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HomeMy WebLinkAbout08-3780Burton 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. CHESTER E GROVE : NO. OB? 3790 l..iVilT1'M 408 East King Street, Shippensburg PA 17257 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-14799 r 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 CITMANK (SOUTH DAKOTA), N.A. IN THE COURT OF COMMON PLEAS 701 East 60th Street N Sioux Falls, SD 57117 Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 0,F. 37 '0 CHESTER E GROVE 408 East King Street, Shippensburg PA 17257 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 Chester E Grove, who resides at 408 East King Street, Shippensburg, 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 7205 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 $26,014.44 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 $26,014.44, and the costs of this action. P.C. By: Derek C Blakker, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. 02/ie/9e *260%4-44 $26014.44 SITE:KC-CL TM:CO-5000 ACID:KCB0201 02129108 00:31:26: CITY CARDS CHESTER E GROVE PO BOX 183064 15141 TROUGH CREEK COLUMBUS, OH VALLEY PIKE 43218-3064 HUNTINGDON PA / 16652-3T10000 C- ?7? CCY Citi' Platinum Select" Card Account Number 7205 61Htm*r Seryiw, i-800-950-5114 Total Credit floe Available CredR Llne Cash Advance Limit Available Crib Llmn =21660 $0 $10900 $0 BOX 6500 Statement/ Amount Over ?arch/Adv SIOUX FALLS, 50 Clgqws1 Date Credit Line Pest Due Mirlbaeal Oue 57117 01/21/208 $4354.44 $4811.90 $1000.48 sale Date host Data Itelereea Number Acthdty S1ece Last statement Standard Purch 1/21 LATE FEE - DEC PAYMENT PAST DUE 66 0000 1/21 PPURCHASES0•FINANCE CHARGE«PERIODIC RATE 1 1 84 000 1 Balance Transfer - Charged To Offer 6 il21 P84RCNO?SO•FINANCE CHARGE«PERIODIC RATE Your late fee was based on your account balance as of the payment due date (01/15/08), which was 25,2T3.96. atie Now Balance $26014.44 Mhduwm Amount Due $26014.44 39.00 0000000000 602.38 0000000000 99.10 0000000000 Help is available! Please call the toll-free number shown above to learn about our special pa agent options. Call Monday - Friday, 7 am to 9 pm, or Saturday, 8 aln tO 5 pm, entra1 Time. Please give us the opportunity to assist you. Credit Protector WYo r 4ccount protection enrollment has been cancelled on your account effective 20/2007. W ecr+ieir h Account SuNnmary Previous t) Purchases - ayme s di +j FINANCE CHARGE a Now Balance Balance & Advances & Cre ts _ PURCHASES $25,2T3.96 $39.00 0.00 $T 1.48 $26,0? 4.44 TOTALCES $25,213.96 $39.00 100.000 $711.48 $26,014.44 Days This Billing Period: 32 Rah Summary Balance Subject to Finance Charge Periodic Rate Nominal APR PE ANNUAL RCENTAGE RATE Purch $11 ,993.84 0.08559%(D) 31.240% 31.240% 3,618.31 0.08559%(D) 31.240% 31.240% to nn 0.08559%(D) 31.240% 31.240% A Verification Shauna Houghton 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 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. d Signature Shauna Houghton Chester E Grove 17205 j„i)uc n t1nufj,12 ut, O ? ? D D -TI ? Q IV, waulow 0 SHERIFF'S RETURN - NOT FOUND CASE NO: 2008-03780 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CITIBANK SOUTH DAKOTA NA VS GROVE CHESTER 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 GROVE CHESTER E but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT & NOTICE , the within named DEFENDANT 408 E KING STREET SHIPPENSBURG, PA 17257 GROVE CHESTER E , NOT FOUND , as to PER LANDLORD, DEFENDANT NO LONGER LIVES THERE. NO FORWARDING ADDRESS ON FILE AT POST OFFICE. Sheriff's Costs: Docketing Service Not Found Surcharge So answers- 18.00 21.00 5.00 R. Thom _-Kline 10.00 Sheriff of Cumberland County .00 54.00 BURTON NEIL & ASSOCIATES 07/09/2008 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. Plaintiff V. CHESTER E GROVE Defendant To the Prothonotary: Please reinstate the Complaint. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 08-3780 CIVIL TERM CIVIL ACTION - LAW Praecipe to Reinstate The law firm of Burton Neil & Associates is a debt collector. C-14799 Attorney for Plaintiff 9b xv. p rN) c> SHERIFF'S RETURN - REGULAR CASE NO: 2008-03780 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITIBANK SOUTH DAKOTA NA VS GROVE CHESTER E 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 GROVE CHESTER E the DEFENDANT at 1510:00 HOURS, on the 26th day of August 2008 at 17 W MAIN STREET NEW KINGSTOWN, PA 17072 by handing to DOROTHY GROVE, WIFE 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 18.00 Service 6.00 Affidavit .00 Surcharge 10.00 00 t/ 34'00 Sworn and Subscibed to before me this day So Answers: R. Thomas Kline 08/27/2008 BURTON NEIL & SSOC TES By: Depu y Sheriff of A. D. CITIBANK (SOUTH DAKOTA), N.A. 701 East 60th Street N, Sioux Falls, SD 57117 Plaintiff V. CHESTER E GROVE 17 West Main Street New Kingstown PA 17072 Defendant To the Prothonotary: : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 08-3780 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 $26,014.44 $26,014.44 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 L received from the defendant and/or the Department of Defense JUDGMENT BY DEFAULT ENTERED AND DAMAGES ASSESSED AS ABOVE. NOTICE GIVEN UNDE A.R.CIV.P. 236 P Prothonotary The law firm of Burton Neil & Associates is a debt collector. States based on information P.C. Derek C. Blaskvr, Esquire Attorney for Plaintiff I.D. NO. 202150 1060 Andrew Drive, Suite 170 West Chester, PA 19380 C-14799 r.a s,? ?rs c°? r t? r 1 O G h O 6 i CITIBANK (SOUTH DAKOTA), N.A. Plaintiff Iv. CHESTER E GROVE Defendant : IN THE COURT OF COMMON PLEAS C-14799 CUMBERLAND COUNTY, PENNSYLVANIA : NO. 08-3780 CIVIL TERM : CIVIL ACTION - LAW Notice of Intention to File Praecipe for Default Judgment TO: Chester E Grove 17 West Main Street New Kingstown PA 17072 114PORTANT 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 DATE OF NOTICE: September 18, 2008 In making this communication, we advise our office is a debt collector. Attorney for Plaintiff Identification No. 202150 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 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. CHESTER E GROVE NO. 08-3780 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 0 C, & ? (, ). C3t0 2? got ono 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.