.
Plaintiff filed an amended complaint on September 6, 2006
FIRST PRELIMINARY OBJECTION
PA.R.C.P. NO. 1028(a)(2) Failure to Conform to Rule of Court
5. Admitted.
6. Denied. Plaintiff has complied with Pa.R.C.P.No. 1019(i).
7. The complaint is a written document which speaks for itself and any
interpretation of said document by Defendant is denied. The documents provide sufficient
information such that Defendant can plead to Plaintiffs complaint.
8. The complaint is a written document which speaks for itself and any
interpretation of said document by Defendant is denied. The documents provide sufficient
information such that Defendant can plead to Plaintiffs complaint.
9. Denied. Plaintiff need not attach the writing if it is not available to the
Plaintiff.
• 10. Denied. Plaintiff has complied with Pa.R.C.P.No. 1019(1).
WHEREFORE, Plaintiff respectfully requests that Defendant's Preliminary objections
be denied.
SECOND PRELIMINARY OBJECTION
PA.R.C.P. NO. 1028(a)(2) Failure to Conform to Rule of Court
11. Denied. Plaintiff has complied with Pa.R.C.P.No. 1019(1). The rule does not
require Plaintiff to attach the writing if it is not available to the Plaintiff.
12. Admitted.
13. Denied. The agreements of sale were attached to Plaintiff's complaint. The full
assignment is a confidential document the public release of which could potentially harm
Plaintiff. Plaintiff would be willing to provide Defendant with the full documentation upon a
stipulation that said documentation will not be disclosed to any other party or person and will
be kept confidential and only used in the within litigation.
14. Denied. The agreements of sale were attached to Plaintiff's complaint. The full
assignment is a confidential document the public release of which could potentially harm
Plaintiff. Plaintiff would be willing to provide Defendant with the full documentation upon a
stipulation that said documentation will not be disclosed to any other party or person and will
be kept confidential and only used in the within litigation.
15. Denied. This averment constitutes a conclusion of law to which no response is
required under the Pennsylvania Rules of Civil Procedure. Without waiving the foregoing and
to the extent a response may be required, Plaintiff specifically denies this averment.
WHEREFORE, Plaintiff respectfully requests that Defendant's Preliminary objections
be denied.
SECOND PRELIMINARY OBJECTION
PA.R.C.P. NO. 1028(a)(2) Failure to Conform to Rule of Court
16. Denied. The documentation attached to the complaint clearly show the original
credit grantor, it traces the title from the original credit grantor to Plaintiff, it shows the
• principal and interest balances, it states when the account was opened and when the last
payment was made.
17. Admitted. However, Plaintiff's right to pursue this cause of action is based on
the original credit grantor's rights. The unjust enrichment is not the items which Defendant
purchased but the credit provided to Defendant so that Defendant could purchase said items.
18. Denied. This averment constitutes a conclusion of law to which no response is
required under the Pennsylvania Rules of Civil Procedure. Without waiving the foregoing and
to the extent a response may be required, Plaintiff specifically denies this averment.
19. Denied. This averment constitutes a conclusion of law to which no response is
required under the Pennsylvania Rules of Civil Procedure. Without waiving the foregoing and
to the extent a response may be required, Plaintiff specifically denies this averment.
WHEREFORE, Plaintiff respectfully requests that Defendant's Preliminary objecitons
be denied.
AMATO AND ASSOCIATES, P.C.
By:
Ronald A , Esq., Atty ID #32323
Michael J. Kennedy, Esq., Atty ID #72412
Attorneys for Plaintiff
107 North Commerce Way
Bethlehem, PA 18017
(610) 866-0400
A DEBT COLLECTION LAW FIRM
9n
N
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
HUDSON & KEYSE, LLC
Plaintiff
VS.
JOHN DYSON
Defendant(s)
No. 06-4529 Civil
CIVIL ACTION
CERTIFICATE OF SERVICE
The undersigned certifies that a true and correct copy of Plaintiff's Answer to
Defendant's Preliminary Objections to Plaintiff's Amended Complaint was served via first
class mail, postage prepaid on September 18, 2006:
Joseph K. Goldberg, Esq.
2080 Linglestown Road, Ste 106
Harrisburg, PA 17110
AMATO AND ASSOCIATES,
By:
onald Amato, Esq., Atty ID #32323
Michael J. Kennedy, Esq., Atty ID #72412
Attorneys for Plaintiff
107 North Commerce Way
Bethlehem, PA 18017
(610) 866-0400
A DEBT COLLECTION LAW FIRM
CZ d p
c'• -rs
fTl rn-M
co
IV - .
PRAECIPE FOR LISTING CASE FOR ARGUMENT
(Must be typewritten and submitted in duplicate)
TO THE PROTHONOTARY OF CUMBERLAND COUNTY:
Please list the within matter for the next Argument Court.
CAPTION OF CASE
(entire caption must be stated in full)
Hudson & Keyse, LLC
VS.
(Plaintiff)
John Dyson
(Defendant)
No. n h=° R? a , C iAxi 1 Term
State matter to be argued (i.e., plaintiff's motion for new trial, defendant's demurrer to
complaint, etc.):
Defendant's Preliminary Objections to
Amended Complaint
4.
Identify counsel who will argue cases:
(a) for plaintiff:
Michael J Kennedy, 107 North rnmmP-rCP Way
(Name and Address)
Bethlehem PA 18017
(b) for defendant:
Joseph K Goldberg 2080 LinglP--;tnwn Road
(Name and Address)
Harrisburg. PA 17110
I will notify all parties in writing within two days that this case has been listed for argument.
Defendant
Date: October 6. 2 0 0 6 Attorney for
CD
??
•
PRAECIPE FOR LISTING CASE FOR ARGUMENT
(Must be typewritten and submitted in duplicate)
TO THE PROTHONOTARY OF CUMBERLAND COUNTY:
Please list the within matter for the next Argument Court.
CAPTION OF CASE
(entire caption must be stated in full)
Hudson & Keyse, LLC
(Plaintiff)
VS.
John Dyson
(Defendant)
No. n6-4529 , CiNXi I Term
1. State matter to be argued (i.e., plaintiff's motion for new trial, defendant's demurrer to
complaint, etc.):
Defendant's Preliminary Obiections to
Amended Complaint
2. Identify counsel who will argue cases:
(a) for plaintiff:
Michael J Kennedy, 107 North rammerr-A way
(Name and Address)
Bethlehem PA 18017
(b) for defendant:
Joseph K Goldberg 2080 LinglPstnwn Road
(Name and Address)
Harrisburg. PA 17110
3. I will notify all parties in writing within two days that this case has been listed for argument.
4. Argument Court Date:
December 6, 2006
re
ose h K. Goldber
Print your name
Defendant
Date: O t oher 6., 2006 Attorney for
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COURT OF COMMON PLEASI? OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
HUDSON & KEYSE, LLC
Plaintiff
No. 06-4529 Civil
VS.
JOHN DYSON
CIVIL ACTION
I
Defendant(s)
CERTIFICATE OF SERVICE
The undersigned certifies thatla true and correct copy of Plaintiff's Brief in
Opposition to Defendant's Preliminary Objections to Plaintiff's Amended Complaint was
served via first class mail, postage prepaid on November 22, 2006:
Joseph . Goldberg, Esq.
2080 Li glestown Road, Ste 106
Harrisbu g, PA 171 10
AMATO AND ASSOCIA S, P.C.
By:
Ronald Amato, Esq., Atty ID #32323
Michael J. Kennedy, Esq., Atty ID #72412
Attorneys for Plaintiff
107 North Commerce Way
Bethlehem, PA 18017
(610) 866-0400
A DEBT COLLECTION LAW FIRM
Cl)
co
HUDSON & KEYSE, LLC,
Plaintiff
vs.
JOHN DYSON,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 06-4529 CIVIL
IN RE: DEFENDANT'S PRELIMINARY OBJECTIONS TO
PLAINTIFF'S AMENDED COMPLAINT
BEFORE BAYLEY, P.J. AND HESS, J.
ORDER
AND NOW, this Z i -' day of January, 2007, following argument thereon and
review of the briefs submitted by the parties, the preliminary objections of the defendant to the
plaintiff's amended complaint are DENIED.
BY THE COURT,
A ?"ichael J. Kennedy, Esquire
For the Plaintiff
J°"seph K. Goldberg, Esquire
For the Defendant
:rim
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60
Joseph K. Goldberg, Esquire
2080 Linglestown Road, Suite 106
Harrisburg, PA 17110
(717) 703-3600
jgoldberg@ssbc-law.com
PA 1D #46782
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
HUDSON & KEYSE, LLC,
Plaintiff NO. 06-4529 CIVIL TERM
V.
: CIVIL ACTION - LAW
JOHN DYSON,
Defendant JURY TRIAL DEMANDED
ANSWER WITH NEW MATTER
AND NOW COMES the Defendant, by and through his attorney, Joseph K.
Goldberg, who Answers the Amended Complaint in this case and files his New Matter,
as follows:
ANSWER
1. Admitted.
2. Admitted.
3. It is denied that Exhibit A is a correct copy of a Statement of Defendant's
account, and strict proof thereof is demanded. It is denied that Exhibit B is a true and
correct copy of the terms and conditions of an account which the Defendant had with
the Plaintiff. Defendant does not know what is meant by the term "special instance,"
and, after reasonable investigation, is unable to admit or deny the averments which
include that term. It is admitted that at one time, the Defendant, together with his wife,
had a credit card account with Bank of America, N.A. It is admitted that Defendant
.
made use of the credit card account, although purchases made on the account were
made mostly by the Defendant's wife.
4. After reasonable investigation, the Defendant is without the sufficient
information or knowledge with which to admit or deny the averments of paragraph 4,
including those as to the Plaintiff making a request to Bank of America, N.A., for
documents, and the averments are therefore denied. It is admitted that no such written
application was attached to the Amended Complaint.
5. After reasonable investigation, the Defendant is without sufficient
information or knowledge with which to admit or deny the averments of paragraph 5,
and the averments are therefore denied.
6. Denied. To the contrary, upon information and belief, the last payment on
the Defendant's credit card account with Bank of America, N.A., was much earlier in
time.
7. After reasonable investigation, the Defendant is without sufficient
information or knowledge with which to admit or deny the averments of paragraph 7,
and the averments are therefore denied. In addition, the averments of paragraph 7 are
conclusions of law to which no response is required. By way of further denial, the
alleged Bill of Sale attached to the Amended Complaint as Exhibit C, does not define
the terms of a transaction between any parties, but only refers to an agreement, a copy
of which and terms of which are not attached to the Amended Complaint.
8. The averments of paragraph 8 are conclusions of law to which no
response is required. To the extent that a response is required, the averments are
denied and strict proof thereof demanded.
2
9. After reasonable investigation, the Defendant is without sufficient
information or knowledge with which to admit or deny the averments of paragraph 9,
and the averments are therefore denied. In addition, the averments of paragraph 9 are
conclusions of law to which no response is required. By way of further denial, the
alleged Bill of Sale attached to the Amended Complaint as Exhibit D, does not define
the terms of a transaction between any parties, but only refers to the actual agreement,
a copy of which and terms of which are not attached to the Amended Complaint.
10. The averments of paragraph 10 are conclusions of law to which no
response is required. To the extent that a response is required, the averments are
denied and strict proof thereof demanded.
11. The averment that the Defendant is in default is a conclusion of law to
which no response is required. To the extent that a response is required, the
Defendant denies the averments and strict proof thereof is demanded.
12. It is denied that the total amount which became due as a result of
purchases, including adjustments, is $2,960.47. It is denied that Exhibit A describes
the Defendant's credit card, or purchases made with it. It is admitted that the
Defendant made purchases using the credit card account.
13. The averments of paragraph 13 are conclusions of law to which no
response is required. To the extent that a response is required, the averments are
denied and strict proof thereof demanded.
14. The averments of paragraph 14 are conclusions of law to which no
response is required. To the extent that a response is required, the averments are
denied and strict proof thereof demanded.
3
15. The averments of paragraph 15 are conclusions of law to which no
response is required. To the extent that a response is required, the averments are
denied and strict proof thereof demanded. After reasonable investigation, the
Defendant is without sufficient information or knowledge with which to admit or deny the
averments of paragraph 15 as to the reasonableness or amount of attorney's fees
incurred by the Plaintiff, and the averments are therefore denied.
16. To the extent that the averments of paragraph 16 imply that the
Defendant agreed with the amount demanded by the Plaintiff, the averments are
denied. To the contrary, the Defendant denies that he owes the amount claimed by the
Plaintiff.
WHEREFORE, the Defendant demands judgment in his favor and against the
Plaintiff, with costs assessed against the Plaintiff.
COUNT II
17. The averments of paragraph 17 are incorporation by reference of the
previous 16 paragraphs, and no additional response is required.
18. Denied. To the contrary, the Plaintiff has never extended any credit of
any nature to the Defendant. By way of further denial, the exhibits attached to the
Amended Complaint do not describe credit extended to the Defendant. None are the
agreement between the Defendant and the original extender of credit, and they contain
inherently conflicting terms.
19. Denied. To the contrary, the Plaintiff has never provided or extended any
type of credit of any nature to the Defendant, and therefore could never be "repaid" for
any credit.
4
20. Denied. To the contrary, the Plaintiff has never provided or extended any
type of credit of any nature to the Defendant, nor did the Defendant ever permit the
Plaintiff to do so. For the same reasons, it is denied that the Plaintiff incurred damages
as a result of it extending credit to the Defendant.
21. Denied. To the contrary, the Plaintiff was never entitled to payment of fair
and reasonable compensation for credit extended to the Defendant. By way of further
denial, upon information and belief, the only loss possibly incurred by the Plaintiff was
the minuscule amount Plaintiff paid to a third-party to purchase an account in the name
of the Defendant.
22. The averments of paragraph 22 are conclusions of law to which no
response is required. To the extent that a response is required, the averments are
denied and strict proof thereof demanded. To the contrary, as the Plaintiff never
extended credit to the Defendant, nor were there any transactions between the parties,
there could be no implied contract between the parties. By way of further denial, it is
denied that the "quantum meruit value of the value of the extension of credit described
in the exhibits attached to" the amended Complaint is $2,960.47, and strict proof
thereof is demanded.
WHEREFORE, the Defendant demands judgment in his favor and against the
Plaintiff, with costs assessed against the Plaintiff.
NEW MATTER
23. The Plaintiff's claims are barred by the statute of limitations.
24. The Plaintiffs claims are barred by the statute of frauds.
25. The Plaintiff is estopped from asserting claims in quasi-contract since it
5
had no dealings with the Defendant or any connection to transactions between the
Defendant and the extender of credit.
26. The Plaintiffs claims are barred by laches.
WHEREFORE, the Defendant demands judgment in his favor and against the
Plaintiff, with costs assessed against the Plaintiff.
Respectfully omitted
Xj, Esquire
782
Date: 9 1?-0
2080 Linglest Road, Suite 106
Harrisburg, P( Y 17110
(717)703-36 0
Attorney for Defendant
6
VERIFICATION
I, John Dyson, hereby state that the responses set forth in the attached
document are true and correct to the best of my knowledge, information and belief; and
that this statement is made subject to the penalties of 18 Pa. C.S. § 4904 relating to
unsworn falsification to authorities.
Dated: I 01 ? /. '2.
JOHN DYSON 41 V
CERTIFICATE OF SERVICE
1, the undersigned, hereby certify that on the _q_,_ day of 2007, 1
served a copy of the foregoing Answer with New Matter, by first-class ail, postage
prepaid, upon the following:
Michael J. Kennedy, Esquire
Amato and Associates, P.C.
107 North Commerce Way
Bethlehem, PA 18017
Attorney for Plaintiff
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COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
HUDSON & KEYSE, LLC
Plaintiff No. 06-4529 Civil
vs.
JOHN DYSON
CIVIL ACTION
Defendant(s)
PLAINTIFF'S REPLY TO NEW MATTER
23. Denied. This averment constitutes a conclusion of law to which no response is required
under the Pennsylvania Rules of Civil Procedure. Without waiving the foregoing and to the extent
a response may be required, Plaintiff specifically denies this averment.
24. Denied. This averment constitutes a conclusion of law to which no response is required
under the Pennsylvania Rules of Civil Procedure. Without waiving the foregoing and to the extent
a response may be required, Plaintiff specifically denies this averment.
25. Denied. This averment constitutes a conclusion of law to which no response is required
under the Pennsylvania Rules of Civil Procedure. Without waiving the foregoing and to the extent
a response may be required, Plaintiff specifically denies this averment.
26. Denied. This averment constitutes a conclusion of law to which no response is required
under the Pennsylvania Rules of Civil Procedure. Without waiving the foregoing and to the extent
a response may be required, Plaintiff specifically denies this averment.
WHEREFORE, Plaintiff requests Your Honorable Court enter judgment in favor of
. Plaintiff and against Defendant in accordance with the prayer of the Complaint.
AMATO AND ASSOCIATES, P.C.
By:
Ronald Amato Esq. , Atty ID #32323
Michael J. Kennedy, Esq., Atty ID #72412
Attorneys for Plaintiff
107 North Commerce Way
Bethlehem, PA 18017
(610) 866-0400
A DEBT COLLECTION LAW FIRM
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
HUDSON & KEYSE, LLC
Plaintiff No. 06-4529 Civil
vs.
JOHN DYSON
CIVIL ACTION
Defendant(s)
CERTIFICATE OF SERVICE
The undersigned certifies that a true and correct copy of Plaintiff's Reply to New
Matter was served via first class mail, postage prepaid on February 28, 2007:
Joseph K. Goldberg, Esq.
2080 Linglestown Road, Ste 106
Harrisburg, PA 17110
AMATO AND ASSOCIATES, P.C.
By:
Rona d Amat , Esq., Atty ID #32323
Michael J. Kennedy, Esq., Atty ID #72412
Attorneys for Plaintiff
107 North Commerce Way
Bethlehem, PA 18017
(610) 866-0400
A DEBT COLLECTION LAW FIRM
VERIFICATION
Nancy A. Quere, hereby states that she is the Legal Account Manager of
Hudson and Keyse, L.L.C. Plaintiff in this action, and verifies that the
statements made in the attached Reply to New Matter are true and correct to the best of
her knowledge, information and belief. The undersigned understands that the statements
herein are made subject to the penalties of 18 PA C.S. 4904 relating to unsworn
falsification to authorities.
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HUDSON & KEYSE, LLC
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 06-4529 CIVIL 20
VS.
JOHN DYSON
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:
MICHAEL J. KENNEDY, ESQ. counsel for the plaintiff/&$rj&* in the above
action (or actions), respectfully represents that:
1. The above-captioned action (or actions) is (are) at issue.
2. The claim of plaintiff in the action is $ 5,970.82
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:
JOSEPH K. GOLDBERG,ESQ.
WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to
whom the case shall be submitted.
Respectfully submitted,
ORDER OF COURT
AND NOW,
petition,
Esq., and
captioned action (or actions) as prayed for.
, 200___, in consideration of the foregoing
Esq., and
Esq., are appointed arbitrators in the above
By the Court,
EDGAR B. BAYLEY
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HUDSON & K E Y S E , L L C IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 06-4529 CIVIL 20
VS.
JOHN DYSON
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:
MICHAEL J. KENNEDY p ESQ. counsel for the plaintiff/dff&dalfC in the above
action (or actions), respectfully represents that:
1. The above-captioned action (or actions) is (are) at issue.
2. The claim of plaintiff in the action is $ 5 , 9 7 0.8 2.
The counterclaim ofthe defendant in the action is
The following attorneys are interested in the case(s) as counsel or are otherwise disqualified to sit
as arbitrators:
JOSEPH K. GOLDBERG, ESQ.
WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to
whom the case shall be submitted.
Respectfully submitted,
ORDER OF COURT
petition,
Esq., an
and Esq., are appointed arbi tors the above
caption
EDGAR B. BAYLEY
AND NOW, .1S , 200$, in consideration o the foregoing
Esq,
and
ed action or acti ) as prayed for.
By 61C o ,
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HUDSON & KEYSE, LLC, IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V.
JOHN DYSON,
DEFENDANT 06-4529 CIVIL TERM
ORDER OF COURT
AND NOW, this 1"_ day of November, 2008, the appointment of a
Board of Arbitrators in the above-captioned case, IS VACATED. Keith O. Brenneman,
Esquire, Chairman, shall be paid the sum of $50.00.
By theJC6urt,
Edgar B. Ifayley, #.
Keith O. Brenneman, Esquire - 11T tES m,z, Lq C_ / j1?o8
Court Administrator - 0 :sal I
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COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
HUDSON & KEYSE, LLC
Plaintiff No. 06-4529 Civil
VS.
JOHN DYSON
CIVIL ACTION
Defendant(s)
PRAECIPE TO DISCONTINUE WITHOUT PREJUDICE
TO THE PROTHONOTARY OF CUMBERLAND COUNTY:
Please discontinue the above-captioned case WITHOUT prejudice.
AMATO AND ASSOCIATES, P.C.
By: C??_
Ronald Amato, Esq., Atty ID #32323
Michael J. Kennedy, Esq., Atty ID #72412
Michael R. Lessa, Esq., Atty ID #88617
Justin N. Davis, Esq., Atty ID #84464
Attorneys for Plaintiff
107 North Commerce Way
Bethlehem, PA 18017
(610) 866-0400
A DEBT COLLECTION LAW FIRM
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