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Home My WebLink About07-4004 -CN 'I'HL LOUR''.' O~' COPiiI~ION PLEAS 7F CiJMBERLANL' COUNTY, PELv'NSYLVANLA CIVIL DIVT.',ION CIT:iI~Ai~1K (SOrJTH DAKOTA) NA P7_aintif f No : ~~ ' -~~y ~~~~L ~~, vs. CUMPLAII4T IN CIVIL ACTION GEORGE r~ SEIDLE D~~fer~dant~ FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmprodt,42524 4VEI~TMAN, LVE~NBERG & REIS LO . , L, . P . A . 436 Seventh Avenue, Suite ?.718 Pit.t.sbux'c;l:, PA I. .5219 (412} 43^-7855 FAX: 412-338-7130 05902489 L J Pit SG^~i IN THE COL3RT JF COMMON PLEAS OF CUb~BERLI-iND ~:'OUTITY, FE?~NSYLVANIA CIVIL DIVItiION CITI:I3ANK {SOUTH DAKOTA; i~TA Plaintlf: VS . Cl'v 11 Z~ctlon NO GEORGE F, SET..`LE Defendant COMPLAINT AI~TD NOVICE TO DEFEND ~`ou ~!uve beer. sued in court . If you wish to defenc against i:he claims SE'_~ co~'Lh :~57 ~Y?e foll_cwing pa.c~e.~, y<~u mint t:a'rte a.:;tiar_ Withlr. t.wenr.y (2~~) c~.:z1r:; after this complaint anc'. i~otic:e a~~e served, 'ay sneering a written! app::aranre per.sona.l~!y o~.• by an attorney ~.nd Lil.i~zg ir. variti.ng with i:11F' rou.r!: your aefsnsEs or objections ±:o t~_ie claims ~.et, forth against you. You ara warned that if you Fail. tc dc; so the case may proceed witY~o zt you, nd a judgment ::Zayy be erlte~ed agai..nst you. icy the court w~~_tliou~. further notice for ar~,r n»ney claimed in tFil=, c;,inplaint or for an~J other clai:r~ or relief r_-r_que~~ted b,' the plaintiff . You may lose mon ~.~ or p~-o~~~.r..ty or other rights important to you. Y~JU Si-iGU'.:D TAKE . THIS FADER TO YOUR LAWYER AT ONCE . IF YOU DO NOT HAVE A LP.WYER OR CAD7I30T AFFORL` CNE, C:O TO OiZ TELEFHCNE THE OFFICE SET FCR.TH BELOW •'1'J FIND OUT WHERE YCL7 Ci~N GET L}~GAL HELP . IF YOU C~I~TNOT AFFCRD TO HIRE A LAWYr;R, THIS OFFICE i~AY BE ABLE TO iJRCVIDF, YC~J WITH INFORMATION ABOUT AGEPICIES 'THAT MAY OFF EI: LEGAL SERVICES TO F~LYGIBLE PERSONS AT A REDUCED FEE OR NC FEE. LAWYER RErERRAL SERVICE CU!~IBERLAND COUNTY BAR -AiSOCIA'3'IOr~ 32 SOUTH BEDTCRD Si'ariT CARLISLE, PA 1701.; , COMPL~~? INT 1. Plainti.f_f is CITIBANK (SOUTH DAKOTA) NA with p'.ace of business located at 701 East 50th Street North, Sicux Fa11s, South Dakota, 5711.7 . 2 . ;~efendant is adult indi~ridual. (s) residing at t~.e address listed bed! ow: GEORGE; E Sr,IrLE 81.3 :•QE'R.T7.VI3~':•E '2D ENOL7~, ~ua 170;'5 3. Plaintiff: is a national banking association, engaged in con:~umer lendir~g thro•krh the issuance of credit cai,ds. 4. Purr~uant `wo P,ef.endant's request, Plaintiff furr..ished to the. Deendar~t a c~~~edit card account (hereinafter account) bearing account num.'^,er 549113J398022467 . 5. Plaintiff kept accurate running records of all debits and credits to the Account. 6. Plaintiff mailed to Defendant monthly statements fors the account ir~cludin~ ?~he billing .statement attached hereto as Exhibit A. The monthly statements accurately stated the previous balances, t~.he debits and credits to the account for the prior_ billing p~•riod. 7. Defendant's actions as set forth above constituted an account stated between parties for the sum of $1,000.68, 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 in its favor and against Defendant, GEORGE E SEIDLE ,individually, in the amount of $1,000.68 with interest at the statutory interest rate of 6% per annum from date of judgment plus costs. WELTMAN, WEINBERG &REIS, CO., L.P.A. William T. Molczan, Esquire PA. I.D.#47437 WELTMAN, WEINBERG &REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 AT~T Universal Platinum Card Charter Member A7~tT Universal Card ,Page 1 of 3 GEORGE E SEIDLE Account 6491 1303 9802 2467 Calling Card + PIN November 8 -December 8, 2006 Quick Reference Minimum Payment Due ...................................... 51,000.66 Due Date" ................................................. Janwry 2, 2007 "PrymeM mutt M revived by 5:00 pm local time on tM paymern duo dab. Amount Past Due ..................................................:299.02 Credit Line ............................................................. $1,180.00 Available Credit ............................................................ 0.00 Cash Advance Limit ................................................ $1 0.00 Available Cash Advance Limit .................................... $0.00 Account Summary Previous Balance 936.49 Payments and iTtments 0.00 MasterCard Activity 64.19 Total ATBT Services 0.00 New Balance 51,000.68 Note: Detailed activity starts on page 3. How To Reach Us Visit: www.universalcard.com Customer Service: 1-800-423-4343 or write Cardmember Services PO Box 44167 Jacksonville, FL 3223)-4167 Your late fee was based on your account balance as of the payment due date (12/04/06), which was 5936.49. Help is available! Please call the toll-free number shown above to learn about our special payment options. Please give us the opportunity to assist you. date paid amount paid check # Please foibw payment Instructions outlined In Ike "Important Instructlons,for Making Payments" »ctlon at tl» statement. 05491130398022467100068999995812 YarAecaeltNemb.r 5491 1303 9802 2467 Phase tinter AaloeM of Payment Lnolose0 P~ayraeat Due Dab Your Total ltabnce tlbdllaan MrMIMt Due JAN 02 2007 11000.68 :1000.68 3275 MC 32 A 1 AR7051fi65 II IIIIIIIIIII11/III/IIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIII GEORGE E SEIDLE 813 WERTZVILLE RD ENOLA PA 17025-1834 IIIIIII/"111'/II IIIIIIIIIIIIIIIII/lllllllllelll/III AT&T UNIVERSAL CARD PO BOX 183056 COLUMBUS, OH 43218-3056 IIJILIIIIIILIIteI111111111t111tIIIIIIIILIrLIIIIILIrlllll Verification I, ~~~C P~rz~y , 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. M~~~~ Defendant's name GEORGE' SEIDLE Client's acct number 5491130398022467 WWR#05902489 ;u n ~+o ~' ~ 1 '~ ~ ~ W C ~J n C` y~ Tl i t__ .'~' . r.__. r~J ~ ~_ ~. ~=<: rv ~.~ ~~ c_ c-~- rv -~ ~: c..a r~ O ~~ -;r `r? cY5 -~-a ~~~ ,.._, fl-j rri 0 CASE NO: 2007-04004 P SEIDLE GEORGE E COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITIBANK (SOUTH DAKOTA) NA VS MEGAN HARLOW Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon SEIDLE GEORGE E the DEFENDANT at 1707:00 HOURS, on the 11th day of July 2007 at 813 WERTZVILLE ROAD ENOLA, PA 17025 ALISON MACADAM, FIANCE Sheriff or Deputy Sheriff of by handing to ADULT IN CHARGE a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. SHERIFF'S RETURN - REGULAR 18.00 14.40 .00 10.00 .00 / 42.40 Sheriff's Costs: Docketing Service Affidavit Surcharge ~' 131p ~? ~.,,, Sworn and Subscibed to before me this day of , So Answers: r' .~ ~.~'`'~ R. Thomas Kline 07/12/2007 WELTMANWrE INBERG RE I S By:(/J ~~ r ~ eputy Sheriff A.D. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CITIBANK (SOUTH DAKOTA) NA Plaintiff vs. GEORGE E SEIDLE Defendant No. 07-4004 CIVIL TERM PRAECIPE FOR DEFAULT IUDGMENT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: WILLIAM T. MOLCZAN, ESQUIRE PA LD.#47437 Weitman, Weinberg & Reis Co., L.P.A. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#05902489 Judgment Amount $ 1084.61 THIS LAW FIRM IS ATTEMPTING TO COLLECT THIS DEBT FOR ITS CLIENT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CITIBANK (SOUTH DAKOTA) NA Plaintiff vs. Civil Action No. 07-4004 CIVIL TERM GEORGE E SEIDLE Defendant TO THE PROTHONOTARY: PRAECIPE FOR DEFAULT JUDGMENT Kindly enter Judgment against the Defendant, GEORGE E SEIDLE above named, in the default of an Answer, in the amount of $1084.61 computed as follows: Amount claimed in Complaint $1.084.61 Interest from date of judgment at the legal interest rate of 6% per annum TOTAL $1084.61 I hereby certify that appropriate Notices of Default, as attached have been mailed in accordance with PA R.C.P. 237.1 on the dates indicated on the Notices. WELTMAN, WEINBERG & REIS CO., L.P.A. By; WILLIAM ~'. MOLCZ~N, ESQUIRE PA 1.D.#47437 weltman, Weinberg & Reis Co., L.P.A. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#05902489 Plaintiffs address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7w Avenue, Pittsburgh, PA 15219 And that the last known address of the Defendant is: 813 WERTZVILLE ROAD, ENOLA, PA 17025 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CITIBANK (SOUTH DAKOTA) NA Plaintiff GEORGE E SEIDLE Defendant TO: George E Seidle 813 Wertzville Rd Enola,Pa 17425 07-4004 CIVIL TERM Il4iPORTANT NOTICE Date of Notice: (¢~,, '7~x~ 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 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 A LAWYER AT ONCE. 1F 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. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717} 249-3166 WELTMAN, WEINBERG & REIS CO., L.P.A. By' James C. armbrodt, P.A.I.D.# 524 Weltm einberg & Reis Co .,L.P.A. 436 See Avenue, Suite 27l 8 Pitts , PA 15219 (41 4-7955 F 412-338-7130 WWR #05902489 IN THE COMMON PLEA5 COURT OF CUMBERLAND COUNTY, PENNSYLVANIA CNIL DNISION CITIBANK (SOUTH DAKOTA) NA Plaintiff vs. GEORGE E SEIDLE Defendant Case no: 07-4004 CIVIL TERM NON-MILITARY AFFIDAVIT The undersigned, who first being duly sworn, according to law, deposes and states as follows: That he/she is the duly authorized agent of the Plaintiff in the within matter. Affiant further states that the within Affidavit is made pursuant to and in accordance with the Servicemembers' Civil Relief Act (SCRA), 50 U.S.C. App. § 521. Affiant further states that based upon investigation it is the affiant's belief that the Defendant, GEORGE E SEIDLE is not in the military service. Affiant further states that this belief is supported by the attached certificate from the Defense Manpower Data Center (DMDC), which states that the Defendant, GEORGE E SEIDLE is not in the military service. Further Affiant sayeth naught. AFFIANT presence this day ~,q , L``1 ~r'-q~ ,,~,,, Ii~C`~r ~'WC?~~TH OF PEP1AlS ? ...-=- '~?~G J Kelt~, Rio,~rt ~-~ , .~ ~, ,c ~. ~n ~..~"~: __.-.-~ lia Asso^;~. ~ y~ ~a. ~; yes DRc:~ber, f This law firm is a debt collector attempting to collect this debt for our client and any information obtained will be used for that purpose. Request for Military Status Department of Defense Manpower Data Center Military Status Report Pursuant to the Servicemembers Civil Relief Act Page 1 of 2 AUG-31-2007 09:48:55 ~C Laet Name First/Middle Begin Date Active Daty Statue Service/Age~cy SEIDLE GEORGE Based on the information you have furnished, the DMDC does not possess any information indicating that the individual is currently on active duty. Upon searching the information data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the current status of the individual as to all branches of the Military. ~~ ~-~- Mary M. Snavely-Dixon, Director Department of Defense -Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The Department of Defense strongly supports the enforcement of the Servicemembers Civil Relief Act [50 USCS Appx. §§ 501 et seq~ (SCRA) (formerly the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's active duty status by contacting that person's Military Service via the "defenselink.mil" URL provided below. If you have evidence the person is on active-duty and you fail to obtain this additional Military Service verification, provisions of the SCRA may be invoked against you. If you obtain further information about the person (e.g., an SSN, improved accuracy of DOB, a middle name), you can submit your request again at this Web site and we will provide a new certificate for that query. This response reflects current active duty status only. For historical information, please contact the Military Service SCRA points-of-contact. See: htt~•//www defenselink mil/faq/pis/PC09SLDR.htm1 WARNING: This certificate was provided based on a name and Social Security number (SSN) provided https://www.dmdc.osd.miUscra/owa/scra.prc_Select 8/31 /2007 Request for Military Status r ~ ~' Page 2 of 2 by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID:HSYQXLWAXO https://www.dmdc.osd.miUscra/owa/scra.prc_Select 8/31 /2007 C'+ ~ C3 C .Y ' f~/~ ~ ~ Q ~ } _ ~ ~~-"-+; 5 4.% ~ ~ ~/ {t ~ ~~ 1 ' •) ws ~ ~ OQ ~, V D r -~ ' -i ~ -~~ L*"1 7~ ~"` CX7 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CITIBANK (SOUTH DAKOTA) NA Plaintiff vs. Civil Action No. 07-4004 CIVIL TERM GEORGE E SEIDLE Defendant NOTICE OF JUDGMENT OR ORDER TO: ( )Plaintiff (xx) Defendant ( )Garnishee You are hereby notified that the following Order or Judgment was entered against you on 0 (xx) Assumpsit Judgment in the amount of $1084.61 plus costs. ( ) Trespass Judgment in the amount of $ plus costs. ( ) If not satisfied within sixty (60) days, your motor vehicle operator's license and/or registration will be suspended by the Department of Transportation, Bureau of Traffic Safety, Harrisburg, PA. (xx) Entry of Judgment of ( ) Court Order ( ) Non-Pros ( ) Confession (xx) Default ( ) Verdict ( ) Arbitration Award Prothonotary By: , D PR ONOTARY (OR DEP ) GEORGE E SEIDLE 8l3 WERTZVILLE ROAD ENOLA, PA 17025 Plaintiff s address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7~' Avenue, Pittsburgh, PA 15219 1-888-434-0085