Loading...
HomeMy WebLinkAbout08-4608Burton 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. SANDRA STROHL 113 S Broad Street Mechanicsburg PA 17055-3704 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 68 - gtPa8 0"" IV; I 14!_64 : 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-15554 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. 701 East 60th Street N Sioux Falls, SD 57117 Plaintiff V. SANDRA STROHL 113 S Broad Street Mechanicsburg PA 17055-3704 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. n p- yG o j Cc,?,ij 7.-e-- 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 Sandra Strohl, who resides at 113 S Broad Street, 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) Sears credit card with account number ending in 2763 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 Defendant 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 $4,033.90 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 $4,033.90, and the costs of this action. Burton Neil & AisocWs, P.C. By: Yale. Vh-irrs-tein,, Esquire A ornev for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt Sears Premier Card® SANDRA STROHL Account Number. 5049 9481 1838 2763 Page 1 of 1 Call us at i-800-917-7700 Go to www.searscard.oom Write to us at PO Box 6924 The Lakes, NV 88901-6924 Payment Due Date 03/31/08 Your Account Summary Billing Cycle Closing Date 03103/08 Amount Over Credit Line $203.90 Amount Past Due $737.45 Total Minimum Due $908.08 Did you know? There may be a quick (and simple) way to bring your account up to date. Call 1-866-518-9050 today. Previous Balance $3,904.27 Payments & Credits $0.00 Purchases & Debits $0.00 Other Charges $35.00 Total FINANCE CHARGES $94.63 Account Balance $4,033.90 Your Credit Summary Total Credit Line $3,830.00 Total Credit Available $0.00 You may be able to bring Even it you don't have a you may also make an your account current by refund coming, we have immediate payment by using your 2007 tas payment opliom that may calling our toll-free refund. And that's just meet your personal needs. number above. one possibility. We would be happy to work with you to find a solution. i FF I ? > t Activity Sale Date Post Date Description Amount 02129/08 02/29108 LATE PAYMENT FEE 35.00 YOUR ACCOUNT IS SERIOUSLY PAST DUE. AMOUNT PAST DUE IS SHOWN ABOVE. ARRANGEMENTS FOR FUTURE PAYMENTS SHOULD BE MADE IMMEDIATELY. Average Corresponding Periodic Rate Periodic Daily ANNUAL D--Day FINANCE Rates *Rate Varies Balance Balance PERCENTAGE RATE M=Month CHARGE SEARS REGULAR $4,033.90 $3,954.34 28.15%b* .0772%(D)* $94.63 EXTERNAL REGULAR $0.00 $0.00 28.15%b* .0772%(D)* $0.00 CASH ACCESS REGULAR $0.00 $0.00 28.15%* .0772%(D)* $0.00 Days in Billing Period: 31 Effective ANNUAL PERCENTAG E RATE: 28.15% Minimum FINANCE CHARGE: $0.00 Sears Premier Card® Account Number: 5049 9481 1838 2763 Payment Total Account Balance Due Date Minimum Due 90 03/31/08 $908.08 033 F $4 Amount Enclosed $ . , 0078994 EX 01 0 08063 1 TR6006 FXG 001 7 N 1111III II IIIIi II lII I1111III IIIIIIIIIIII II III II 111II VIII IIIIII Ills lI11II111I II IIIIIIIIIIIIIII IIIIII IIIIIIIII l11I1111II111I1I Make check payable to SANDRA STROHL SEARS CREDIT CARDS 113 S BROAD ST PO BOX 183081 MECHANICSBURG PA 17055-3704 COLUMBUS, OH 43218-3081 Please make address changes on reverse side. 200 50499481183827L3 0403390 0090808 0000000 of-AHIBIT . . N Verification I, Mena Ravnows 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. 1 Signature C-15554 Sandra Strohl Account number ending in 2763 1031 00 ? ? ?, .?? O v O D c? ^.,, , _ (,1 -. ._ .. i ?- ? 3 ? ?'"' _:? - l«- .. r..?,? -,.._ C,? ? T, p ter... R ?, ?±".??Y ?" SHERIFF'S RETURN - REGULAR CASE NO: 2008-04608 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITIBANK SOUTH DAKOTA NA VS STROHL SANDRA STEVE BENDER Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE STROHL SANDRA was served upon DEFENDANT the at 0009:10 HOURS, on the 9th day of August , 2008 at 113 S BROAD STREET MECHANICSBURG, PA 17055-3704 by handing to PATRICK STROHL HUSBAND OF DEFENDANT 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 10.00 Affidavit .00 Surcharge 10.00 g1631o ° 38.00 Sworn and Subscibed to before me this day So Answers: Igoe R. 'Thomas Kline 08/11/2008 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. SANDRA STROBL 113 S Broad Street Mechanicsburg PA 17055-3704 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-4608 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 $4,033.90 $4,033.90 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 AND DAMAGES ASSESSED AS ABOVE. NOTICE GIVEN UNDER PA.R.CIV.P. 236 s " P_ - 1 -0 0 k? Pr Prothonotary eil & A sKociates, P.C. By: Yale Wein , squire Aft ey or Plaintiff l0est NO. 89678 Andrew Drive, Suite 170 Chester, PA 19380 The law firm of Burton Neil & Associates is a debt collector. C-15554 C-15554 CITIBANK (SOUTH DAKOTA), N.A. IN THE COURT OF COMMON PLEAS Plaintiff V. SANDRA STROBL Defendant CUMBERLAND COUNTY, PENNSYLVANIA NO. 084608 CIVIL TERM CIVIL ACTION - LAW Notice of Intention to File Praecipe for Default Judgment TO: Sandra Strohl 113 S Broad Street Mechanicsburg PA 17055-3704 IMPORTANT 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 or 800-990-9108 DATE OF NOTICE: September 3, 2008 eil & Aksociafs. P.C. Yale D. WeiiAte?6 Attorney fo Plainti In making this communication, we advise our office is a debt collector. Identificaon No. 89678 1060 An rew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 G) .- ?1 pn Sts -? r rrl r-- r I t t 1 O d art ;.: r?a N --oct) C.L G J W .f K? . .c3 14M.. 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 Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. SANDRA STROHL NO. 08-4608 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 ZrrF AOQQ Prothonotary By._??l . le, ['M_x 161 Deputy U/4g 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.