The URL can be used to link to this page

Home My WebLink About08-3781Burton Neil & Associates, P.C. By: Yale D. Weinstein, Esquire ID. NO. 89678 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. HERMEET SINGH 4420 Gettysburg Road Apt 3 Camp Hill PA 17011-6612 Defendant IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. QB - 5 781 0-10t Terh : 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-15857 Burton Neil & Associates, P.C. By: Yale D. Weinstein, Esquire ID. NO. 89678 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. . NO. 0 - f ' & 700 / 0- ?-- 7.t.?- HERMEET SINGH 4420 Gettysburg Road Apt 3 Camp Hill PA 17011-6612 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 Hermeet Singh, who resides at 4420 Gettysburg Road Apt 3, Camp Hill, 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(n) AT&T Universal credit card with account number ending in 2250 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 $6,529.37 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 $6,529.37, and the costs of this action. Neil & AWciates, P.C. By. Yal P. Weinstein, Esquire A ey for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt at&t AT&T Universal Rewards Card Charter Member HERMEET SINGH Account1 IR250 Calling Card + PIN November 7 - December 7, 2007 Quick Reference Minimum Payment Due ...................................... $6,529.37 Due Date" ................................................. January 1, 2008 "Payment must be received by 5:00 pm local time on the payment due deb. Amount Past Due .......................... .................. $1,448.61 Amount Over Limit ............................................ $1,129.37 Credit Line ............................................................. $5,400.00 Available Credit ............................................................ 80.00 Cash Advance Limit ............................................. $1,700.00 Available Cash Advance Limit .................................... $0.00 Account Summary Previous Halanoe 6,324.62 Ea envllllod aid,djustments 0.00 MasterCar Activity 204.75 Total AT&T Services 0.00 New Balance $6,529.37 Note: Detailed activity starts on page 3. rV""vwmwr AT&T Universal Card Page 1 of 3 How To Reach Us Visit: www.universaleard.com Customer Service: 1-800-423-4343 or write Cardmember Services, PO Box 44167 Jacksonville, FL 32231-4167 Your late fee was based on your account balance as of the payment due date (12/03/07), which was $6,324.62. Help is available! Please call the toll-free number shown above to learn about our special payment options. Please give us the opportunity to assist you. date paid amount paid check # Clti* AT&T and the AT&T globe design are trademarks of AT&T Knowledge Ventures, licensed to Cltlgroup kw- Please follow payment Instructions outlined In the "Important Instructions for Making Payments" section of the statement. Year Account Nmber 2250 Please Enter Amowd of Payment -Enclosed Pay me Due Data Your Total sam- MNldan Amount Dus JAN 01 2008 56529.37 $6529.37 $ 2405 NC 32 A 1 AR7052042 I I I I I I 111911111/IIII I I I I I I I I I I I I I I I I I I I I I I I I I I I 111111" I I I I I II HERMEET SINGH 4420 GETTYSBURG RD APT 3 CAMP HILL PA 17011-6612 IIIIIIIIIII III11111III11I11119I 111111IIIIIII9IIl Il1l AT&T UNIVERSAL CARD P.O. BOX 18256 COLUMBUS, OH 43218-2564 EXHIBIT A d''? W s. r:"' ?'??11?KNw....:.. HERMEET SINGH Account 2254 November 7 - December 7, 2007 AT&T Universal Card Page 2 of 3 In the return-envelalpe, please: I Make your check payable to AT&T Universal Card. 2 Enclose your check or money order. Include your number and name on the front of your check or money order. Please, no cash or foreign currency. Enclose your payment coupon. Do not staple or tape It to your payment. Insert the payment coupon so that the entire AT&T Universal Card address appears through the window of your remittance envelope. HERMEET SINGH Accoun- 2250 November 7 - December 7, 2007 AT&T Universal Card Page 3 of 3 AT&T UNIVERSAL MASTERCARD ACTIVITY Purchases ............................................................................................................. Cash Advances and Checks ............................................................................... Fees ....................................................................................................................... Total MasterCard Activity .................................................................................. PURCHASES ......................................165.75 .......................................... 0.00 ........................................ 39.00 .................................... 5204.75 Total MasterCard Purchases ................................................ $165.75 Standard Purch Trans Post nescripfion Amount 12/07 PURCHASES*FTNANCE CHARGE*PERTOD 165.75 Total Standard Purch $165.75 CASH ADVANCES Cash Advance Limit ....................................... $1,700.00' `This represents a portion of your total credit line. FINANCE CHARGE INFORMATION Days In Balance Periodic Transaction ANNUAL. Nominal Periodic x Blllinq x Subject to = FINANCE + Fae/ ?ERCENTAGE APR Rate Period Finance Charge SHAM MAM am PURCHASES Standard Purch 31.490% .08627%(D) x 30 x $6,404.38 = $165.75 + $0.00 31.490% CASH ADVANCES Standard Adv 31.490% .08627%(D) x 30 x $0.00 = $0.00 + $0.00 31.490% Total FINANCE CHARGE _ $165.75 PEES Standard Purch 12/07 LATE FEE - NOV PAYMENT PAST DUE 39.00 Total Fees $39.00 AT&T SERVICES SUMMARY AT&T Universal Calling Card Calls ................................................................................................................... $0.00 I Verification M 1. + % I, Shaun 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. Signature Shaun Houghton Hermeet Singh ?i?E250 r 'loMguoH snusri2 r oinpuoH snusri2 n ? J C. ca rt Cz.; V _s ? J _y Gam" `7 SHERIFF'S RETURN - REGULAR CASE NO: 2008-03781 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITIBANK SOUTH DAKOTA NA VS SINGH HERMEET SHANNON SHERTZER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE SINGH HERMEET was served upon the DEFENDANT , at 0947:00 HOURS, on the 28th day of June , 2008 at 4420 GETTYSBURG ROAD APT 3 CAMP HILL, PA 17011-6612 HERMEET SINGH 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 Service Affidavit Surcharge 18.00 14.00 .00 10.00 .00 4 .00 Sworn and Subscibed to before me this day So Answers: .,.rte<?.,,E -10 R. Thomas Kline 06/30/2008 BURTON NEIL & ASSOCIATES By: Deputy She iff of A. D. 1 CITIBANK (SOUTH DAKOTA), N.A. 701 East 60th Street N, Sioux Falls, SD 57117 Plaintiff V. HERMEET SINGH 4420 Gettysburg Road Apt 3 Camp Hill PA 17011-6612 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-3781 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 $6,529.37 $6,529.37 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 formation received from the defendant and/or the Department of Defense website. JUDGMENT BY DEFAULT ENTERED AND DAMAGES ASSESSED AS ABOVE. NOTICE GIVEN DER PA.R.CIV.P. 236 Pr roth y Burton Neil & As4d'a/ates. P.C. By: The law firm of Burton Neil & Associates is a debt collector. Yale D f` einstein, Esquire Attom for Plaintiff I.D. . 89678 1060 drew Drive, Suite 170 Wes Chester, PA 19380 C-15857 1 CITI13ANK (SOUTH DAKOTA), NA. Plaintiff V. HERMEET SINGH Defendant IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 08-3781 CIVIL TERM : CIVIL ACTION - LAW Notice of Intention to File Praecipe for Default Judgment TO: Hermeet Singh 4420 Gettysburg Road Apt 3 Camp Hill PA 17011-6612 IMPORTANT NOTICE 0-15857 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 28, 2008 In making this communication, we advise our office is a debt collector. eil & A*ool'a4es. P.C. Bf: Yale D. Wein fin, Esquire Attorney for am iff Identificati No. 89678 1060 And w Drive, Suite 170 West Che er, PA 19380 (610) 696-2120 j; rv Pn c? r Burton Neil & Associates, P.C. By: Yale D. Weinstein, Esquire ID. NO. 89678 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA), N.A. Plaintiff V. HERMEET SINGH Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 08-3781 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 -8 /11 Log rBy: Deputy If you have any questions concerning the above, please contact: Yale D. Weinstein, 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. Chad J. Julius The Law Offices of Leslie D. Jacobson Attorneys for the Defendant 8150 Derry Street, Ste. A Harrisburg, PA 17111 - 5260 717.909.5858 717.909.7788 (fax) CITIBANK (SOUTH DAKOTA), N.A. 701 East 60th Street N Sioux Falls, SD 57117 Plaintiff V. HERMEET SINGH 4420 Gettysburg Road Apt. 3 Camp Hill, PA 17011-6612 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 08-3781 CIVIL TERM CIVIL ACTION - LAW PRAECIPE TO ADD TO THE PROTHONOTARY OF SAID COURT: Please add the attached Discharge in Bankruptcy to the above captioned case and mark the docket accordingly. Thank you. Respectfully Submitted, Dated: 1, 0l THE LAW OFFICES OF IFESLIE DAVID JACOBSON Chad J. Juliu Jeslie ttorney for Debtor Law Offices David Jacobson 8150 Derry Street Harrisburg, PA 17111.5260 717.909.5858 717.909.7788 [fax] B18 (Official Form 18) (02/09) UNITED STATES BANKRUPTCY COURT MIDDLE DISTRICT OF PENNSYLVANIA In re: Debtor(s) (name(s) used by the debtor(s) in the last 8 years, including married, maiden, and trade): Hermeet Singh 4420 Gettysburg Road Apt. 3 Camp Hill, PA 17011 Chapter 7 Case No. 1:08-bk-03964-MDF Kanwalpreet Kaur 4420 Gettysburg Road Apt. 3 Camp Hill, PA 17011 Last four digits of Social-Security, Individual Taxpayer- Identification, Employer Tax-Identification No(s)(if any): xxx-xx-3395 xxx-xx-0427 DISCHARGE OF DEBTOR(S) It appearing that the debtor(s) is entitled to a discharge, IT IS ORDERED: The debtor(s) is granted a discharge under section 727 of title 11, United States Code, (the Bankruptcy Code). BY THE COURT Dated: May 18_____200, Mary D. France United States Bankruptcy Judge SEE THE BACK OF THIS ORDER FOR IMPORTANT INFORMATION. This document is electronically signed and filed on the same date. Case 1:08-bk-03964-MDF Doc 22 Filed 05/18/09 Entered 05/18/09 01:01:09 Desc Ch 7 Discharge Page 1 of 2 B18 (Official Form 18) (02109) Continued EXPLANATION OF BANKRUPTCY DISCHARGE IN A CHAPTER 7 CASE This court order grants a discharge to the person named as the debtor. It is not a dismissal of the case and it does not determine how much money, if any, the trustee will pay to creditors. Collection of Discharged Debts Prohibited The discharge prohibits any attempt to collect from the debtor a debt that has been discharged. For example, a creditor is not permitted to contact a debtor by mail, phone, or otherwise, to file or continue a lawsuit, to attach wages or other property, or to take any other action to collect a discharged debt from the debtor. [In a case involving community property: There are also special rules that protect certain community property owned by the debtor's spouse, even if that spouse did not file a bankruptcy case.] A creditor who violates this order can be required to pay damages and attorney's fees to the debtor. However, a creditor may have the right to enforce a valid lien, such as a mortgage or security interest, against the debtor's property after the bankruptcy, if that lien was not avoided or eliminated in the bankruptcy case. Also, a debtor may voluntarily pay any debt that has been discharged. Debts That are Discharged, The chapter 7 discharge order eliminates a debtor's legal obligation to pay a debt that is discharged. Most, but not all, types of debts are discharged if the debt existed on the date the bankruptcy case was filed. (If this case was begun under a different chapter of the Bankruptcy Code and converted to chapter 7, the discharge applies to debts owed when the bankruptcy case was converted.) Debts That are Not Discharged Some of the common types of debts which are = discharged in a chapter 7 bankruptcy case are: a. Debts for most taxes; b. Debts incurred to pay nondischargeable taxes; c. Debts that are domestic support obligations; d. Debts for most student loans; e. Debts for most fines, penalties, forfeitures, or criminal restitution obligations; f. Debts for personal injuries or death caused by the debtor's operation of a motor vehicle, vessel, or aircraft while intoxicated; g. Some debts which were not properly listed by the debtor; h. Debts that the bankruptcy court specifically has decided or will decide in this bankruptcy case are not discharged; i. Debts for which the debtor has given up the discharge protections by signing a reaffirmation agreement in compliance with the Bankruptcy Code requirements for reaffirmation of debts; and j. Debts owed to certain pension, profit sharing, stock bonus, other retirement plans, or to the Thrift Savings Plan for federal employees for certain types of loans from these plans. This information is only a general summary of the bankruptcy discharge. There are exceptions to these general rules. Because the law is complicated, you may want to consult an attorney to determine the exact effect of the discharge in this case. Case 1:08-bk-03964-MDF Doc 22 Filed 05/18/09 Entered 05/18/09 01:01:09 Desc Ch 7 Discharge Page 2 of 2 CITIBANK (SOUTH DAKOTA), N.A. IN THE COURT OF COMMON PLEAS 701 East 60th Street N CUMBERLAND COUNTY, Sioux Falls, SD 57117 PENNSYLVANIA Plaintiff V. No. 08-3781 CIVIL TERM HERMEET SINGH CIVIL ACTION - LAW 4420 Gettysburg Road Apt. 3 ; Camp Hill, PA 17011-6612 Defendant CERTIFICATE OF SERVICE I, Elizabeth Rhoades, Legal Assistant, with the Law Offices of Leslie David Jacobson, hereby certify that I served a true and correct copy of the foregoing Discharge in Bankruptcy by depositing the same in the U.S. Mail, First Class, postage prepaid to the following: Mr. Yale D. Weinstein, Esquire Burton Neil & Associates, P.C. 1060 Andrew Drive, Suite 170 West Chester, PA 19380 Attorney for Plaintiff LAW OFFICES OF LESLIE D. JACOBSON Dated: (/Jq By: °C Elisabeth Rhoades FILLED orr" 'I7 FF J 'i . lr '1 GiY Z0 ?3 91UL - I PM 12: ' :" a .1t