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HomeMy WebLinkAbout07-3610 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CITIFINANCIAL I CIVIL DIVISION I I I Plaintiff (s) , I ~``~ ~~ljl(,~~'~ 1 No. 2007- v. I I Ronald A. Neill ~ an individual I Defendant(s), I I I COMPLAINT I I ~ Code No. I ~ Filed on Behalf of: I 1 PLAINTIFF I I I 1 ATTORNEY OF RECORD FOR THIS PARTY I ~ Louis B. Swartz I ~ PA. ID # 00242 I I ISWARTZ, LOVEJOY & ASSOCIATES 116th FLOOR LAW AND FINANCE BUILDING (PITTSBURGH, PENNSYLVANIA 15219 i I ((412) 288-0300 <77722 NOTE: THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE <77722 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CITIFINANCIAL Plaintiff(s), No. 2007- v. Ronald A. Neill an individual Defendant(s), NOTICE TO DEFEND AND CLAIM RIGHTS 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 days (20) 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 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 1-800-990-9108 717-249-3166 NOTDEFCU.PLE i • <77722 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CITIFINANCIAL Plaintiff(s), No. 2007- 3S/Go v. Ronald A. Neill an individual Defendant(s), COMPLAINT 1. Plaintiff(s) is CITIFINANCIAL. Plaintiff's address is ATTN: PAYMENT PROCESSING, FORT MILL, SC 29715. 2. Defendant(s) is Ronald A. Neill an individual. Defendant's address is 212 E MAIN ST APT. 1, Camp Hill PA 170116316. 3. Plaintiff, at Defendant's special instance and request, opened for the Defendant a credit account which Defendant thereafter used and there is a balance due and unpaid, despite demand, in the amount of $5,744.65 plus interest from January 30, 2007. WHEREFORE, Plaintiff demands Judgment again~t~ ~fendant(s) in the amount of $5,744.65 Plus legal interest and costs. Louis B. Swa z~- Attorney for PLAINTIFF 16th FLOOR LAW AND FINANCE BUILDING PITTSBURGH, PENNSYLVANIA 15219 (412) 288-0300 '• <~nzz IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CITIFINANCIAL Plaintiff(s), No. 2007- v. Ronald A. Neill an individual Defendant(s), COMPLAINT 1. Plaintiff(s) is CITIFINANCIAL. Plaintiff's address is ATTN: PAYMENT PROCESSING, FORT MILL, SC 29715. 2. Defendant(s) is Ronald A. Neill an individual. Defendant's address is 212 E MAIN ST, SHIREMANSTOWN PA 170116316. 3. Plaintiff, at Defendant's special instance and request, opened for the Defendant a credit account which Defendant thereafter used and there is a balance due and unpaid, despite demand, in the amount of $5,744.65 plus interest from January 30, 2007. WHEREFORE, Plaintiff demands Judgment again~~L~efendant(s) in the amount of $5,744.65 Plus legal interest I and costs. Loui s B . Swa"~ Attorney for PLAINTIFF SWARTZ, LOVEJOY & ASSOCIATES 16th FLOOR LAW AND FINANCE BUILDING PITTSBURGH, PENNSYLVANIA 15219 (412) 288-0300 ~~ »~~zz IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CITIFINANCIAL Plaintiff(s), v. Ronald A. Neill an individual Defendant(s), No. 2ao~- VERIFICATION The undersigned, ~, avers that he/she is the of Plaintiff, is authorized to make this v rification on behalf of Plaintiff, the statements of fact contained in the attached Complaint are true and correct to the best of his/her information, knowledge and belief, and are made subject to the penalties of 18 Pa. Cons. Stat. Ann. Section 4904 relating to unsworn falsification to authorities. Date ~ V~ ~ (J 1 VERIFCOM.PLE ~ _(~' ~~ ^( v `~. ~~ C_t -- ~ n . `~, -,., -n ~ ---~ __ ,~-- 2 ~ ~ .~ r n _ .. -.err; _ = - CS3 ~ , a ~-' a __~ _„ __ r a ,~:a ...s.i :. •• Q-, -~ /, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CITIFINANCIAL Plaintiff, v. Ronald A. Neill an.individual Defendant, CIVIL DIVISION No. 2007-03610 STIPULATION FOR JUDGMENT Code No. Filed on Behalf of: PLAINTIFF ATTORNEY OF RECORD FOR THIS PARTY Louis B. Swartz PA. ID # 00242 SWARTZ, LOVEJOY & ASSOCIATES 16th FLOOR LAW AND FINANCE BUILDING PITTSBURGH, PENNSYLVANIA 15219 (412) 288-0300 ;77722 NOTE: THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CITIFINANCIAL Plaintiff, No. 2007-03610 v. Ronald A. Neill an individual Defendant, STIPULATION FOR JUDGMENT The parties stipulate as follows. 1. Plaintiff commenced this civil action by filing a Complaint stating a claim for $5,744.65 plus interest from January 30, 2007 for sums due on Defendant's Citifinancial card account #2009080388127, and costs (the "Indebtedness"). 2. Defendant has offered and Plaintiff has agreed to accept payment of the Indebtedness in monthly installments, each in the amount of $236.00. The Defendant shall pay the balance in monthly installment payments of $236.00 on or before the 23rd day of the month beginning July 23, 2007 with interest at 6% per year, provided payment is made timely in accordance with the terms of this Stipulation. 3. Judgment shall be entered in favor of Plaintiff and against Defendant for the full amount of the Indebtedness as defined above in the sum of $5,744.65 plus interest from July 9, 2007 and costs (the "Judgment"). 4. So long as Defendant makes the said payments timely, time being of the essence, Plaintiff shall not take any further legal action beyond entering judgment on this Stipulation and upon receipt of timely payment of the Indebtedness, interest and costs in full in accordance with the terms of this Stipulation, Plaintiff shall satisfy the Judgment. 5. If Defendant fails to make the agreed payments timely, time being of the essence, Plaintiff may execute on the Judgment upon praecipe to the Prothonotary for the balance due on the Judgment after credit is given for any payments made by Defendant and Plaintiff may take any other supplemental action on the Judgment as authorized by law and rules of court. 6. Defendant shall make the said payments to and payable to. Louis B. Swartz, Attorney for Citifinancial, 1600 Law and Finance Building, ~1~tsburgh, PA 3~f LOUIS B. SWARTZ, S IRE/DATE Swartz Lovejoy & s cs. Attorney for Plair..tiff 1600 Law and Finance Building Pittsburgh, PA 15219 412/288-0300 15219. ~ f -~ ~~ RONALD A. NEILL DATE Defendant 212 E. Main Street, Apt 1 Camp Hill, PA 17011 717-730-7241 ~ .y,. ~ ~ ~ 'k :~. ~.. iii ~ ~ 8 _~ ~ 1 T r " =' t~ ~ ='' r~rs cn .~.~ w { .~ SHERIFF'S RETURN - REGULAR CASE NO: 2007-03610 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITIFINANCIAL VS NEILL RONALD A MICHAEL BARRICK Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon NEILL RONALD A the DEFENDANT at 1659:00 HOURS, on the 22nd day of June 2007 at 212 E MAIN STREET APT 1 CAMP HILL, PA 17011-6316 by handing to RONALD NEIL 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 Service Affidavit Surcharge j~o4~~ ~ ~-..,,~ Sworn and Subscibed to before me this of So Answers: 18.00 12 .4 8 J~'~ 10.00 R. Th3omas Kline .00 40.48 06/25/2007 SWARTZ LOVEJOY & ASSOCIATES By. day Deputy he iff A.D.