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HomeMy WebLinkAbout09-2372Burton Neil & Associates, P.C. By: Neil Sarker, Esquire ID. NO. 203465 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 WILLIAM L DERRICK : NO. (q - oZ37,2 Cj V it (t%M 3425 Market Street, Camp Hill Pa 170114428 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-23043 A Burton Neil & Associates, P.C. By: Neil Sarker, Esquire ID. NO. 203465 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. WILLIAM L DERRICK 3425 Market Street, Camp Hill Pa 17011-4428 Defendant CIVIL ACTION - LAW Complaint 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 William L Derrick, who resides at 3425 Market Street, 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 credit card with account number ending in 7493 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 $2,570.17 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 $2,570.17, and the costs of this action. Burton Neil & Associates, P.C. By: Neil Sarker, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. ? r z O ; f• N ? w rO V_ > u i • l u m • V) N N J u 4 R ? •oQ C_ m .0 01 E 10 k. N ¢ v >t-- K X oa ?ooLn S ? do V en ui M v d 0 O r N O C c o N E ' Y M 01 U ` Y i ? EW in S r J C ? c • • ? V N 7 Q V 0. N J • a to i z2 1 .m W uW iu za Wx +u EY e? nV ..w iywy C' G, i1a l $ C • s`m I ? r I .d r o 1 ti i I N C I N i D ? •Q F N 1 to 0 0 O O O• cn N 11.1 10 Q N ? E E h Q • l0- 0•', W «W zW< zua W d M oa < z a O d aUM 1'n d d? c m? AW m O O O O N O O O M Q O O D >y N Y ? - - d C M C SON ?3 W p mr?o N- C c y° 3 a C o ` c •- u u c o a? sa U3 d V 00 ? E O 100 L ? ? a c A o? d? i eE 0 - E co m ? d a V N L ? Y + a C d _ d d U • i1 - 1 n7 a x " O g Y c E E • N w r a 0> a u u 3 c da Er O m 0 W > d C d>'N NO N ° w o . r. o L ' fu a Q l- W > "D > wN IS: o c m < u < > ocn ?. date paid arn aud,aid _-- -- U ,, Detagl and follow payment IMtrYCtNna on rwano F MM..h..*payabkto:C.1t1 Cads Total New Balance: $2rs70.n Minimum Amount D : $2r570.1n Payment Due Date: 02/12/2009 000000 PW 32 A 0 WILLIAM L DERRICK 3425 MARKET ST CAMP HILL PA17011-4 8 r. 7493 Amount Enclosed: Payment must be ncaNatl by 5:00 PM local YmM on the payment We data. CITI CARDS P.O. BOX 182564 v COLUMBUS, OH43218-2564 EXHIBIT E 0 u d v c e r ° c .C > y ° q OOO, a J ? 00, 3$ x?" u OCp 700 V S.1 Vmin LO ? O of m oCO a T C p N ? d w O V) w 0 ? 00E> ?a 3 O N O" NEo arY E m S M -0 Y c'C o C. a n To _Ma o?Y c ? O N _ y - f0 ? V rn N N N N c O m N E as o v °-cE E •Ip T!p N ? y .Q UU = N Cl Verification Shauna M4ughton 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. C-23043 William L Derrick Account number ending in 7493 1000 ,r aax.,- Signature 0 - JOTARY 20Q9 Y; ! 5 Ali 1 [ Sg 4%. 5o Pb AT *'f Cy,o 635N I ?a3?ss Sheriffs Office of Cumberland County R Thomas Kline qtr of Climb" rt h Edward L Schorpp Sheriff Solicitor Ronny R Anderson Jody S Smith Chief Deputy OFFICE OF r"- SHERIFF Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 04/18/2009 09:18 AM - Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on April 18, 2009 at 0918 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: William L. Derrick, by making known unto Dawn Pynes, adult in charge, at 3425 Market Street, Camp Hill, Cumberland County, Pennsylvania, 17011, its contents and at the same time handing tc her personally the said true and correct copy of the same. SHERIFF COST: $49.60 April 21, 2009 SO ANSWERS, R TH0 AS K SHERIFF Docket No. 2009-2372 Citibank v William Derrick RLEG-OFFiCE 2009 APR 27 AN H: 306 CITIBANK (SOUTH DAKOTA), N.A. 701 East 60th Street N, Sioux Falls, SD 57117 Plaintiff V. WILLIAM L DERRICK 3425 Market Street Camp Hill Pa 1701 14428 Defendant 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 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 09-2372 CV CIVIL ACTION - LAW $2,570.17 $2,570.17 Understanding that false statements herein made are subject to penalty under 18 Pa. C.S. § 4904 relating to unsworn 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. NO TIC GIVEN UN R PA.R.CIV.P. 236 Pr Prothono py?/ Burton Neil & Associates, P.C. By: Neil Sarker, Esquire Attorney for Plaintiff I.D. NO. 203465 1060 Andrew Drive, Suite 170 West Chester, PA 19380 The law firm of Burton Neil & Associates is a debt collector. C-23043 C-23043 CITIBANK (SOUTH DAKOTA), N.A. Plaintiff V. WILLIAM L DERRICK Defendant : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 09-2372 CV : CIVIL ACTION - LAW Notice of Intention to File Preeeipe for Default Judgment TO: William L Derrick 3425 Market Street Camp Hill Pa. 170114428 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: May 12, 2009 In making this communication, we advise our office is a debt collector. Burton Neil & Associates, P.C. By: Neil Sarker, Esquire Attorney for Plaintiff' Identification No. 203465 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 P. A? ?? ? (4,l3a cw ?,,?Ra.3 fJo??, Burton Neil & Associates, P.C. By: Neil Sarker, Esquire ID. NO. 203465 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. : NO. 09-2372 CV WILLIAM L DERRICK 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 6l,./ 9 grothonot By: Deputy If you have any questions concerning the above, please contact: Neil Sarker, 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.