HomeMy WebLinkAbout08-3711Burton 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
Plaintiff
V.
CYNTHIA L GAISIOR
409 Sheely Lane, Mechanicsburg PA 17050-3606
IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
. L -
NO. O 8 - SIll el',.
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-14854
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
Plaintiff
V.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO.
CYNTHIA L GAISIOR
409 Sheely Lane, Mechanicsburg PA 17050-3606
Defendant : CIVIL ACTION - LAW
Complaint
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 Cynthia L Gaisior, who resides at 409 Sheely Lane, 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 ending in 2718 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 $4,285.28 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 $4,285.28, and
the costs of this action.
Burt el i& Associates, P.C.
By: AL
erek C. Blas er, Esquire
Attorney for Plaintiff
The law firm of Burton Neil & Associates, P.C. is a debt collector.
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Amount Enclosed: _
Minimum Amount Due:
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Payment Due Date: ny 5:0G PM
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CYNTHIA L GAISIOR
409 SHEELY LN CITI CARDS
MECHANICSBURGPA 17050- 3606 P.O. BOX 182564
COLUMBUS, OH43218-2564
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Verification
I,
1EIW 4M Pf*RD
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.
f
Sig ure
Cynthia L Gaisior
(lR3Mg3W A331HWA
C? s= , )
r = r ;_--1
0?0
SHERIFF'S RETURN - REGULAR
CASE NO: 2008-03711 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
CITIBANK SOUTH DAKOTA NA
VS
GAISIOR CYNTHIA L
SHANNON SHERTZER
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE
GAISIOR CYNTHIA
DEFENDANT
the
at 1123:00 HOURS, on the 28th day of June , 2008
at 409 SHEELY LANE
MECHANICSBURG, PA 17050-3606 by handing to
CYNTHIA GAISIOR
a true and attested copy of COMPLAINT & NOTICE together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Postage
Surcharge
711,516 S %1',
18.00
22.00
.59
10.00
/ .00
? 50.59
Sworn and Subscibed to
before me this
day
So Answers:
R. Thomas Kline
06/30/2008
BURTON NEIL & ASSOCIATES
By: Deputy Sher ff
was served upon
of A. D.
CITIBANK (SOUTH DAKOTA), N.A.
701 East 60th Street N, Sioux Falls, SD 57117
Plaintiff
V.
CYNTHIA L GAISIOR
409 Sheely Lane
Mechanicsburg PA 17050-3606
Defendant
To the Prothonotary:
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 08-3711 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
$4,285.28
$4,285.28
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 Bui
AND DAMAGES ASSESSED AS ABOVE.
NOTI GIVEN UND PA.R.CIV.P. 236 By:
Pro rothono
The law firm of Burton Neil & Associates is a debt collector.
P.C.
DerWC' Plasker, Esquire
Attorney or Plaintiff
I.D. NO. 202150
1060 Andrew Drive, Suite 170
West Chester, PA 19380
C-14854
CITIBANK (SOUTH DAKOTA), N.A.
Plaintiff
V.
CYNTHIA L GAISIOR
Defendant
: IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 08-3711 CIVIL TERM
CIVIL ACTION - LAW
Notice of Intention to File Praecipe for Default Judgment
TO: Cynthia L Gaisior
409 Sheely Lane
Mechanicsburg PA 17050-3606
IMPORTANT NOTICE
C-14854
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: July 23, 2008 Burto it A ociates, P.C.
By:
Derek C. I ke , quire
Attorney for Plainti
Identification No. 202150
In making this communication, we advise our office is a 1060 Andrew Drive, Suite 170
debt collector. West Chester, PA 19380
(610) 696-2120
-IZI
ap
Cil
co
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
: CUMBERLAND COUNTY,
PENNSYLVANIA
V.
CYNTHIA L GAISIOR
NO. 08-3711 CIVIL TERM
Defendant : 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 hl'a
4rothono
By:
Bertity?
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.
OF THC FILED-OFFICE
'_'1q0,' OTAPY
2010 KAR -5 PH 1:44
McNEES WALLACE & NURICK LLC
By: Debra Denison Cantor
I.D. No. 66378
100 Pine Street
Harrisburg, PA 17108-1166
(717) 237-5297
(717) 260-1667 facsimile
dcantor(-mwn.com
Attorneys for Defendant
KYLE BURLEY,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
V.
LISA M. BURLEY,
Defendant
NO. 2009-3711
CIVIL ACTION - LAW
IN DIVORCE
MOTION FOR APPOINTMENT OF MASTER
Defendant, Lisa M. Burley, moves the court to appoint a Master with respect to the
following claims:
® Divorce
? Annulment
® Alimony
? Alimony Pendente Lite
and in support of the Motion states:
® Distribution of Property (Pension and
Retirement Benefits only)
? Support
? Counsel Fees
? Costs and Expenses
1. Discovery is complete as to the claims for which the appointment of master is
requested.
2. The non-moving party has appeared in the action by his counsel, Michael A.
Scherer, Esquire.
3. The statutory grounds for divorce are 3301(c) or (d).
4. The action is contested with respect to the following claims: divorce,
equitable distribution (pension only), and alimony.
5. The action does not involve complex issues of law or fact.
6. The hearing is expected to take one (1) day.
7. Additional information, if any, relevant to the motion: None.
Date: March, 2010 Nam Cantor
Attorney for Defendant
AND NOW.
, 2010,
appointed master with respect to the following claims:
BY THE COURT:
Esquire, is
J.
MOVING PARTY
NAME: Lisa M. Burley
ATTORNEY'S NAME: Debra D. Cantor
ATTORNEY'S ADDRESS:
100 Pine Street
Harrisburg, PA 17101
ATTORNEY'S TELEPHONE NO.:
717-237-5297
ATTORNEY'S E-MAIL:
dcantor .mwn.com
NON-MOVING PARTY
NAME: Kyle Burley
ATTORNEY'S NAME: Michael A. Scherer
ATTORNEY'S ADDRESS:
19 West South Street
Carlisle, PA 17013
ATTORNEY'S TELEPHONE NO.:
717-249-6873
ATTORNEY'S E-MAIL:
mschererC&-obslaw.com
-2-
CERTIFICATE OF SERVICE
The undersigned hereby certifies that on this date a copy of the foregoing document
was served by first class mail, postage prepaid, upon the following:
Michael A. Scherer, Esquire
O'Brien, Baric & Scherer
19 West South Street
Carlisle, PA 17013
?D
?anne Barnhart
Date: March 4,2010
f A
ELF,
Burton Neil & Associates, P.C. - T
By Derek C. Blasker, Esquire ID. NO. 202150
1060 Andrew Drive, Suite 170 2010 t r
West Chester, PA 19380 aoIa auA- A3 Rih 10: a?
610-696-2120 G1 ;s'' T'(
Attorney for Plaintiff
CITIBANK (SOUTH DAKOTA), N.A. IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V.
: NO. 08-3711 CIVIL TERM
CYNTHIA L GAISIOR
Defendant : CIVIL ACTION - LAW
Praecipe to Satisfy Judgment
To the Prothonotary:
Mark the judgment Satisfied .
Burton Nbil & UADciates, P.C.
By:
Derek C\Al ker, 18squire
Attorney for laintiff
The law firm of Burton Neil & Associates is a debt collector.
C-14854
49
codt e07 21