The URL can be used to link to this page

Home My WebLink About07-1824 Burton Neil & Associates, P.C. By: Burton Neil, Esquire ID. NO. 11348 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA) N.A. 701 East 60th Street North, Sioux Falls, SD Plaintiff V. JOHN FREI III 5010 Pheasant Hollow Road, Mechanicsburg PA Defendant IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 017 -142 7 01 L 'T'' t CIVIL ACTION - LAW Complaint - 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 (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 claim 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. 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. LAWYER REFERENCE AND INFORMATION SERVICE Cumberland County Bar Assoc. 32 South Bedford Street Carlisle, PA 17013 Telephone No. 717-249-3166 or 800-990-9108 C-10889 ti IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVQA''NI'A i,;-X 6, L CIVIL ACTION - LAW Complaint 1. Plaintiff is Citibank (South Dakota) N.A., with place of business located at 701 East Burton Neil & Associates, P.C. By: Burton Neil, Esquire, I.D. NO. 11348 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA) N.A. 701 East 60th Street North, Sioux Falls, SD Plaintiff V. JOHN FREI III 5010 Pheasant Hollow Road, Mechanicsburg PA Defendant 60th Street North, Sioux Falls, South Dakota. 2. Defendant is John Frei III, who resides at 5010 Pheasant Hollow Road, Mechanicsburg, Cumberland County, Pennsylvania. 3. Plaintiff is a national banking association, engaged in various types of banking business including consumer lending through the issuance of credit cards. 4. Plaintiff furnished consumer credit to the defendant by means of a credit card with account number 5424180722783971 hereinafter referred to as the credit card account. 5. Plaintiff kept accurate running records of all debits and credits to the account. 6. Plaintiff mailed to defendant monthly statements for the account including the billing statement attached hereto as Exhibit A. The monthly statements accurately stated the previous balance, the debits and credits to the account for the prior billing period. 7. Before plaintiff mailed Exhibit A, defendant had for many months made payments on account of the billing statement or retained the statement without payment. 8. Defendant's actions as set forth above constituted an account stated between parties for the sum of $6,655.30 which sum reflects the Exhibit A statement balance less credits, if any, which were applied subsequent to the date of Exhibit A. Wherefore, plaintiff demands judgment against defendant r9ohe sum of $6,655.30, and the costs of this action. eil & AsAciAes, P.C. Burton Neil, Esquire The law firm of Burton Neil & Associates, P.C. is a debt collector. ?* ?? 10/06/06 $6655.30 $1182.21 SITE:KC-CL TM:CO-5000 ACID:ROB0554 10/24/06 19:26:29: - CITI CARDS JOHN FREI III P.O. BOX 182564 5010 PHEASANT HOLLOW RD COLUMBUS, OH 43218-2564 MECHANICSBURG PA 17050-2448000 ` ' C tip Citi Diamond Preferre d Car Account Number 5424 1807 2278 3971 Customer SerAce: 1-800-866-9900 Total Credit Line $6900 Available Credit Line $244 Cash Advance Limit Available Cash Limit New Balance BOX 6500 $1700 $244 $6655.30 Statement/ SIOUX FALLS. SD Closing Date 57117 09/13/2006 Amount Over Credit Line Purch/Adv Past out minimum Due Minimum Amount Due $0.00 + $904 26 + $277.95 $1182 21 Sak Date Pest Date Category Activity Sinn Last Statement . Amount 9/13 Standard Pu rch LATE FEE - AUG PAYMENT PAST DUE 39 00 9/13 66 0000 PURCHASES*F INANCE CHARGE*PERIODIC RATE . 0000000000 172 95 84 0000 . 0000000000 Your late fee was based on your account ba (09/07/06), which was $6,443.35. lance as of the payment due date Your account is seriously past due and your credit privileges have been suspended. Please call the toll-free number shown above to learn about our special payment options. Call Monday - Friday, 7 am - 9 pm, or Saturday, 8 am - 5 pm, Central Time. EXHIBIT Account Summary PURCHASES ADVANCES $6,443.35 $0 00 $39.00 $0.00 00 $0 • rsaiance $172.95 $6,655.30 TOTAL . $6,443.35 . $0.00 $39.00 $0.00 $0.00 $0.00 $172.95 $6,655.30 Rate Summary Balance Subject to Periodic Days This Billing Period: 30 Nominal PURCHASES Finance Charge Rate ANNUAL APR PERCENTAGE RATE Standard Purch ADVANCES $6,526.56 0.08833%(D) 32.240% 240% 32.240% Standard Adv $0.00 0.08833%(D) 32.240% 32.240% t. . . ', Verification 1' Tars. qrg s am an employee of Citicorp Credit Services, Inc., (USA) which is by contract the service provider for plaintiff CITIBANK (SOUTH DAKOTA) N.A. retained to perform services including but not primarily limited to collecting delinquent debt. I am authorized to make this verification as attomey-in-fact for plaintiff under powers of attorney from plaintiff to Citicorp Credit Services, Inc. (USA) and to me. The foregoing averments of fact in the within pleading are true and correct to the best of my knowledge, information and belief. I understand that the statements made herein are subject to the penalties of 18 Pa. C.S. Section 4904, relating to unworn falsification to the authorities. '? afore John FREI III 5424180722783971 l r W N n 7 -s NJ N 10(1-3 ti CITIBANK (SOUTH DAKOTA) N.A. 701 East 60th Street N, Sioux Falls, SD 57117 Plaintiff V. JOHN FREI III 5010 Pheasant Hollow Road Mechanicsburg PA 17050-2448 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-1824 CIVIL ACTION - LAW Praecipe for Default Judgment To the Prothonotary: Please enter judgment by default for want of an answer in the above case in favor of the plaintiff and against the defendant, and assess damages as follows: Principal: TOTAL $6,655.30 $6,655.30 Understanding that false statements herein made are subject to penalty under 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities, I verify that: 1. The above are the precise last-known addresses of the judgment debtor and creditor. 2. The annexed notice of intention to file this praecipe was mailed to all parties against whom judgment is to be entered and to their record attorneys, if any, after the default occurred, and at least ten days prior to the date of the filing of this praecipe. 3. Pursuant to Section 201(b)(1)(A) of the Servicemembers Civil Relief Act of 2003 (SCRA), the defendant is not in the military service of the United States based on information received from the defendant and/or the Department of Defense website. JUDGMENT BY DEFAULT ENTERED AND DAMAGES ASSESSED AS ABOVE. NOTICE G EN UND PA.R.CIV.P. 236 Pro Prot onotary Burton Neil & Mociates. P.C. Burton Neil, Es ire Attorney for Plain I.D. #11348 1060 Andrew Drive, Suite 170 W. Chester, PA 19380 The law firm of Burton Neil & Associates is a debt collector. C-10889 CITIBANK (SOUTH DAKOTA) NA. Plaintiff V. JOHN FREI III Defendant IN THE COURT OF COMMON PLEAS C-10889 CUMBERLAND COUNTY, PENNSYLVANIA : NO. 07-1824 : CIVIL ACTION - LAW Notice of Intention to File Praecipe for Default Judgment TO: John Frei III 5010 Pheasant Hollow Road Mechanicsburg PA 17050-2448 IMPORTANT NOTICE You are in default because you have failed to enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to your lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help. 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. LAWYER REFERENCE AND INFORMATION SERVICE Cumberland County Bar Assoc. 32 South Bedford Street Carlisle, PA 17013 Telephone No. 717-249-3166 or 800-990-9108 DATE OF NOTICE: April 30, 2007 In making this communication, we advise our office is a debt collector. Burton Neil & Asy6ciates, P.C. Attorney for Plaintiff Identification No. 11348 1060 Andrew Drive, Suite 1 West Chester, PA 19380 (610) 696-2120 cc: John P. Neblett, Esquire 2000 Linglestown Rd. Suite 204 Harrisburg, PA 17110 IIiNINIUN?II?11?I?I?INlllll II?NINIINIIIN?IIINI?IIIINNYIIINNIIIII?IhII?NiNllll ?- o 3 Burton Neil & Associates, P.C. BY: Burton Neil, Esquire ID. NO. 11348 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 ATTORNEY FOR: Plaintiff CITIBANK (SOUTH DAKOTA) N.A. IN THE COURT OF COMMON PLEAS Plaintiff V. : CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-1824 JOHN FREI III Defendant : CIVIL ACTION - LAW Rule of Civil Procedure NO. 236 (Revised) Notice is given that a JUDGMENT in the above captioned matter has been entered against you Prothonotary By. If you have any questions concerning the above, please contact: Burton Neil, Esquire Attorney for Party Filing 1060 Andrew Drive, Suite 170 West Chester, PA 19380 Phone: 610-696-2120 The law firm of Burton Neil & Associates is a debt collector. SHERIFF'S RETURN - REGULAR CASE NO: 2007-01824 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITIBANK SOUTH DAKOTA NA VS FREI JOHN III KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon FREI JOHN III the DEFENDANT , at 2036:00 HOURS, on the at 5010 PHEASANT HOLLOW ROAD MECHANICSBURG, PA 17050 JOHN FREI III 5th day of April , 2007 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 11.52 Affidavit .00 Surcharge 10.00 .00 3 9 . 5 2 Sworn and Subscibed to before me this day of So Answers: R. Thomas Kline 04/10/2007 BURTON NEIL & ASSOCIATES By. A. D.