HomeMy WebLinkAbout07-2262t' 1•,
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.
PASQUALE J MACRI
316 Fort Street, Shippensburg PA 17257-1408
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 07 - ?o 4;t, (2 6u,L 7?,?
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
Lawyer Referral Service
213 N. Front Street
Harrisburg, PA 17101
Telephone No. 717-232-7536
C-11385
1 ? .
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
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 0' - -12?? C i Lj' G
PASQUALE J MACRI
316 Fort Street, Shippensburg PA 17257-1408
Defendant CIVIL ACTION - LAW
Complaint
1. Plaintiff is CITIBANK (SOUTH DAKOTA), N.A., with place of business located at
701 East 60th Street North, Sioux Falls, South Dakota.
2. Defendant is Pasquale J Macri, who resides at 316 Fort Street, Shippensburg,
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 5528320004008359 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 $6,845.61 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 for the sum of $6,845.61, and
the costs of this action.
Burton N Wciates, P.C.
By:
Burton Neil, EsAuire
The law firm of Burton Neil & Associates, P.C. is a debt collector.
PAYMENT ACCOUNT: 3886 571799 6906
COUPON BILLING DATE: 03-02-05
PAYMENT DATE: 03-26-05
TOTAL DUE: c=S ??= 6,845.61=
PASQUALE J MACRI
ACXIOM CORPORATION
6405 FLANK DR
HARRISBURG PA
17112-275005
DINERS CLUB
P. 0. BOX 6009
THE LAKES, NV
USA 88901-6009
PAYMENT ACCOUNT: 3886 571799 6906
SUMMARY TOTAL DUE:-- _--===-=a$ _== 6,845.61==
BILLING DATE: 03-02-05 ._._.__
YOUR ACCOUNT HAS BEEN CANCELLED. PLEASE DO NOT TRY TO USE YOUR CARD
AS NO CHARGES WILL BE APPROVED. IF YOU HAVE ANY QUESTIONS, PLEASE CALL
1-800-613-4637. OUR HOURS ARE 8:00AM TO 11:00PM EST MONDAY - THURSDAY,
8:OOAM TO 6:30PM FRIDAY, AND 9:OOAM TO 1:00PM SATURDAY.
JINERS CLUB ACCOUNT: 3886 571799 6906
ACCOUNT NAME: PASQUALE J MACRI
ACTIVITY BILLING DATE: 03-02-05
PAYMENT DATE: 03-26-05
REFERENCE CHARGES AND PAYMENTS
DATE DESCRIPTION NUMBER OTHER DEBITS AND CREDITS
When you pay your bill by check, you authorize us to electronically process your
payment. If your check is processed electronically, your checking account may be
debited on the same day we receive the check and it will not be returned with
your checking account statement. If someone other than you or a bill paying
service pays your bill, you must give a copy of this notice to them before the
payment is sent to us.
03-02-05 LATE FEE ASSESSED ON PAST 806810611948 S 152.96
DUE AMOUNT $6,118.20
AT 02.SOX
TOTAL FOR: 3886 571799 6906 S 152.96
PREVIOUS - PAYMENTS - CREDITS = PAST DUE
BALANCE BALANCE
S 6,692.65 S 0.00 S 0.00 $ 6,692.65
+ LATE + NEW + OTHER +/- TRAVEL DINERS CLUB
FEES CHARGES DEBITS ADVANCES BALANCE DUE
$ 152.96 S 0.00 S 0.00 S 0.00 S 6,845.61
KC036010445 D KC93104 CO
a ti
wxx DUPLICATE STATEMENT wrr
P-XHIBIT A
Verification
I, NCft DietZ 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 attorney-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 unsworn falsification to the authorities.
Pasquale J Macri
5528320004008359
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iil t3? ile i_i )'l iii iii#Y Ili iim. i i(t S„t".1not yilai
unemployed for a year. Plaintiff would not set up a repayment schedule that was
_3_i_ __ rl.__. ?_.,. _i ___.____._y _ '?iiii?i ?Ari7v yni?ACi?i,i iii 'i ?)y!pe?l i?tj
? clu-
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1044 IRS form. Our total assetsinet worth are less than the amount the Plaintiff is asking.
I ask the couuL Lis set up a repaymnerit sched7dk LIf-It WO-U-1 U be a, i)1 da ie at t ll.S tulle WI Lil a
continuance that I could make higher payments once I make more income.
{
Pas.-, Ii;-sir ivgne".ie
Defendant
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C'? ° C3
SHERIFF'S RETURN - REGULAR
CASE NO: 2007-02L621P
COMMONWEALTH OF S
COUNTY OF CUMBER D
YLVANIA:
CITIBANK SOUTH DAKOTA NA
VS
MACRI PASQUALE J
RICHARD E SMITH Sheriff or Deputy Sheriff of
Cumberland Count Pennsylvania, who being duly sworn according to law,
says, the withi COMPLAINT & NOTICE was served upon
MAORI PASQUALE the
DEFENDANT at 1040:00 HOURS, on the 27th day of April 2007
at 316 FORT STR ET
SHIPPENSBURG, P 17257-1408 by handing to
PASQUALE J MACR
a true and atte ted copy of COMPLAINT & NOTICE together with
and at the sam time directing His attention to the contents thereof.
Sheriff's Cost So Answers:
Docketing 18.00
Service 19.20
Affidavit 00 •
Surcharge 10.00 R. Thomas Kline
Postage .39
sq;t,4 y ? 47.59 00/00/0000
Sworn and Sub cibed to By:
before me thi day r uty Sheri f
of A.D.
BURTON NEIL & ASSOCIATES, P.C.
Edward J. O'Brien, Esquire
Identificstion No. 32985
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
CUMBERLAND COUNTY, PENNSYLVANIA
V.
NO. 07-2262 Civil Term
PASQUALE J. MACRI
Defendant : CIVIL ACTION - LAW
Plaintiffs Motion for Judgment on the Pleadings
Plaintiff Citibank (South Dakota) N.A. by its counsel, Burton Neil & Associates, P.C.
moves the Court under Pa R.C.P. 1034 for judgment on the pleadings against defendant in the
sum of $6,865.41 plus the record costs of this action and in support thereof states:
1. The pleadings consisting of complaint and answer are closed.
2. Defendant's pro se answer is entirely unresponsive to any averment in plaintiff's
complaint and accordingly admits all the complaint averments.
A-
3. By reason of the foregoing, there is no genuine issue of material fact which will require
a trial.
WHEREFORE, plaintiff moves for judgment on the pleadings under Pa R.C.P. 1034 in
the sum of $6,865.41 plus the record costs of this action.
Burton Neil & Associates. P.C.
Edward J. O'
NOTICE: Burton Neil & Associates, P.C. is a debt collector.
BURTON NEIL & ASSOCIATES, P.C.
Edward J. O'Brien, Esquire Id. No. 32985
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. 07-2262 Civil Term
PASQUALE J. MACRI
Defendant : CIVIL ACTION - LAW
Plaintiffs Brief in Support of Motion for Judgment on the Pleadings
1. Facts and Procedural History
Plaintiff filed a complaint against defendant to recover the balance past due on a credit
card account in the sum of $6,845.61. The Cumberland County Sheriff duly served defendant
plaintiff's complaint on April 27, 2007. Defendant filed a one paragraph pro se answer to the
complaint. Defendant's answer alleged he had been laid off and unemployed for a year, was
never offered a repayment arrangement that he could afford and had much less in net assets that
plaintiff is seeking here. As none of defendant's answer allegations are responsive to plaintiff's
complaint, his answer had the effect of admitting all allegations in the complaint. Defendant's
explanation of the reasons why he did not pay plaintiff does not rise to the level of a defense to
this obligation.
The pleadings in this action are closed. The matter is before the Court on plaintiff's
motion for judgment on the pleadings under Pa. R.C.P. 1034(a).
II. Question Presented
Whether there exists a genuine issue of material fact which will require a trial?
III. Argument
A. Standard for Decision.
"The motion for judgment on the pleadings should be granted only in clear cases, which
are free from doubt, and where there are no issues of fact. The deciding court should grant
judgment only where the case is so clear that a trial would clearly be a fruitless exercise." 6
Standard Pennsylvania Practice 2d Section 31:45 and the cases cited therein. Even under this
stringent standard, plaintiff is entitled to judgment since the defendant's pro se answer'
effectively admitted plaintiff's case. Proceeding to trial despite those admissions would indeed be
a fruitless exercise.
B. Defendant's Unresponsive Answer Conclusively Admitted All Averments of
Plaintiff's Complaint.
Defendant's answer was not responsive to any of the averments of the complaint. Rather,
it was simply an explanation as to why defendant did not pay the debt. Pa.R.C.P. 1029(b)
provides that "Averments in a pleading to which a responsive pleading is required are
admitted when not denied specifically or by necessary implication. A general denial or a
demand for proof, except as provided by subdivisions (c) and (e) of this rule, shall have the effect
of an admission." (Emphasis added). Clearly, none of the complaint's allegations were denied
specifically nor reading the answer as a whole was anything denied by necessary implication.
Therefore, defendant admitted each allegation.
Pennsylvania law is clear - these admissions are conclusive and binding on defendant.
'That defendant is pro se does not entitle him to more lenient application of court rules, absolve
him of adherence to them or free him from the risk of adverse consequences for failure to do so. Peters
Creek Sanitary v. Welch, 545 Pa. 309, 681 A.2d 167, 170 (1996) ; Jones v. Rudenstein, 401 Pa. Super.
400, 585 A.2d 520 (1991) appeal den, 529 Pa. 634, 600 A. 2d 954 (1991); Faretta v. California, 422 US
806, 834 n. 46, 955 S.Ct. 2525, 2540 n.46, 45 L.Ed.2d 562, 581 n 46 (1975).
See: Jewelcor Jewelers & Distributors v. Corr, 373 Pa. Super 536, 542 A.2d 72 (1988); Tops
Apparel Mfg: Co. v. Rothman, 430 Pa. 583, 244 A. 2d 436 (1968); Packel & Poulin,
Pennsylvania Evidence, 2d Ed., Section 127, p. 30.
C Defendant's Allegations of Inability to Pay Does Not Serve as a Defense.
The averment of financial distress or inability to pay is not a defense to this action. See
Luber v. Luber, 418 Pa. Super. 542, 548-550, 614 A.2d 771, 774 (Pa. Super. Ct., 1992); Felix v.
Giuseppe Kitchens & Baths, Inc., 2004 PA Super 120, P11, 848 A.2d 943, 948 (Pa. Super. Ct.,
2004); Levey v. Cogen Sklar LLP, 63 Pa. D. & C.4th 543, 552 (Pa. D. & C., 2003).
IV. Conclusion
The defendant having effectively admitted all the allegations of the complaint, there is no
genuine issue of material fact which will require a trial. Judgment on the pleadings should be
entered under Pa. R.C.P. 1034(a) for plaintiff for the admitted sum due of $6,845.61 plus record
court costs 2 of $126.09.
Burton Neil & Associaes, P.C.
Edward J. O'Btigln, Esquire
NOTICE: Burton Neil & Associates, P.C. is a debt collector.
2 Statute of Gloucester, 6 Edw. 1, c. 1 (1275); 42 Pa. C. S. A. Section 1726; 42 Pa. C. S. A.
Section 20003; Gold v. Northeast Theater Corp., 281 Pa. Super. 69, 421 A. 2d 1151, 1154 (1980); De
Fulvio v. Holst, 239 Pa.Super. 66, 69, 362 A.2d 1098, 1099 (1976): "At law the general rule is that costs
follow as a matter of course, and the court has no discretion to award or deny them."
Burton Neil & Associates, P.C.
By: Edward J. O'Brien, Esquire ID. NO. 32985
1060 Andrew Drive, Suite 170
West Chester, PA 19380
610-696-2120
Attorney for Plaintiff
CITIBANK (SOUTH DAKOTA), N.A.
Plaintiff
V.
PASQUALE J MACRI
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 07-2262 Civil Team
CIVIL ACTION - LAW
Certificate of Service
I, Edward J. O'Brien, Esquire do hereby certify that I served a true and correct copy of the
within Motion for Judgment on the Pleadings, supporting Brief, Praecipe for Listing Case for
Argument and proposed Order on pro se defendant, Pasquale J Macri at his address of record via
first class mail, postage prepaid on the date set forth below.
Burton Neil & Associates, P.(C.
Z?
Date: 'I q
By: Jtl--
Edward J. O'Brien, qui
Attorney for Plainti
The law firm of Burton Neil & Associates is a debt collector.
C-11385
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CITIBANK (SOUTH DAKOTA) N.A. IN THE COURT OF COMMON PLEAS
Plaintiff
CUMBERLAND COUNTY, PENNSYLVANIA
V.
NO. 07-2262 Civil Term
PASQUALE J. MACRI
Defendant : CIVIL ACTION - LAW
ORDER
AND NOW, this day of , 2008, plaintiff's motion for judgment on the
pleadings is granted. It is hereby ORDERED that judgment be entered for plaintiff Citibank
(South Dakota) N.A. and against defendant Pasquale J. Macri in the sum of $6,845.61 plus
record court costs of $126.09.
By the Court:
J.
Edward J. O'Brien, Esquire Pasquale J. Macri
Attorney for Plaintiff Pro Se Defendant
Burton Neil & Associates, P.C. 600 Locust Lane
1060 Andrew Drive, Suite 170 Shippensburg, Pa 17257
West Chester, PA 19380
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.
--------------------------------------------------------------------------------------------------------------------
CITIBANK (SOUTH DAKOTA), N.A.
Plaintiff
V.
PASQUALE J MACRI
Defendant
NO. 07-2262 Civil Team
1. State matter to be argued (i.e., plaintiffs motion for new trial, defendant's demurrer to
complaint, etc.):
Motion for Judgment on the Pleadings
2. Identify counsel who will argue case:
(a) for plaintiff: Edward J. O'Brien, Esquire
c/o Burton Neil & Associates, P.C.
address: 1060 Andrew Drive, Suite 170, West Chester, PA 19380
b) for defendant: Pasquale J Macri, Pro Se
address: 600 Locust Lane Shippensburg PA 17257-1408
3. I will notify all parties in writing within two days that this case has been listed for
argument.
4. Argument Court Date: April 16, 2008
Edward J. O'Br.e?(,1
Attorney for the lainti
The law firm of Burton Neil & Associates is a debt collector.
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Burton Neil & Associates, P.C.
By: Edward J. O'Brien, Esquire ID. NO. 32985
1060 Andrew Drive, Suite 170
West Chester, PA 19380
610-696-2120
Attorney for Plaintiff
CITIBANK (SOUTH DAKOTA), N.A.
Plaintiff
V.
PASQUALE J MACRI
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 07-2262 Civil Team
CIVIL ACTION - LAW
Amended Certificate of Service
I, Edward J. O'Brien, Esquire do hereby certify that I served a true and correct copy of the
within Motion for Judgment on the Pleadings, supporting Brief, Praecipe for Listing Case for
Argument and proposed Order on pro se defendant, Pasquale J Macri at his address of record via
first class mail, postage prepaid on the date set forth below.
Date: 3(A()L,
Burton Neil & Associates, P.C.
By:
The law firm of Burton Neil & Associates is a debt collector.
C-11385
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CITIBANK (SOUTH DAKOTA),
N.A.,
Plaintiff
VS.
PASQUALE J. MACRI,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 07-2262 CIVIL
IN RE: PLAINTIFF'S MOTION FOR JUDGMENT ON THE PLEADINGS
BEFORE HESS, OLER, AND GUIDO, J.J.
ORDER
AND NOW, this Z-l' day of April, 2008, it appearing that the answer of the defendant
seeks relief from the court which we are powerless to grant and is devoid of any defense to the
complaint, the motion of the plaintiff for judgment on the pleadings is GRANTED.
BY THE COURT,
Edward J. O'Brien, Esquire
For the Plaintiff
/ Z-
asquale J. Macri
316 Fort Street
Shippensburg, PA 17257-1408
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Kev' A. Hess, J.
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Burton Neil & Associates, P.C.
By: Edward J. O'Brien, Esquire ID. NO. 32985
1060 Andrew Drive, Suite 170
West Chester, PA 19380
610-696-2120
Attorney for Plaintiff
CITIBANK (SOUTH DAKOTA), N.A.
Plaintiff
V.
PASQUALE J MACRI
IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 07-2262 Civil Team
Defendant : CIVIL ACTION - LAW
Praecipe for Entry of Judgment on Court Order
To the Prothonotary:
Enter judgment on behalf of the plaintiff, CITIBANK (SOUTH DAKOTA), N.A., and
against the defendant, PASQUALE J MACRI, as per the Court's Order dated April 21, 2008 and
assess damages in the sum of $6,845.61 plus court costs.
Burto Neil & Ass Mites, P.C.
By
Edward J. 'Bri , Esquire
And now, this a9'µ day of April , 2008 judgment is entered on behalf
of the plaintiff, CITIBANK (SOUTH DAKOTA), N.A. and against the defendant, PASQUALE J
MACRI, in the sum of $6,845.61 plus court costs.
P thono um e and County
Deputy
In making this communication, we advise that this office is a debt collector.
•
CITIBANK (SOUTH DAKOTA),
N.A.,
Plaintiff
vs.
PASQUALE J. MAORI,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 07-2262 CIVIL
IN RE: PLAINTIFF'S MOTION FOR JUDGMENT ON THE PLEADINGS
BEFORE HESS, OLER, AND GUIDO, J.J.
ORDER
AND NOW, this 0,1' day of April, 2008, it appearing that the answer of the defendant
seeks relief from the court which we are powerless to grant and is devoid of any defense to the
complaint, the motion of the plaintiff for judgment on the pleadings is GRANTED.
BY THE COURT,
Edward J. O'Brien, Esquire
For the Plaintiff
Pasquale J. Macri
316 Fort Street
Shippensburg, PA 17257-1408
rim
Kev A. Hess, J.
TRUE COPY FROM REOORU
in Teomny whereof, i here unto set my
-04 Vt pf std at, Isle. PA
i1of
oar
Burton Neil & Associates, P.C.
By: Edward J. O'Brien, Esquire ID. NO. 32985
1060 Andrew Drive, Suite 170
West Chester, PA 19380
610-696-2120
Attorney for Plaintiff
CITIBANK (SOUTH DAKOTA), N.A.
701 East 60th Street N
Sioux Falls, SD 57117
Plaintiff
V.
PASQUALE J MACRI
316 Fort Street
Shippensburg PA 17257-1408
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 07-2262 Civil Team
CIVIL ACTION - LAW
Certification of Address and
Affidavit of Non-Military
Understanding that false statements herein are subject to penalty under 18 Pa. C.S. Section
4904 relating to unsworn falsification to authorities, I verify that:
1. The above are the precise last-known addresses of the judgment creditor and debtor.
2. 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.
Burto eil & Ass elate
By:
dward J. O'Brie Esqu
Attorney for Plaintiff
In making this communication, we advise that this office is a debt collector.
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Burton Neil & Associates, P.C.
By: Edward J. O'Brien, Esquire ID. NO. 32985
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
v.
PASQUALE J MACRI
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 07-2262 Civil Team
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 on 41,2q 9
Prothon tary ofe Aberlanounty
Deputy
If you have any questions concerning the above, please contact:
Edward J. O'Brien, Esquire
Attorney for Party Filing
1060 Andrew Drive, Suite 170
West Chester, PA 19380
Phone: 610-696-2120
In making this communication, we advise that this office is a debt collector.