HomeMy WebLinkAbout08-1357Burton Neil & Associates, P.C.
By: Derek C. Blasker, Esquire ID. NO. 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.
SARAH E PERRINE NO.
109 N Hanover Street, Carlisle PA 17013-2469
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 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 Bar Assoc.
32 South Bedford Street
Carlisle, PA 17013
Telephone No. 717-249-3166 or 800-990-9108
C-13389
Burton Neil & Associates, P.C.
By: Derek C. Blasker, Esquire ID. NO. 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 N
Sioux Falls, SD 57117
IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V.
3 5 j
Ctiln;t Tc?
SARAH E PERRINE NO. OR - I
109 N Hanover Street, Carlisle PA 17013-2469
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 Sarah E Perrine, who resides at 109 N Hanover Street, Carlisle,
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 5424181035661508 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 $9,086.19 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 $9,086.19, and
the costs of this action.
& Ak?ociates, P.C.
By:
Derek C. Blacker, Esquire
Attorney for Plaintiff
The law firm of Burton Neil & Associates, P.C. is a debt collector.
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Total New Balance:
$9.066.19
Minimum Amount Due:
$2,396.61
Payment Due Date:
10/04/2007
000000 MC 20 A 0
SARAH E PERRINE
109 N HANOVER ST
CARLISLE PA 17013-2469
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Account Number:
5424 1810 35661508
Amount Enclosed:
Payment must be Welled ky 5:00 PM
local time on the Payment due date.
CITI CARDS
P.O. BOX 182564
COLUMBUS, OH43218-2564
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Verification
I' Shauna Houghton
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 unswom falsification to the authorities.
Signature Shauna Houghton
Sarah E Perrin
5424181035661508
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SHERIFF'S RETURN - NOT FOUND
CASE NO: 2008-01357 P
COMMONTWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
CITIBANK SOUTH DAKOTA NA
VS
PERRINE SARAH E
R. Thomas Kline Sheriff or Deputy Sheriff, who being
duly sworn according to law, says, that he made a diligent search and
inquiry for the within named DEFENDANT
PFRRTNE SARAH E but was
unable to locate Her in his bailiwick. He therefore returns the
COMPLAINT & NOTICE ,
the within named DEFENDANT
, PERRINE SARAH E
109 N HANOVER STREET
CARLISLE, PA 17013-2469
NOT FOUND , as to
DEFENDANT DOES NOT LIVE AT GIVEN ADDRESS.
NO FORWARDING ON FILE AT POST OFFICE.
Sheriff's Costs:
Docketing 18.00
Service 4.80
Not Found 5.00
Surcharge 10.00
00
3?1 A?oF 37.80
So answers -
R. Thomas K±ne
Sheriff of Cumberland County
BURTON NEIL
03/17/2008
Sworn and Subscribed to before
me this day of
A. D.
Burton Neil & Associates, P.C.
By: Derek C. Blasker, Esquire ID. NO. 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
Plaintiff
V.
SARAH E PERRINE
33 Eastwick Lane, Carlisle PA 17015
Defendant
CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 08-1357 CIVIL TERM
: CIVIL ACTION - LAW
Praecipe to Reinstate
To the Prothonotary:
Please reinstate the Complaint.
Burton it Ass i tes, P.C.
By:
ere C. lasker, Esquire
Attorney for Plaintiff
The law firm of Burton Neil & Associates is a debt collector.
C-13389
#k '? 0
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R? d
R ?S
etid t??-?
SHERIFF'S RETURN - REGULAR
CASE NO: 2008-01357 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
CITIBANK SOUTH DAKOTA NA
VS
PERRINE SARAH E
w
SHAWN HARRISON Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
PERRINE SARAH E the
DEFENDANT , at 1012:00 HOURS, on the 8th day of April 2008
at 33 EASTWICK LANE
CARLISLE, PA 17013-2469 by handing to
SARAH PERRINE
a true and attested copy of COMPLAINT & NOTICE
together with
and at the same time directing Her attention to the contents thereof
18.00
5.00
.00
10.00
.00
? 33.00
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
y1i y/0? q.
Sworn and Subscibed to
before me this day
of ,
So Answers:
R. Thomas Kline
04/10/2008
BURTON NEIL
By:
Deputy heriff
A. D.
CITIBANK (SOUTH DAKOTA), N.A.
701 East 60th Street N, Sioux Falls, SD 57117
Plaintiff
V.
SARAH E PERRINE
33 Eastwick Lane
Carlisle Pa 17015
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 08-1357 CIVIL TERM
: 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
$9,086.19
$9,086.19
Understanding that false statements herein made are subject to penalty under 18 Pa. C.S. §
4904 relating to unworn 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.
NOTI E GIVEN U ER PA.R.CIV.P. 236
4E = is-a" F
Pro Prothono
7-
The law firm of Burton Neil & Associates is a debt collector.
Bu*ere ssociates, P.C.
By:
Blasker, Esquire
Attorney for Plaintiff
I.D. NO. 202150
1060 Andrew Drive, Suite 170
West Chester, PA 19380
C-13389
C-13389
CTTIBANK (SOUTH DAKOTA), N.A. : IN THE COURT OF COMMON PLEAS
Plaintiff
V.
SARAH E PERRINE
Defendant
CUMBERLAND COUNTY, PENNSYLVANIA
: NO.08-1357 CIVIL TERM
: CIVIL ACTION - LAW
Notice of Intention to File Praecipe for Default Judgment
TO: Sarah E Perrine
33 Eastwick Lane
Carlisle PA 17015
IMPORTANT NOTICE
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 (10)
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 your 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: April 30, 2008
In making this communication,,we advise our office is a
debt collector.
Burton
By:
Derek C.
Attorney for Plaintiff\
Identification No. 202150
1060 Andrew Drive, Suite 170
West Chester, PA 19380
(610) 696-2120
cc: Hubert Gilroy, Esquire
10 E. High Street
Carlisle, PA 17013
F - FIFE
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J Burton Neil & Associates, P.C.
By: Derek C. Blasker, Esquire ID. NO. 202150
1060 Andrew Drive, Suite 170
West Chester, PA 19380
610-696-2120
Attorney for Plaintiff
CITIBANK (SOUTH DAKOTA), N.A
Plaintiff
V.
SARAH E PERRINE
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 08-1357 CIVIL TERM
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 w?b?Q9
Prothonotary
By:
Deputy
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.