The URL can be used to link to this page

Home My WebLink About08-2990Burton Neil & Associates, P.C. By: Brit J. Suttell, Esquire ID. NO. 204140 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. SCOTT E BASH : NO. 0% - 01990 l'' wi t term 504 Brook Meadow Drive, Mechanicsburg PA 1 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-13797 Burton Neil & Associates, P.C. By: Brit J. Suttell, Esquire ID. NO. 204140 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 Plaintiff V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. OF - 2 9 90 Cud 72t. SCOTT E BASH 504 Brook Meadow Drive, Mechanicsburg PA 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 Scott E Bash, who resides at 504 Brook Meadow Drive, Mechanicsburg, 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 5424180546915510 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 $16,355.12 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 $16,355.12, and the costs of this action. Burton Neil & Associates, P.C. By: Brit J/ Suttell, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. 08/20/07 $16355.12 $16355.12 SITE:KC-CL TM:CO-5000 ACID:KCB3104 03/20/08 00:12:21: SCOTT E BASH 504 BURKE MEADOW DR MECHANICSBURG PA 17050 Citio Dividend Platinum Select" Card C tl• Account Number 5424 1805 4691 5510 Customer Service: 1-800-925-8871 Total Credit Line Available Credit Line Cash Advance Limit Available Cash Limit New Balance $14450 $0 $8600 $0 $16355 12 BOX 6500 . SIOUX FALLS, SO Statement/ Closin Date a Amount Over Credit Line Post Due Purch/Adv Inimum Due Minimum Amount Due 57117 07/26/2 07 $1905.12 $3995.21 590.52 $16355.12 Sale Date Post Date Reference Number Activity Since Last Statement Amount Standard Purch 7/26 PURCHASES*FINANCE CHARGE*PERIODIC RATE 84 0000 Balance Transfer - Charged To Offer 4 7/26 PURCHASES*FINANCE CHARGE*PERIODIC RATE 84 0000 Balance Transfer - Charged To Offer 7 7/26 PURCHASES*FINANCE CHARGE*PERIODIC RATE 84 0000 10.54 0000000000 339.62 0000000000 77.36 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. Please see enclosed privacy notice for important information. Account Summary Previous (+) urc ases (-) Payments (+) FINANCE (=) N ew Balance & Advances & Credits CHARGE Balance PURCHASES $15,927.60 0.00 0.00 $427.52 $16 355.12 ADVANCES $0.00 0.00 1 0.00 1 $0.00 , $0.00 TOTAL $15,927.60 0.00 0.00 $427.52 $16,355.12 Da ys This Billing Period: 30 Rate Summary Balance Subject O Periodic omina Finance Charge Rate APR PERCENTAGE RATE PURCHASES Standard Purch $397.78 0.08833%(D) 32.240% 32.240% Offer 4 $12,816.18 0.08833%(D) 32.240% 32.240% Offer 7 $2,919.33 0.08833%(D) 32.240% 32. 40% ADVANCES Standard Adv $0.00 0.08833%(D) 32.240% EXHJW CITI CARDS PO BOX 183067 COLUMBUS, OH 43218-3067 C' 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 unsworn falsification to the authorities. IS-)AUU" Signature Shauna Houghton Scott E Bash 5424180546915510 I 00 O •? 0 00 J a a C) t'V d W -on 'L3 N ? SHERIFF'S RETURN - REGULAR CASE NO: 2008-02990 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITIBANK SOUTH DAKOTA NA VS BASH SCOTT E KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon BASH SCOTT E the DEFENDANT , at 2006:00 HOURS, on the 14th day of May 2008 at 504 BROOK MEADOW DRIVE MECHANICSBURG, PA 17050 by handing to SCOTT BASH 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: So Answers: Docketing 18.00 Service 11.00 Affidavit .00 Surcharge 10.00 R. Thomas Kline .00- /a jr- 39.00 05/15/2008 BURTON NEIL & ASSOCIATES Sworn and Subscibed to By: -?O? -/?,/ before me this day De t S er' of A.D. CITIBANK (SOUTH DAKOTA), N.A. 701 East 60th Street N, Sioux Falls, SD 57117 Plaintiff V. SCOTT E BASH 504 Brook Meadow Drive Mechanicsburg PA 17050-3207 Defendant : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-2990 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 $16,355.12 $16,355.12 Understanding that false statements herein made are subject to penalty under 18 Pa. C. S. § 4904 relating to unswom 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 UND R PA.R.CIV.P. 236 - //--7,/ 4?? Pro Prothonotary Burton Neil s ociates, P.C. By: B t J. Suttell, Esquire Attorney for Plaintiff I.D. NO. 204140 1060 Andrew Drive, Suite 170 West Chester, PA 19380 The law firm of Burton Neil & Associates is a debt collector. C-13797 CITIBANK (SOUTH DAKOTA), N.A. Plaintiff V. SCOTT E BASH Defendant IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-2990 CIVIL TERM CIVIL ACTION - LAW Notice of Intention to File Praecipe for Default Judgment TO: Scott E Bash 504 Brook Meadow Drive Mechanicsburg PA 17050-3207 IMPORTANT NOTICE C-13797 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: June 9, 2008 In making this communication, we advise our office is a debt collector. Burton Neil & Associates, P.C. By; Brit J. Sutt 1, Esquire Attorney for Plaintiff Tdentification No. 204140 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 r.? Y4 -1 D e . Burton Neil & Associates, P.C. By: Brit J. Suttell, Esquire ID. NO. 204140 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. SCOTT E BASH CUMBERLAND COUNTY, PENNSYLVANIA : NO. 08-2990 CIVIL TERM Defendant : CWIL 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 to ht, /a$ A By: Deputy If you have any questions concerning the above, please contact: Brit J. Suttell, 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. IN THE UNITED STATES BANKRUPTCY COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA IN RE: SCOTT E. BASH CHERYL A. BASH Debtors SCOTT E. BASH Movant(s) V. CITIBANK (SOUTH DAKOTA),, N.A. 701 E. 60111 ST. N. SIOUX FALLS, SD 57117 Defendant(s) Case No. 01-08-bk-04730-MDF Chapter 13 ORDER The Debtor's motion to avoid a judicial lien is hereby approved. The judicial lien filed in the Court of Common Pleas of Cumberland County, Pennsylvania at Citibank (South Dakota), N.A., number 08-2990, civil action-law, is hereby avoided. Thfs dr curenl is electronically signed 'and filed ran=t)ie same date: CERTiFTED !--ROM THEt RECORD this ?i day of ---- J,qwU 20 v Clerk, U.S. 8aw.:: Dated: January 12, 2009 Per Di puly Clerk I )M_ Case 1:08-bk-04730-MDF Doc 22 Filed 01/12/09 Entered 01/12/09 14:56:16 Desc Main Document Page 1 of 1 L N i.3