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HomeMy WebLinkAbout07-4591 Burton Neil & Associates, P.C. By: Derek C. Blasker, Esquire ID. N0.202150 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 701 East 60th Street N, Sioux Falls, SD 57117 Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. WILLIAM T PHILLIPY IV NO. p''j- y,59~ Ci~i ~ Te,~ 236 Erford Road, Camp Hill PA 17011-1207 Defendant 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 aze 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-12026 a Burton Neil & Associates, P.C. By: Derek C. Blasker, Esquire, I.D. N0.202150 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. • WILLIAM T PHILLIPY IV 236 Erford Road, Camp Hill PA 17011-1207 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 49= Y54i c.u,~ ~~c,~., CNIL 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 William T PHILLIPY IV, who resides at 236 Erford Road, Camp Hill, 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 5424180135224563 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 > w for the sum of $4,283.46 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 $4,283.46, and the costs of this action. Burton '1 & sociat s, .C. By: rek C. sker, E quire The law firm of Burton Neil & Associates, P.C. is a debt collector. a Verification I, l~-r'~,c~aeL (~e2rzY 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 on its behalf. 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. Signature William T PHILLIPY IV 5424180135224563 ,. - 05/02/07 X4283.46 84283.46 SITE:KC-CL TM:CO-5000 ACID:KCB3104 ~~~ a?t#~ _a~~;s~aassssi~` 0 5/ 2 2/ 0 7 ••• ~ 22:22:36: CITI CARDS WILLIAM T PHILLIPY IV PO BOX 183059 236 ERFORD RD COLUMBUS, OH CAMP HILL PA 43218-3059 17011-1207000 s'~ ~~ Citi® Platinum Select® Card ~ tie Attount Number 5424 1801 3522 4563 Customer Servke: 1-800-950-5114 Total Credit Llne Available CredI;LOIne Cash Advance LImIt Available Cash Limit BOX 6500 X3370 New Bal 52500 SIOUX FALLS, SD statement/ Amount over $0 ance 54283.46 57117 Closin Date Credit Line Past Due Pureh/Adv 96 MlnimumDue 04/12/2x07 5913.46 5836 Mlnlmum Amount Due . salaDate Post Date ReterenceNumber 5188.30 Acthlty since Lest statement $4283.46 Standard Purch 4/12 Amount LATE FEE - MAR PAYMENT PAST DUE 4/12 66 0000 00000000009'00 PURCHASES*FINANCE CHARGE*PERIODIC RATE 84 0000 107.30 0000000000 Your late fee was based on your account balance as of the payment due date (04/03/07), which was $4,137.16. Help is available! Please call the toll-free number shown above to learn about al payment options. Call Monda c - F id 8u st 5 y o r am ay, 7 am to 9 pm, or Saturday, pm, Central Time. Please give us the opportunity to a i ss st you. Account Summary Nrevious Balance (+) urc ases (-) aymen s & Advances (+) FI ANC (°) New PURCHASES ADVANCES $4,137.16 & Credits $88 00 CHARGE Balance TOTAL $0.00 $4,137.16 . 0.00 $0'00 0.00 $39.00 $107.30 $4,283.46 00 $0 0 0.00 . $1 7.30 $4,283.46 Rate Summary Ba ante 5u sec o Peroo Ic Da s Thls Blllln Period: 29 PURCHASES Finance Char a Rate Nomura ANNUAL APR Standard Purch $4 188 73 PERCENTAGE RATE ADVANCES , . 0.08833%(D) 32 240% Standard Adv $0.00 0.08833%(D) . 32.240% 32.240% 32.240% EXHIBIT -6Q (7 (' "~ ° ~'- ~ -C- t~ . rT'rn a• ik ~ r , ~' ~ ~ ~. G7 :'n .C ,~ ~ `'~ rr~~v f V ~t"t' ~~~~ _ ~ ' ~ r, ;;~ ~' ~ ~" `G ' Cp SHERIFF'S RETURN - REGULAR CASE NO: 2007-04591 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITIBANK (SOUTH DAKOTA) NA VS PHILLIPY WILLIAM T IV SHARON LANTZ Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE PHILLIPY WILLIAM T IV DEFENDANT was served upon the at 2027:00 HOURS, on the 6th day of August 2007 at 236 ERFORD ROAD CAMP HILL, PA 17011-1207 TATT T.T TTM DIITT.T .T DV T~7 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 13.44 Affidavit .00 Surcharge 10.00 ~ ~I'tlo~ C.~.~ 00 4 Sworn and Subscibed to before me this day of , So Answers: ~~E !' R. Thomas Kline 08/07/2007 BURTON NEIL & ASSOCIATES By: Deputy She ff A.D. CITIBANK (SOUTH DAKOTA), N.A. IN THE COURT OF COMMON PLEAS 701 East 60th Street N, Sioux Falls, SD 57117 Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. WILLIAM T PHILLIl'Y IV 236 Erford Road Camp Hill PA 17011-1207 N0.07-4591-CIVIL Defendant :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 $4,283.46 $4,283.46 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 GIVEN UNDER PA.RCIV.P. 236 S o Prothonotary Burton eil As ciates, B. Derek C. Blasker, Esquire Attorney for Plaintiff I.D. #202150 1060 Andrew Drive, Suite 170 W. Chester, PA 19380 The law firm of Burton Neil & Associates is a debt collector. C-12026 ~~N INI I I~~I~INI I N IIII CITIBANK (SOUTH DAKOTA), N.A Plaintiff' v. WILLIAM T PHILLIPY N Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA N0.07-4591-CNIL CNIL ACTION -LAW Notice of Intention to File Praeclpe for Default Judgment TO: William T Phillipy N 236 Erford Road Camp Hill PA 17011-1207 IMPORTANT NOTICE c-12026 You are in default because you have failed to enter a written appearance personally or by attorney and file in writing with the court yow 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 yow property or other important rights. You should take this notice to yow 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: August 28, 2007 In making this communication, we advise our office is a debt collector. ~~~ on eil Associa .C. By: Derek . Blas er, Esquire Attorney for Plaintiff Identification No. 202150 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 i Z ~-: R '~ ~ ~- r~. -u m ~ ~~ 6' ~ ~ ° "` +, Burton Neil & Associates, P.C. BY: Derek C. Blasker, Esquire 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 ATTORNEY FOR: Plaintiff ID. N0.202150 CITIBANK (SOUTH DAKOTA), N.A. Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. WILLIAM T PHILLIl'Y IV Defendant IN THE COURT OF COMMON PLEAS N0.07-4591-CIVIL :CIVIL ACTION -LAW Rule of Civil Procedure N0.236 (Revised) Notice is given that a JUDGMENT in the above captioned matter has been entered against you on 9'I~/0'1 Prothonotary By: ~ ~ . pKB If you have any questions concerning the above, please contact: Derek C. Blasker, 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.