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Home My WebLink About07-5413~~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CITIBANK (SOUTH DAKOTA) NP. Plaintiff No: (~-Jr' X13 c~~;~?,~ vs JASON R MANBECK COMPLAINT IN CIVIL ACTION Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt,42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 Seventh Avenue, Suite 2718 Pittsburgh, PA 15219 (412) 434-7955 FAX: 412-338-7130 06152440 C J Pit KXW IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CITIBANK (SOUTH DAKOTA) NA Plaintiff vs. Civil Action No JASON R MANBECK Defendant COMPLAINT AND NOTICE TO DEFEND 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 (20) days after this complaint and notice are served, by entering a written appearance personally or by an 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 other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THI5 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. 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 REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 COMPLAINT 1. Plaintiff is CITIBANK (SOUTH DAKOTA) NA with place of business located at 701 East 60th Street North, Sioux Falls, South Dakota, 57117. 2. Defendant is adult .individual(s) residing at the address listed below: JASON R MANBECK 2114 BRIGADE RD ENOLA, PA 17025 3. Plaintiff is a national banking association, engaged in consumer lending through the issuance of credit cards. 4. Pursuant to Defendant's request, Plaintiff furnished to the Defendant a credit card account (hereinafter account) bearing account number 5424180481562780 . 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 st<}.ted the previous balance, the debits and credits to the account for t:'~te prior billing period. 7. Defendant's actions as set forth above constituted an account stated between parties for the sum of $22958.75 which sum reflects the Exhibit A statement balance less credits,. if any, which were applied subsequent to the date of Exhibit A. Wherefore, the Plaintiff prays for judgment in its favor and against Defendant JASON R MANBECK INDIVIDUALLY in the amount of $22958.75 with continuing interest thereon at the rate of 6.000 per annum from date of judgment plus costs. James Warmbrodt,42524 WEL , WEINBERG & REIS CO., L.P.A. 436 ev nth Avenue, Suite 2718 Pit sbu gh, PA 15219 (4 2) 34-7955 F 2-338-7130 0 152' 40 C J Pit KXW 08/03/07 522958.75 522958:75 SITE:KC-CL TM:CO-5000 ACID:KCB3104 ~~ _ •-• 07/24/07 20:58:15: CITI CARDS PO BOX 183056 JASON R MANBECK COLUMBUS. OH ATTNY ACCOUNT-CODE=PRLG 43218-3056 ENOLA PA 17025-1453000 ® eiect~ Card ~ t~. Citi Platinum S AaoiaN N~miOer 5424 1804 8156 2780 C+~sbontar Starvlc~ 1-800-950-5114 Total Credit tine Available CredR tint Cash Advance Umit Available Cash Limlt New Ealance BOX 6500 Sib800 50 51500 50 522958.75 statement/ Amount Over Purch/Adv Minimum SIOUX FALLS r SD Closing Oate Credit Lina Past Due l~Inimwn Due Amovat Due 57117 07/10/2007 56158.75 58076.85 1809.39 522958.75 -_~ __._ e-s-.--..~ w..~... aetMtr Sieu Last StabmtM _ Amount Standard Purch 7/10 g4~H0000*FINANCE CHARGE•PERIODIC RATE 00000000500 ~72 Balance Transfer - Chargqed To Offer 4 7/10 84RCHOOOO~FINANCE CHARGE+PERIODIC RATE 0000000000 '67 Help is available! Please call the toll-free nualber shown above to learn about BuaaStoc5apmpayCentralpTioalne ~ Please q~veyus tAe opportunity to assistsyourday, Account Summary revious Balance + ure ases - ayme s & Advances & Credits + CHARGE ew Balance PURCHASES 522,378.36 0.00 0.00 550.39 00 0 ;22,958.75 00 50 ADVANCES TOTAL 0.00 522,38.36 0.00 0.00 0.00 0.00 . 5580.39 . 522,958.75 Da s This BIIII Period: 29 a once sec o eno is arllne ANNUAL Rate Summary Finance Charg e Rate APR PE RCENTAGE RATS PURCHASES Standard Purch 519,781.52 79 75 0.08833%(D) 08833%(D) 0 32.240% 32.240% 32.240% 32.240% Offer 4 . 52,8 . ADVANCES Standard Adv 50.00 0.08833%(D) 32.240% 32.240% Verification ERICKA SMITH I~ , 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. JASON R MANBECK 54241804815b2780 WWR#06152440 ~' o`o -4 0@ -a ~ ~ . ~, VI -,3 ~~ ~~ C v N. -fl ~ ~± w ET SHERIFF'S RETURN - REGULAR CASE NO: 2007-05413 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITIBANK (SOUTH DAKOTA) NA VS MANBECK JASON R DAVID MCKINNEY Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon MANBECK JASON R the DEFENDANT at 1546:00 HOURS, on the 26th day of September, 2007 at 2114 BRIGADE ROAD ENOLA, PA 17025 by handing to JASON MANBECK 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 ~v~Q Oi~ Sworn and Subscibed to before me this of So Answers: 18.0 0 ~~~~ ,/.J'r~'%~'-~" ~~-~ 14.4 0 '" ~`" _a~-~ ~"--~ .00 10.00 R. Thomas Kline .00 42.40 09/27/2007 WELTMAN WEINBERG REIS By. day Deputy She iff A.D. s ~as~~-~ ~2.(y`~QnbQc~ Dcfc:ndant III: rl-IE~~ryIlnp+t ouRr of ~ Cot1Nr~, Sr.ATE of ~ `~ ~Ck. ` ' f~^ ~~"\ ~'~ Plarnti fI; .ASE NUMBER: ~ ~ - 5 C f /3 ~~, vs. _. :~~5\YER TO CC)i~1PLAINT CO&~I~ES NOW the Defen~ant in tl~e abar~e styled cause to answer the PlaintifFs Catuplaint asp follows: _,~,~ Q-{{~~,~c i Dated this ~ ~ C~C~heo~ . ~OC)~ Respectfully Snbnaitted, Si~ttire of Dt•fendant CERTIFICATE OF SERVICE , I, the m7dcrsigned, hereby certify that f ha~re sc:rvcd the 'Plaintiff or its attorney with a copy of tl~~s pleading by US nail, postage pre-paid, on this the day of Q~-_. ?t)O~ ~I i I'~ ~~ ~ I, Defendant ~- ,R October 10, 2007 Cumberland County Court System We received your compliant in regards to the outstanding balance of $22,9~~58.75 to our Citibank credit card account. We have been working with a debt consolidation since January of 2007 named Freedom Debt Relief. We have been sending them payments in the amount of $117/month for them to negotiate payoff with our credit card companies. We have been su'~cessful in paying one off and are working to get our account balance built up again tq pay off the rest. They estimate that be being in the program we should have all our de~t paid off by June of 2009. We are working to maker larger payments to the plan in hopes of getting tl~~~is resolved quicker. The contact information for Freedom Debt Relief is 1875 S. Grant Street, S~luite 400, San Mateo, CA 94402. They can be reached at 1-800-993-8950. We are working very hard to get all our debt paid off and trying to make everyone whole. We are good for this, however need more time to get this matter resolved. '~ ~I n ~~ ~ w~ -rice: ~ '} ,~I TC ;"i~t ~=-' "... ~~'~ ~~ .1- '~~ ~ i 4~n ~ J j Yr ~ i" .N • ~ r .O~ ~ ' Y IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CITIBANK (SOUTH DAKOTA) NA, Plaintiff, vs. JASON R MANBECK, Defendant. Case No.: 07-5413 CIVIL TERM MOTION FOR JUDGMENT ON THE PLEADINGS FILED ON BEHALF OF: Plaintiff COUNSEL OF RECORD OF THIS PARTY: 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 W WR No. 6152440 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CITIBANK (SOUTH DAKOTA) NA, Plaintiff, Case No.: 07-5413 CML TERM vs. JASON R MANBECK, Defendant. MOTION FOR JUDGMENT ON THE PLEADINGS AND NOW COMES, Plaintiff, by and through its counsel, Weltman, Weinberg & Reis, Co., L.P.A., and hereby files this Motion for Judgment on the Pleadings and respectfully moves this Court pursuant to Pennsylvania Rule of Civil Procedure 1034 for judgment on the pleadings. In support thereof, Plaintiff avers as follows: 1. This action arises out of the accumulation of credit card debt by Defendant. 2. Plaintiff filed a Complaint against Defendant seeking judgment in the amount of $22958.75 with additional interest at the rate of 6.0 per annum from Date Of Judgment, plus costs. A true and correct copy of the Complaint is attached hereto as Exhibit "A" and made a part hereof. 3. Attached to the Complaint was Verification from an authorized representative of Plaintiff verifying the accuracy of the amount sought. See Exhibit "A". 4. Defendant Pro Se filed an Answer in response to the Complaint, admitting all of the material facts pled in the Complaint and stating only that he is working with a Debt Settlement Company. A true and correct copy of Defendant's answer is attached hereto as Exhibit "B" and made a part hereof. 5. Financial inability to repay a debt is not a defense in an action to collect that debt. WWR No. 6152440 6. Under Pennsylvania Rule of Civil Procedure 1029(b), the averments of the pleading to which a response is required are deemed admitted when not denied specifically. 7. Defendant's answer contained no meritorious defenses asserted through New Matter. 8. Under Pennsylvania Rule of Civil Procedure 1032(a), "a party waives all defenses and objections which are not presented either by preliminary objection, answer or reply..." 9. The pleadings are closed and time exists to dispose of this Motion before trial. 10. No genuine issue of material fact exists as to Plaintiff's claim. 11. Plaintiff is entitled to judgment in its favor as a matter of law on the amount sought in the Complaint. WHEREFORE, Plaintiff respectfully requests that this Honorable Court enter an Order directing judgment on the pleadings in favor of Plaintiff and against Defendant, Jason R Manbeck, in the amount of $22958.75 with additional interest at the rate of 6.0% per annum from Date Of Judgment, plus costs. Respectfully Submitted: ~~ William T. Molcz squire PA I.D. # 437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR No. 6152440 C7 C '*~ o° ~~~ ?T7 f ~ '; ~ T'z"~ .~ f ... -'. r N Q . r- ~=~- ~ ~7 ~ - . rt C~. W C3Z -C IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CITIBANK (SOUTH DAKOTA) NP, Plaintiff No ~ Qr] - 5413 CIV~ ~ T,P.rr~ vs. JASON R MANBECK COMPLAINT IN CIVIL ACTION Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt,42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 Seventh Avenue, Suite 2718 Pittsburgh, PA 15219 (412) 434-7955 FAX: 412-338-7130 06152440 C J Pit KXW EXHIBIT -~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CITIBANK (SOUTH DAKOTA) NA Plaintiff vs. Civil Action No JASON R MANBECK Defendant COMPLAINT AND NOTICE TO DEFEND 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 (20) days after this complaint and notice are served, by entering a written appearance personally or by an 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 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. 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 REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 COMPLAINT 1. Plaintiff is CITIBANK (SOUTH DAKOTA) NA with place of business located at 701 East 60th Street North, Sioux Falls, South Dakota, 57117. 2. Defendant is adult individual(s) residing at the address listed below: JASON R MANBECK 2114 BRIGADE RD ENOLA, PA 17025 3. Plaintiff is a national banking association, engaged in consumer lending through the issuance of credit cards. 4. Pursuant to Defendant's request, Plaintiff furnished to the Defendant a credit card account (hereinafter account) bearing account number 5424180481562780 . 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 t::ze prior billing period. 7. Defendant's actions as set forth above constituted an account stated between parties for the sum of $22958.75 which sum reflects the Exhibit A statement balance less credits, if any, which were applied subsequent to the date of Exhibit A. Wherefore, the Plaintiff prays for judgment in its favor and against Defendant JASON R MANBECK INDIVIDUALLY in the amount of $22958.75 with continuing interest thereon at the rate of 6.000 per annum from date of judgment plus costs. James Warmbrodt,42524 WEL WEINBERG & REIS CO., L.P.A. 436 ev nth Avenue, Suite 2718 Pit sbu gh, PA 15219 (4 2) 34-7955 F 2-338-7130 0 152 40 C J Pit KXW -~ ~f~' 08/03/07 $22958.75 $22958.75 SITE:KC-CL TM:CO-5000 ACID:KC63104 =#i~=: :: =_ :#k3i~ ~#s~== 0 7/ 2 4/ 0 7 2 0: 5 8:15 CITI CARDS PO BOX 183056 JASON R MANBECK COLUMBUS. OH ATTNY ACCOUNT-CODE=PRLG 43218-3056 ENOLA PA 17025-1453000 Citi~ Platinum Select Card ~ t~~ AcCOWIt Nta11blf 5424 1804 8156 2780 Gttsttxrter Sertrke: 1-800-950-5114 Total CreAlt Line Available Credit Line Cash Advance Umit Avail able Cash Limit New balance $16800 $0 $1500 $0 $22958.75 BOX 6500 SIOUX FALLS. SD Statement/ Amount Over Closing Data Credit Line Pest Due Parch/Adv inimum Due Mlnlmum Amount Due 57117 07/10/2007 $6158.75 $8076.85 809.39 $22958.75 SeM Date Post Data Rahrenca Number Acthrity Since Last Statement Amoum Standard Purch 7/10 PURCHASES*FINANCE CHARGE*PERIODIC RATE 506.72 64 0000 0000000000 Balance Transfer - Charged To Offer 4 7/1o PuRCHASES*FINANCE CHARGE*PERIODIC RATE 73.67 84 0000 0000000000 Help is available! Please call the toll-free number shown above to learn about our special payment options. Call Monday - Friday, 7 am to 9 pm, or Saturday, 8 am to 5 pm, Central Time. Please give us the opportunity to assist you. D(Hj ~Ii l Account Summary revious (+) urc ases (-) Paymen s (+) ANC =) ew Balance & Advances & Credits CHARGE Balance 'URCHASES $22,378.36 0.00 0.00 $580.39 $22 958.75 ADVANCES ' $0.00 0.00 0.00 $0.00 , S0.00 OTAL $22,378.36 0.00 0.00 $580.39 $22,958.75 Da s Thls Btltin Period: 29 Rate Summary a ante u sec o Peroo lc Nomina ANNUAL Finance Charge Rate APR PERCENTAGE RATE 'URCHASES Standard Purch $19,781.52 0.08833%(D) 32.240% 32.240% Offer 4 $2,875.79 0.08833%(D) 32.240% 32.240% DVANCES Standard Adv ;0.00 0.08833%(D) 32.240% 32.240% Verification ERtCtC~4 SMITH I, , 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 I8 Pa. C.S. Section 4904, relating to unsworn falsification to the authorities. JASON R MANBECK 5424180481562780 WWR#06152440 %a l1` THEt`~ ~~mw i ~~'~k~'OL`RT OF~y 1-• ;;~e~ COUNTS', PlaintiFF, 'CASE I~;UiviBER: ~='~-5 yl3 i vS. Defendant. .~NS~?1'ER TO COATPG~VT COh~IES VO~V the Defeo 1 snit in tl~e above styled cause to ~uls~t%er the Flauztiff's Complaint as folio«~s: EXHIBIT B Dated this ~ (~i :~~}~'~°~ '~'~~ Respectfully Submitted, is~ture ofDefend~~int CERTIFICATE OF SERVICE I, the tu~dersigned, hereby certi i'~- that I have s~;rved the Plaintiff or its attorney with a copy oFthis pleading by US mail. postage pre-paid, o~i this the t~day of ~~_, 200' Defendant October 10, 2007 Cumberland County Court System We received your compliant in regards to the outstanding balance of $22,958.75 to our Citibank credit card account. We have been working with a debt consolidation since January of 2007 named Freedom Debt Relief. We have been sending them payments in the amount of $1175/month for them to negotiate payoff with our credit card companies. We have been successful in paying one off and are working to get our account balance built up again to pay off the rest. They estimate that be being in the program we should have all our debt paid off by June of 2009. We are working to maker larger payments to the plan in hopes of getting this resolved quicker. The contact information for Freedom Debt Relief is 1875 S. Grant Street, Suite 400, San Mateo, CA 94402. They can be reached at 1-800-993-8950. We are working very hard to get all our debt paid off and trying to make everyone whole. We are good for this, however need more time to get this matter resolved. CERTIFICATE OF SERVICE A true and correct copy of Plaintiff's Motion for Judgment on the Pleadings and Brief in support thereof has been served by U.S. Mail, Postage Pre-Paid, on o2~{~h day of [Jr,Y , 2007, upon the following: Jason R Manbeck 2114 Brigade Rd Enola Pa 17025 BY: ~.u William T. Molczan squire PA I.D. #4743 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR No. 6152440 VERIFICATION The undersigned does hereby verify subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities, he is an attorney for the Plaintiff herein; makes this Verification based upon the facts as supplied to him by the Plaintiff and/or its agents and because the Plaintiff is outside the jurisdiction of the court and the Plaintiff's Verification cannot be obtained within the time allowed for filing of this Motion, and that the facts set forth in the foregoing Motion are true and correct to the best of his knowledge, information and belief. 1/" , Attorney for Plaint' WWR No. 6152440 n '~ Q c~~ ~ -n ._ _,~..,. ~ .~ ii T -`*' _ i L-.~+` ~~J~ -i ~. _ ..,- •i J} ' ~ ~ " _, ~•i r f~ `a ` ~. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DNISION CITIBANK (SOUTH DAKOTA) NA Plaintiff vs. No.07-5413 CIVIL TERM PRAECIPE FOR ENTRY OF JUDGMENT BY CONSENT JASON R MANBECK Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt, Esquire PA I.D. #42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#6152440 i ~ IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CNIL DIVISION CITIBANK (SOUTH DAKOTA) NA Plaintiff vs. JASON R MANBECK Defendant TO THE PROTHONOTARY: Civil Action No. 07-5413 CNIL TERM PRAECIPE FOR JUDGMENT BY CONSENT Kindly enter Judgment against Defendant, Jason R Manbeck, in the amount of $23079.65 plus costs, based upon the consent of the parties. CONSENTED TO: WELTMAN, WEINBERG & REIS CO., L.P.A., JASON R MANBECK, By: Attc W~ BY~ '~V~°r~be.~~ Defen nt 1• IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CNIL DNISION CITIBANK (SOUTH DAKOTA) NA Plaintiff vs. Civil Action No. 07-5413 CIVIL TERM JASON R MANBECK Defendant STIPULATION OF THE PARTIES FOR PAYMENT AND FOR THE ENTRY OF JUDGMENT BY CONSENT TO THE PROTHONOTARY: Kindly enter Judgment in favor of Plaintiff and against the Defendant, Jason R Manbeck, above-named, in the amount of $23079.65 pursuant to the Stipulation of the Parties for Payment and for the Entry of Judgment by Consent, as follows: Defendant admits indebtedness to Plaintiff in the amount of $23079.65 with continuing interest thereon at a rate of 6.0% per annum plus costs from November 14, 2007. 2. To secure the repayment of said indebtedness, Defendant agrees that Judgment by Consent will be entered in favor of the Plaintiff and against the Defendant, Jason R Manbeck, in the amount of $23079.65 plus continuing interest thereon at the rate of 6.0% per annum from November 14, 2007 and costs. Plaintiff agrees not to execute on its Judgment so long as Defendant causes to be delivered to Plaintiff the following payments in full by 12:00 NOON on the following dates: (a) $700.00 due by 11/30/07; (b) $700.00 due on the LAST day of each consecutive month thereafter until the Judgment amount plus accrued interest and costs are paid in full. ~. 4. All payments are to be made payable to the order of "CITIBANK (SOUTH DAKOTA) NA" 5. All payments due under this agreement are to be received at the offices of Weltman, Weinberg & Reis, Co., L.P.A., P.O. BOX 5430, Cleveland, OH 44101-0430. 6. In the event of default, each payment received shall be first attributed to costs, interest and then to principal. 7. Time is of the essence of this agreement and should the Defendant fail to have in the hands of Plaintiff or Plaintiff s counsel any payment in full within five (5) calendar days of the stated due date, then Plaintiff shall be immediately free to issue Execution as well as pursue all other remedies, in law or in equity, to collect the full balance of the Judgment entered hereunder plus appropriate additional interest and costs. 8. No act or omission of the Plaintiff, nor of anyone alleged to be acting on its behalf, shall constitute a waiver, estoppel, or any other excuse for non-performance of any duty undertaken by the Defendant in this Stipulation which the parties agree is final and complete. 9. Intending to be legally bound, the parties set their hands and seals this ~~ay of-~l ~,!~~ 20 WELTMAN, WEINBERG & REIS CO., L.P.A. By; ~ James C. brodt, Esquire PA LD. #42 4 WELTMA , WE ERG & REIS CO., L.P.A. 2718 Kop ers B lding 436 Seve th Av ue Pittsbur , PA 5219 (41 ) 43 955 W R o. 6152440 By. _ ~~~,ao-m-v~ Defen ant, Jason R Manbeck ~ ~ a c ~ : -~ ~, ~ ~ c~ _. = ;.:~4 ~ ~. ,,~ r-.... ~...- , r . -- ~- ~ ~ - ~a .._~ 1+. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CITIBANK (SOUTH DAKOTA) NA Plaintiff vs. Civil Action No. 07-5413 CIVIL TERM JASON R MANBECK 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 (xx) Assumpsit Judgment in the amount of $23079.65 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 ( ) Default ( ) Verdict ( ) Arbitration ( ) Award (XX) By Consent Prothonotary JASON R MANBECK 2114 BRIGADE RD ENOLA PA 17025 By: PROT ONOTA y) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CITIBANK (SOUTH DAKOTA) NA Plaintiff vs. Civil Action No. 07-5413 CIVIL TERM JASON R MANBECK Defendant PRAECIPE FOR APPEARANCE Kindly enter our appearance on behalf of the Plaintiff in the above captioned matter. BURTON NEIL, By:< Yale PA I 1060 Wes (6 q ~~5x%~~~s QC. ~/ # 8~~ drew Drive, Suite 170 Nester, PA 19380 692-2120 PRAECIPE FOR WITHDRAWAL OF APPEARANCE Kindly withdraw our appearance on behalf of the Plaintiff in the above captioned matter. WELTMAN, WEINBERG & REIS CO., L.P.A. BY : !/~ William T. Mo cz ,47437 436 Seventh Aven e, Suite 1400 Pittsburgh, PA 15219 (412) 434-7955 C ~ r•~ , ~.. - ~ ~ ~: , 1 ~ ~i e~ ',~.- - W ~.."i~S A .+r ~rJ . 1 ~ '^M~ .~ V±