HomeMy WebLinkAbout08-3289Burton 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
V.
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
ERIC-PAUL JOHNSON : NO. C)$ - 3a8R 0w;l to m
1620 Valley Road, Mechanicsburg PA 17055-4854
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-15298
Burton Neil & Associates, P.C.
By: Brit J. Suttell, Esquire lD. 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
V.
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. o f- ? N CZc 4
ERIC-PAUL JOHNSON
1620 Valley Road, Mechanicsburg PA 17055-4854
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 Eric-Paul Johnson, who resides at 1620 Valley Road, 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 5424180823704579 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 $1,046.67 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 $1,046.67, and
the costs of this action.
Burton Neil & Associates, P.C.
By. r
Bri . Suttell, Esquire
Attorney for Plaintiff
The law firm of Burton Neil & Associates, P.C. is a debt collector.
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Total New Balance:
$1,046.67
Minimum Amount Due:
$574.49
Payment Due Date:
11/01/2007
000000 MC 20 A 0
ERIC-PAUL JOHNSON
1620 VALLEY RD
MECHANICSBURGPA17055-4854
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- Detach and follow payment instructions on reverse
MaXechechpayableto:Cltl Card$
Account Number. L, G
5424 1808 23704 579 Amount Enclosed:
Payment must be received by 5:00 PM
local time on the payment due date.
CITI CARDS
P.O. BOX 182564
COLUMBUS, OH43218-2564
EXHIBIT
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Verification
I, Sh"un&,tlon
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.
S
e
Shauns Houghton
ERIC-PAUL Johnson
5424180823704579
noiriguoH snusrl2
CD c
0
SHERIFF'S RETURN - REGULAR
CASE NO: 2008-03289 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
CITIBANK SOUTH DAKOTA NA
VS
JOHNSON ERIC PAUL
MARK CONKLIN
Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE
the
JOHNSON ERIC PAUL
was served upon
DEFENDANT
, at 1845:00 HOURS, on the 3rd day of June , 2008
at 1620 VALLEY ROAD
MECHANICSBURG, PA 17055
ERIC JOHNSON
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 14.00
Affidavit .00
Surcharge 10.00
G/D 9/DID? .00
42. 00
Sworn and Subscibed to
before me this day
So Answers:
R. Thomas Kline
06/04/2008
BURTON NEIL & ASSOCIATES
By.
Deputy Sheriff
of A. D.
CITIBANK (SOUTH DAKOTA), N.A.
701 East 60th Street N, Sioux Falls, SD 57117
Plaintiff
V.
ERIC-PAUL JOHNSON
1620 Valley Road
Mechanicsburg PA 17055-4854
Defendant
To the Prothonotary:
IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 08-3289 CIVIL TERM
CIVIL ACTION - LAW
Praecipe for Default Judgment
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
$1,046.67
$1,046.67
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.
NOTIC GIVEN UNRER PA.R.CIV.P. 236
Pro rothono
Burton Neil & Associates, P.C.
it J. Suttell, squire
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-15298
CITIBANK (SOUTH DAKOTA), N.A.
Plaintiff
V.
ERIC-PAUL JOHNSON
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 08-3289 CIVIL TERM
CIVIL ACTION - LAW
Notice of Intention to File Praecipe for Default Judgment
TO: Eric-Paul Johnson
1620 Valley Road
Mechanicsburg PA 17055-4854
IMPORTANT NOTICE
C-15298
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 30, 2008
In making this communication, we advise our office is a
debt collector.
Burton Neil & Associates, RC
By U)
Brit J. S ell, Esquire
Attorney for Plaintiff
Identification No. 204140
1060 Andrew Drive, Suite 170
West Chester, PA 19380
(610) 696-2120
?'` C=
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731
s E.,
4
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.
Plaintiff
V.
ERIC-PAUL JOHNSON
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 08-3289 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" /L/. .-2&,P 9'
rothon
By:
Deputy
If you have any questions concerning the above, please contact:
Brit J. Suttell, Esquire
Attorney for Parry 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.