HomeMy WebLinkAbout08-4011
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
NAJWA S KASSEM : NO. 46 11 C
6352 Mercury Drive, Mechanicsburg PA 17050
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-16006
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
701 East 60th Street N
Sioux Falls, SD 57117
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 1 fA / C out
cf rk
NAJWA S KASSEM C, 7
6352 Mercury Drive, Mechanicsburg PA 17050
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 Najwa S Kassem, who resides at 6352 Mercury 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(n) AT&T
Universal credit card with account number ending in 0985 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
8. Defendant's actions as set forth above constituted an account stated between parties
for the sum of $4,595.98 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 $4,595.98, and
the costs of this action.
Attorney
The law firm of Burton Neil & Associates, P.C. is a debt collector.
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date paid amoun t paid - (beck d Detach and follow payment Instructions on revers.
1A.k. ch.ckpaybl.to:AT&T Universal Card
Total New Balance:
$4,595.98
Minimum Amount Due:
$4,595.98
Payment Due Date:
03/28/2008
000000 MC 32 A 0
NAJWA S KASSEM
6352 MERCURY DR
MECHANICSBURG PA 17050-5268
Account Number:
985
Amount Enclosed:
Payment must be ncale.d by Loo PM
local time on the payment due dato.
AT&T UNIVERSAL CARD
P.O. BOX 182564
COLUMBUS, OH 43218-2564
J i • ?
Verification
Shauna Houghton
1, 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
Shauna Houghton
Najwa S Kassem
0985
?Y
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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.
V.
Plaintiff
NAJWA S KASSEM
6352 Mercury Drive
Mechanicsburg PA 17050-5268
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 08-4011 CIVIL TERM
CIVIL ACTION - LAW
Praecipe to Reinstate
To the Prothonotary:
Please reinstate the Complaint.
B
B,
The law firm of Burton Neil & Associates is a debt collector.
C-16006
Attorney for Plaintiff
? o
Cri
Ti
SHERIFF'S RETURN - NOT FOUND
CASE NO: 2008-04011 P
COMMONTWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
CITIBANK (SOUTH DAKOTA) N A
VS
KASSEM NAJWA S
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
KASSEM NAJWA S but was
unable to locate Him in his bailiwick
COMPLAINT & NOTICE ,
He therefore returns the
NOT FOUND , as to
the within named DEFENDANT , KASSEM NAJWA S
6352 MERCURY DRIVE
MECHANICSBURG, PA 17050
DESPITE NUMEROUS ATTEMPTS, PAPER EXPIRED BEFORE SERVICE WAS MADE.
Sheriff's Costs:
Docketing 18.00
Service 24.00
Affidavit ' 4 .00
Surcharge sell 10.00
Not Found 5.00
57.00
So answers:
' R. Thomas Kline
Sheriff of Cumberland County
BURTON NEIL & ASSOCIATES
08/06/2008
Sworn and Subscribed to before
me this day of
A. D.
SHERIFF'S RETURN - NOT FOUND
CASE NO: 2008-04011 P
COMMONTWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
CITIBANK (SOUTH DAKOTA) N A
VS
KASSEM NAJWA S
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
KASSEM NAJWA S but was
unable to locate Him in his bailiwick. He therefore returns the
the within named DEFENDANT , KASSEM NAJWA S
COMPLAINT & NOTICE
,
NOT FOUND , as to
6352 MERCURY DRIVE
MECHANICSBURG, PA 17050
LIGHTS WERE ON BUT NO ONE WOULD ANSWER DOOR. 8 ATTEMPTS AT
SERVICE MADE.
Sheriff's Costs:
Docketing 18.00
Service 24.00
Affidavit .00
Surcharge 10.00
Not Found 5.00
So answers:
R. ThoMks Kline
Sheriff of Cumberland County
BURTON NEIL & ASSOCIATES
09/24/2008
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.
IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 08-4011 CIVIL TERM
NAJWA S KASSEM
Defendant
CIVIL ACTION - LAW
Praecipe to Discontinue
To the Prothonotary:
Kindly discontinue the above-captioned action withqv4t prejudice.
B
By:
it sociates, P.C.
e asker, Esquire
Attorney for Plaintiff
The law firm of Burton Neil & Associates is a debt collector.
C-16006
C) ?
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