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HomeMy WebLinkAbout09-1071Burton Neil & Associates, P.C. By. Derek C. Blacker, 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 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. MARLIN L COMP NO. t+PrM 1021 Teakwood Lane, Enola PA 17025-2047 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 fiirther 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. YOIJ SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAW A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FOR'T'H 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-14702 t 4 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. Oq- MARLIN L COMP 1011 Teakwood Lane, Enola PA 17025-2047 Defendant CIVIL ACTION - LAW Complaint i. Plaintiff is Citibank (South Dakota), N.A., with place of business located at 701 East 60th Strut North, Sioux Falls, South Dakota. 2. Defendant is Marlin L Comp, who resides at 1021 Teakwood Lane, F,nola, Cumberiand 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 4577 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. 1 8. Defendant's actions as set forth above constituted an account stated between parties for the sum of $3,616.50 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 $3,616.50, and the costs of this action. BurtodN41 kfissociates, P.C. By: V Ve . lasker, Esquire Attorney f r Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. Can us at 1-800-917-7700 Sears Card® Go to www.eearscard.com Write to us at PO Box 0924 The Lakes, NV 88901-6924 MARLIN L COMP Pa mant Due Date Account Number: 4577 Page 1 of 1 02/11/08 Your Account Summary Billing Cycle Closing Date 01/22/08 Amount Over Credit Line $239.30 Amount Past Due $1 Total Minimum Due $1,294.37 Previous Balance $3,678.78 Payments & Credits $62.28 Purchases & Debits $0.00 Other Charges Total FINANCE CHARGES $0.00 6 Account Balance .50 $3,6 Your Credit Summary Total Credit Line $3,080.00 Total Credit Available $0.00 Amount Activity Sele Date Poet Date Description 12/22/07 12/22/07 ACCOUNTCARE FEE OR CREDIT INS. ADJ. -62.28 Average Corresponding Periodic Rate Periodic FINANCE Deily ANNUAL PERCENTAGE RATE D=Dey M=Month CHARGE Rates `Rate Varies Balance Balance SEARS 50 616 $3 $0.00 29.40% .0806%(D)* $0.00 REGULAR . , EXTERNAL 00 $0 $0.00 29.40%* .0806%(D)* $0.00 REGULAR . CASH ACCESS 00 $0 $0.00 29.40%* .0806%(D)* $0.00 REGULAR . tive ANNUAL PERCENTAGE RATE: 29.40% Minimum FINANCE CHARGE: $0.00 Eff Days in Billing Period: 32 ec Sears Card® Account Number: 4577 Payment Total Amount Enclosed Account Balance Due Date Minimum Due $02!11/08 $1,294.37 0000000 ZX 14 08022 1 TR8006 FXG 001 7 W IIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIII MARLIN L COMP 1021 TEAKWOOD LN ENOLA PA 17025-2047 Please make address changes on reverse side. III IIIIIIIIII IIIIIIIIIIIIIIIIIIII III IIIIIIIIIIIIIIIIIII111 Make check payable to SEARS CREDIT CARDS PO BOX 183081 COLUMBUS, OH 43218-3081 200 361650 0129437 0000000 1412 DCHtB1T • Verification Tiena Reynolds am an employee of Citicorp Credit Services, 1, 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 C-14702 Marlin L Comp Account number ending in 4577 1031 +o s 06 6 r Uat Pn 00 ? a r --.3 r -3 ?a t_ _-T1 T 0 SHERIFF'S RETURN - REGULAR CASE NO: 2009-01071 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITIBANK (SOUTH DAKOTA) N A VS COMP MARLIN L STEVE BENDER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon COMP MARLIN L the DEFENDANT , at 1825:00 HOURS, on the 25th day of February , 2009 at 1021 TEAKWOOD LANE ENOLA, PA 17025-2047 by handing to MARLIN COMP 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 Sworn and Subscibed to before me this of So Answers: 18.00 13 . 5 0 .? . 00 10.00 R. Thomas Kline .00 41.50 02/26/2009 BURTON NEIL & ASSOC. By: day Deputy S eriff A. D. j1j fa,7 .. 7 t,?,: fi? v CITIBANK (SOUTH DAKOTA), N.A. 701 East 60th Street N, Sioux Falls, SD 57117 Plaintiff V. MARLIN L COMP 1021 Teakwood Lane Enola PA 17025-2047 Defendant IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 09-1071 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 $3,616.50 $3,616.50 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. NOTI GIVEN ER PA.R.CIV.P. 236 Pro rothonot The law firm of Burton Neil & Associates is a debt collector. Burto ei ssociates, P.C. By: Dere e Blasker, Esquire Attorney for Plaintiff I.D. NO. 202150 1060 Andrew Drive, Suite 170 West Chester, PA 19380 C-14702 C-14702 CITIBANK (SOUTH DAKOTA), N.A. Plaintiff V. MARLIN L COMP Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-1071 CIVIL TERM : CIVIL ACTION - LAW Notice of Intention to File Praecipe for Default Judgment TO: Marlin L Comp . 1021 Teakwood Lane Enola PA 17025-2047 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: March 19, 2009 In making this communication, we advise our office is a debt collector. Burton By: Derek C. Blas re uire Attorney for Plaintiff Identification No. 202150 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 ..1" of aaon"S'nav 2009 APR -6 PM 2* 36 t:x t WUNW PE*WLVANIA +14.00 Qo -w 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), IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. MARLIN L COMP : NO. 09-1071 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 N?G ?6 rothono 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.