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Home My WebLink About09-2564 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 FIA CARD SERVICES, N.A. f/k/a BANK OF AMERICA, N.A. (USA) 4161 Piedmont Parkway Greensboro, NC 27410 Plaintiff V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA KEVIN W LEWELLEN : NO. 64 - ;Ls&q 0, 3780 Spring Road Apt 7A, Carlisle PA 17013 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 116262 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 FIA CARD SERVICES, N.A. f/k/a BANK OF AMERICA, N.A. (USA) 4161 Piedmont Parkway Greensboro, NC 27410 IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. O y _5'G y CIVIL ACTION - LAW Complaint 1. The plaintiff is FIA CARD SERVICES, N.A. f/k/a BANK OF AMERICA, N.A. KEVIN W LEWELLEN 3780 Spring Road Apt 7A, Carlisle PA 17013 Defendant (USA), a national banking association with place of business located at 4161 Piedmont Parkway, Greensboro, NC. 2. The defendant is Kevin W Lewellen, who resides at 3780 Spring Road Apt 7A, Carlisle, Cumberland County, Pennsylvania. 3. Plaintiff furnished consumer credit to defendant by means of a credit card with account number ending in 1687, which was subsequently changed to account number ending in 2381. 4 Defendant accepted the credit card account by making purchases, balance transfers and/or cash advances. 5. Monthly statements were sent to defendant each month which detailed the charges and credits made to the credit card account for the prior month. 6. The balance due on the credit card account is $11,687.61. 7. Defendant did not pay the balance due on the credit card account in full upon receipt of the monthly billing statements and also did not make the required minimum monthly payment set forth in the monthly billing statement. As such, defendant is in default on the credit card account. 8. Although demand has been made by plaintiff upon defendant to pay the sum of $11,687.61, defendant failed and refused to pay all or any part thereof. Wherefore, plaintiff demands judgment against defendant in the sum of $11,687.61 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. 0 Verification 6-9-- coza is for FIA CARD SERVICES, N.A. fWa BANK OF AMERICA, N.A. (USA), the within plaintiff in this action. He/she verifies that the statements of fact made i the foregoing pleading are true and correct to the best of his/her knowledge and belief. The undersigned understands that the statements made herein are subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to the authorities. Date: ?, , z,? ?? axe 4 116262 Kevin W Lewellen "A/ n ame 20$09 AFR 23 Ph .+'I8.5o PD Al" U`M 15-6,7,901 P-0 Ou4t 1 Sheriffs Office of Cumberland County R Thomas Kline r umaer ?A Lu••?4 ySolicitor Sheri Ronny R Anderson Jody S Smith Chief Deputy OFFICE `aF THE SHERIFF Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 04/30/2009 10:22 AM - Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on April 30, 2009 at 1022 hours, he served a true copy of the within Complaint and Notice upon the within named defendant, to wit: Kevin W. Lewellen by making known unto Kevin W. Lewellen personally at 3780 Spring Road, Apt. 7A, Carlisle, Cumberland County, Pennsylvania, 17013, its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $34.30 SO ANSWERS, -?.? ERIFF April 30, 2009 R THXSK SH 2009-2564 FIA Card Services v Kevin Lewellen ? rv CZ3 t 7-7 rn j f-0 `Ct? -Za c FIA CARD SERVICES, N.A. f/k/a BANK OF AMERICA, N.A. (USA) 4161 Piedmont Parkway, Greensboro NC 27410: Plaintiff v. KEVIN W LEWELLEN 3780 Spring Road Apt 7A Carlisle PA 17013 Defendant To the Prothonotary: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL,~VANIA N0.09-2564 CV CIVIL ACTION -LAW Praecipe for Default Judgment Please enter judgment by default for want of an answer in the above case in vor of the plaintiff and against the defendant, and assess damages as follows: Principal: $11,687.61 TOTAL $11,687.61 j 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 ar~d creditor. 2. The annexed notice of intention to file this praecipe was mailed to all p rties against whom judgment is to be entered and to their record attorneys, if any, after the default ccurred, 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 o 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 ro Proth Burton Neil & By: Neil Sarker, Est Attorney for Pla I.D. NO. 20346` 1060 Andrew D~ West Chester, P P.C. ive, Suite 170 ~ 19380 The law firm of Burton Neil & Associates is a debt collector. FIA CARD SERVICES, N.A. flk/a IN THE COURT OF COMMON PLEAS BANK OF AMERICA, N.A. (USA) Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. N0.09-2564 CV KEVIN W LEWELLEN Defendant : CIV1L ACTION -LAW Notice of Intention to Fite Praecipe for Default Judgment I, TO: Kevin W Lewellen 3780 Spring Road Apt 7A Carlisle PA 17013 116262 IMPORTANT NOTICE You are in default because you have failed to enter a written appearance personally or by att rney 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 ay lose your property or other important rights. You should take this notice to your lawyer at once. If you do not ave 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 infornnation 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. 'i ~I LAWYER REFERENCE AND INFORMATION SERVICE Cumberland County Bar Assoc. 32 South Bedford Street ~ Carlisle, PA 17013 Telephone No. 717-249-31b6 or 800-990-9108 DATE OF NOTICE: May 26, 2009 Burton Neil & Associates, F.C. In making this communication, we advise our office is a debt collector. By: f V Neil Sarker, Esquire Attorney for Plaintiff Identification No. 203465 l Ob0 Andrew Drive, Suite 170 West Chester, PA 19380 (610)b96-2120 fi9LEI~-t;r~=i::E flF THr p;~~nY~~^ntir,~'?Y Z0~9 JUG C 1 Pr`s I ~ ~i3 r'ri ~y; ~~`~ E..UriNsA #1~}.0o Pp ATM ~~r 5~4y3 ~ ~~~~ac~ 1lnkca. ~~~ Burton Neil & Associates, P.C. By: Neil Sarker, Esquire ID. N0.203465 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff FIA CARD SERVICES, N.A. f/k/a BANK OF AMERICA (USA) IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSY VANIA v. N0.09-2564 CV KEVIN W LEWELLEN Defendant :CIVIL ACTION -LAW Rule of Civil Procedure N0.236 (Revised) III Notice is given that a JUDGMENT in the above captioned matter has bee entered against you on (o~ ~09 rothon6~ 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.