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HomeMy WebLinkAbout09-2951 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 US BANK NATIONAL ASSOCIATION ND 9321 Olive Boulevard St. Louis, MO 63132 Plaintiff V. SUSAN G HENDERSON & CLIFTON H HENDERSON 16 Hazelwood Court, Mechanicsburg PA 17050-7963 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA . NO. 09 -,Z Q Jr / (2,16k Terw. 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 119151 w 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 US BANK NATIONAL ASSOCIATION ND 9321 Olive Boulevard St. Louis, MO 63132 Plaintiff V. SUSAN G HENDERSON & CLIFTON H HENDERSON 16 Hazelwood Court Mechanicsburg PA 17050-7963 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. C) 9- 2, 9 S 1 C'c d -r,., - Defendant : CIVIL ACTION - LAW Complaint 1. Plaintiff is US BANK NATIONAL ASSOCIATION ND, with place of business located at 9321 Olive Boulevard, St. Louis, Missouri. 2. Defendants are Susan G Henderson & Clifton H Henderson, who reside at 16 Hazelwood Court, 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 defendants by means of a(n) US Bank Creditline credit card with account number ending in 6946 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 defendants 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. r 7. Before plaintiff mailed Exhibit A, defendants had for many months made payments on account of the billing statement or retained the statement without payment. 8. Defendants' actions as set forth above constituted an account stated between parties for the sum of $23,068.42 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 defendants for the sum of $23,068.42, 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. C 9 us am o o A ?:1 -5786 lnyuiriea -888.852 BNK 57816 I'age 1 of rst Sement for NaotivlyCfrarn Jul. 25 2008 thI3 rough Aug. 26, 2008 SON SUSA NGHENDERSO and LI FT ONH ?IENDE Activity Summary Previous Balance ..................»............. $22,440.98 $0.00 Payments and Credits ........................ $0.00 Purchases, Advaulces & Other Debits $39.00 FINANCE CHARGES ».-.».».»»• $2?68?2 Nsw BaNlnce»....».»..........»............».. credit and payment information Credit Line ... ................»......................... *zv,uuu.w Available Credit ................... None Minimum Payment Due (Current Month)... $852.00 Minimum Payment Due Past Due) ........... J.32173. .00 TOW Now # bdinum Po;f nt Due---- PayrnerDuo Date set , .........».»......»....».».».. 2008 To awM tats ahaMd% Yourpayment must be p0eW by the duo date of 09i20,t)B. Paying the newbalanw *0 not pay off your account dyou wtM w payyoura0nountin AAA, phase oar Qoatomerservlw for the PaYVN amount Purchase* 08116 LATE FEE - PAYMENT DUE ON 08118 ............................. 39.00 Advorx os, De61ts Fbrarxe Charges 08126 ***FINANCE CHARGE"-INTEREST ................................. 588.44 BALANCE TRANWER 0 4,7r,:04 3 ADVANCES S $18,280,99 $0.00 0.079424% VARIABLE ;4,837.82 0.079424% VARIABLE $17,814.09 0.079424% VARIABLE 0 28.99% 4 28.89% $1M0 $466.90 28.99% 0.00'X' 28.99% 28.99% Gonrnued an Next Page C ban!i.. To change your addre" or for ouaWnwr Service please "N. 1-S W&52.6786 Every Nourl Every Dayl Please detach and eend coupon wfth cheoh payabh to. U.3. Bank 1143557885650469460005173000023068423 2827LRP T24 PO SUSAN G HENDERSON 116 HAZZEELWOOD CT HENDERSON MECHAN ICSSURG PA 17050-7963 'IIl'IIIl"11111i11?i1'?Il??ll"??I YourAcoount Number: oww Total New Balance: $23,068.42 Wl*nam Payment Due_ $5,173.00 Sep. 20, 2008 U.S. Bank P.O. Box 790408 St. Louis, MO 63179-0408 Idlltl'11'1?Ii??illloll Idl?irpylitllJill EXHIBt Y A-- MEEwwwMllw11Rww? August Statement for activtiy from Jul. 25 2008 througgh Aug. 26, 2008 Inquiries: 1-8884352-6786 SUSAN G HENDERSON and CLIFTON H ?IENDERSON Page 2 of 2 y ant, 800-6992566 IeYa talk about your situation. There be aw no to ad love this problem We ufor rge you ? m? Of i us our at past due amo must have t You are receiving aapaper statement because a special communication is required. Please refer to the enclosed inserts O 1, 2008 and your Annual Privacy Pledge. Your E-Statement for portantc changes to your account othe un neti statement. only As a remirnier, we May rge a fore '?grt fee of 3% on transactions th at occur in a countryer ( therrre nor transactions performnU S. Dollars or converted to U.S. DaNars prior to being Process by converted by Visa). Please refer to the "Using Your Card in a Foreign Country" aedbn of your Cardrnember Agreement. Each time you or a third party on your behalf, pa your bill by personal check, you authorize us to convert that payment into an elekxronic debit. If the check is processed efttronically, the checking account vA be debiled for the amount on the check and the detect wilt ar on your account statemen if you have any questions, please contact us at the Inquiries phone number on this statement. LBY Send irntuiries to: ®Send Payments to: By E-Mail: Hoort Evrtfy Days Customer Service U.B. Bank visit our wslxsffie: Voios: 1.888.852-5788 P.O. Box 6352 P.O. Box 790408 usbankoom TDD: 1-800-846-2580 Fargo, ND 58125-6352 8t. Louis, MO 83179.0408 Feud 1-866-588-7729 End of Statement Verification CYM-%Lk DUDA is (Name of authorized representative) Recovery Manager (Title or Position) for, US BANK NATIONAL ASSOCIATION ND, the within Plaintiff in this action, and that the statements of fact made in the foregoing Complaint are true ;and correct to the best of the undersigned verifier's 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 unworn falsification to authorities. Date: ` 6 d Name 119151 Susan G Henderson Account number ending in 6946 1326 0 2Q09 SAY I I FM 3: 08 CUI? u : )UNITY At T PENNSYLVANIA $18.60 pa amt ag,v 5µa1,8 Q:r# some 1498/ Sheriffs Office of Cumberland County R Thomas Kline 01 C u1fib't Try Edward L Schorpp Sheriff Solicitor Ronny R Anderson Jody S Smith Chief Deputy Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 05/12/2009 08:45 PM - Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on May 12, 2009 at 2000 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Susan G. Henderson, by making known unto herself personally, defendant at 16 Hazelwood Court Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time handing to her personally the said true and correct copy of the same. 05/12/2009 08:45 PM - Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on May 12, 2009 at 2000 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Clifton H. Henderson, by making known unto Susan Henderson, wife of defendant at 16 Hazelwood Court Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $52.10 May 13, 2009 2009-2951 US Bank National Association VS Susan G. Henderson SO ANSWERS, ??1eArt? *r- r R THOMAS KLINE, SHERIFF By Deputy Sheriff ,.` T- C 7 ..,G BY: David Reinherz, Esquire Attorney for Defendant 1218 Chestnut Street, Suite 405 Philadelphia, PA 19107 ID#82042 Telephone (215) 922-2055 Fax (215) 922-2778 US BANK NATIONAL ASSOCIATION ND : IN THE COURT OF COMMON PLEAS Plaintiff, vs. : COUNTY OF CUMBERLAND, PENNSYLVANIA SUSAN G. HENDERSON & CLIFTON H. HENDERSON Defendants DOCKET NO. 09-2951 CIVIL ACTION - LAW ANSWER TO ORIGINAL COMPLAINT Comes now SUSAN G. HENDERSON & CLIFTON H. HENDERSON, Defendants (hereinafter referred to as Defendant), and submits an Answer to the allegations contained in the Complaint filed against Defendant herein. FIRST DEFENSE Defendant would show that the Complaint fails to state a claim or cause of action against him upon which any relief can be granted. SECOND DEFENSE And now, answering the allegations of the Complaint filed against him, paragraph by paragraph, Defendant would show the following: 1. Defendant admits the allegations of Paragraph 1 of the Complaint that the Plaintiff is US BANK NATIONAL ASSOCIATION ND, with place of business located at 9321 Olive Boulevard, St. Louis, Missouri. 2. Defendant admits the allegations of Paragraph 2 of the Complaint that the Defendant is SUSAN G. HENDERSON & CLIFTON H. HENDERSON, who reside at 16 Hazelwood Court, Mechanicsburg, Cumberland County, Pennsylvania 3. Defendant is without sufficient knowledge or information at this time to admit or deny the allegations of Paragraph 3 through 8 of the Complaint and therefore denies same. DATED: WHEREFORE, now having fully answered said Complaint, Defendants request that said Complaint be dismissed with prejudice and that Defendants be awarded costs of this suit from Plaintiff. 6-1;! -7/o/ 9 David Reinherz, Esquire Attorney for Defendant 1218 Chestnut Street, Suite 405 Philadelphia, PA 19107 ID#82042 Telephone #922-2055 Page 2 of 3 CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing Defendant's Answer to Original Complaint has been properly delivered on this dtday of May, 2009 to: Neil Serker, Esquire ID#203465 Burton Neil & Associates, P.C. 1060 Andrew Drive, Suite 170 West Chester, PA 19380 David Reinher2, Esquire Attorney for Defendant Page 3 of 3 05/28/2009 14:43 PAR 17177957594 STAPLES Q002 MAY-28-2009 11:03AM LAW OFFICES OF VICTOR W. LUKE No. 0519 P. 2 • r US BANK NATIONAL ASSOCXATION ND Plsiattff, ' Vs. SUSAN 0. HENDERSON & CLIFTON H. IENDBRSON Defendants. ' IN THE COURT OF COMMON PLEAS CUMB]DU AND COUNTY, PBNNMVANIA DOCKET No. 09-2951 CIVIL ACTION - LAW VERIFICATION SUSAN G. HENDEMON & CLIFTON A. HENDFRSON, being fat duly swan according to lxw, deposes and ftes that they have reed the farsaoing, Aaswar to Qftb l Complo at, and that the Amens are true to dw but of their lmowledge SWORN TO EEF01M ME sad abseribod In mq preamm tbia?day of 5009. SEAL, "ARM 9f ramILVA" 1,111ft llolo poft T 0. UN160,Ps0"WftAWN a?atHdWft My Cowndedion Expfree b Day Year 1 T!?- C`A Burton Neil & Associates, P.C. By: Burton Neil, Esquire ID. NO. 11348 1060 Andrew Drive, Suite 170 West Chester, PA 19380 Telephone: 610-696-2120 Attorney for Plaintiff US BANK NATIONAL ASSOCIATION ND ar , ~r_- : , ~~.: ~ , r.Qlfl ~EE3 i 9 Pig ~ ~ ~€~ IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v, NO. 09-2951-CIVIL TERM SUSAN G HENDERSON and CLIFTON H. HENDERSON Defendant :CIVIL ACTION -LAW Praecipe for Entry of Judgment on Stipulation To the Prothonotary: Pursuant to the authority set forth in the attached agreement between the plaintiff and defendant, enter judgment on behalf of the plaintiff, US BANK NATIONAL ASSOCIATION, and against the defendant, SUSAN G HENDERSON and assess damages in the sum of $23,199.02. & Associates, P.C. Murton Neil, ] Attorneys for And now, this lq'~' FGday of , 201 D ,judgment is entered on behalf of tl~ plaintiff, US BANK NATIONAL ASSOCIATION and against the defendant, SUSAN G HENDERSON, in th sum of $23,199.02. Prothonotary of CUMBERLAND County C~ The law firm of Burton Neil & Associates is a debt collector. ~I~.OO Pp AT~~ C1C.~ 7'00341 a~ a3~ X03 ~~~ ~1~~ ', ~ ' From 2104852143 ,Pale: 515 ~ Date: 10/9/2009 1:02:25 PM Burton Neil & Associates, P.C. ay: Robert J. Kane, Esquire ID. N0.209794 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff US BANK NATIONAL ASSOCIATION Nl~ PlaintifF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSY"L'VANIA v. SUSAN G. HENDERSON and CLIFTON H. HENDERSON Defendant N0.09-2951-CIVIL TERM CIVIL ACTION -LAW Praecipe for Entry of Judgment Upon Stipulation of the Parties To the Prothonotary: Enter judgment on behalf of plaintiff US Bank National Association ND and against defendants Susan G. Henderson and Clifton H. Henderson in the sum of $23,068.42 plus costs of $130.60 pursuant to the stipulation of the parties attached hereto. Burton Neil & Associates, P.C. Robert J. Kane, Esquire --- Attorney for Plaintiff US Bank National Association ND Defendant /~~ - Susan Cr. Hende~rs~ ue t Cliff n H. Henderson In making this communication, we advise this arm is a debt collector. From: 2104852143 M ,Pa~e:r515 ~ ~Date:,10191Z0091:02:25 PM •rr .~ /• LV V I I • V L"" ~ r ~ ~ • .ri VVJI ~ ~ J Hul~ton Neil 8t Aasocietea, P.C. >3Y: 3~,ir~~Tt~(L . ;squiue ID. N0. - I$~-IS + 1060 Andrew Drive, Suite 170 West Chester, PA 19380 b10-b46-2120 AttorAay for Plsimtiiff US BANK NATIONAL ASSOCIATION' ND plaintiff 1N THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. SUSAN (1. HENDSRSON and CL1P'x'ON H. ~IIr1VD8RSON Defendant N0.09-2951-CIVIL TERM CML ACTION -LAW Praecipe for Entry of Jad~nent Upon Sttpulatian of the Parties To the Prothonotary: 8nter judgment on behalf of plaimdff US Bank National Association ND end against defendants Susan 4. Hendeuson and Clifton H. Henderson in the sum of S23,068.42 plus coats of 5130.b0 pursuant to the atipulatioa of the parties attached hereto. Burt ociates, p.C. $l~~Tf~l1.)eiL ~, Bsquire Attorney for Plaintiff US Bank National Association ND Defendant , Susan Ci. Hen~~ / /. V.~p H. Henderson In ,raking thls oommunicetton, we e~dvise this tixaa~ Is a debt collector. From: 2104852143 Pale: 2/5 Date: 10!9!2009 1:02:24 PM // Burton Neil & Associates, P.C. By: Robert J. Kane, Esquire ID, N0.209794 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff US BANK NATIONAL ASSOCIATION ND Plaintiff 1N THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANYA v. SUSAN G. HENDERSON aad CLIFTON H. HENDERSON Defendant N0.09-2951-CIVIL TERM C1VIL ACTION -LAW Settlement Agreement wlth Stipulation for Entry of Judgment This Settlement Agreement is made by and between plaintiff US Bank National Association ND (hereinafter referred to as "US Bank") by and through its respective duly authorized and appointed agent, Burton Neil & Associates, P.C., and Defendants Susan G. Henderson and Clifton H. Henderson (hereinafter referred to as "Hendersons"). WITNESSETH WHEREAS, US bank filed a civil action against Hendersons, seeking to recover from them the total principal sum of $23,068.42 plus court costs in the amount of $130.60 for failure to pay their credit card bearing account number 4355758565046946, for a total of $23,199.02 {hereakfter the "balance") which plaintiff issued to them; WHEREAS, Hendersons aclu~owledge their obligation to pay plaintiff the balance but are not able to pay the same in full immediately; aad WHEREAS, the parties hereto desire to resolve the Litigation without further legal proceedings and in the manner set forth hereinafter; ~~ ~ From 2104852143 Pale: 315 ~ Date: 1019!2009 1:02:25 PM NOW, THEREFORE, in consideration ofthe mutual covenants and conditions herein contained, the parties hereto, expressly intending to be legally bound hereby, agree as follows: 1. It is agreed Hendersons shall be permitted to pay, ar~d US Bank will accept, in full and complete settlement of the aforemenfiioned account, the sum of $16,100.00 as follows: (a} An initial payment of $11,000.00 on or before October 30, 2009. (b) 12 monthly payments thereafter of $425.00 due by the 30th of each month beginning vn November 30, 2009 and continuing until the settlement is paid. All payments are to be sent to US Bank's counsel, Burton Neil & Associates, P.C. at 1060 Andrew Drive, Suite 170, Weat Chester, PA 19380. 2. To secure Hendersons's payment, it is further understood and agreed that US Bank shall be permitted to enter judgment against Hendersons under this agreement for the sum of $23,199.02. Interest will accrue at 6% per annum from the date of the judgment on the declining balance, 3. "Default" as defined herein shall mean any of the following: Hendersons's failure to make a required payment due hereunder by the due date or the dishonor of any check tendered under this agreement for any reason by any bank or other financial institution. 4. Hendersons shall have agrace /cure period of seven (7) days with respect to each payment from the date of notice as set forth below. lz~ tJ~e event of default as defined in Paragraph 3 above, and before US Bank may file execution, it shall first be required to give written notice of default and opportunity to cure said default by first class mail to Hendersons e/o Michael Bell, Esquire, at his address of record. The notice shall indicate that a default had taken place and give Hendersons a period of seven (7) days from the date of the notice to cure the default by making the required payment. If Hendersons do nvt cure the default by the end of the seven day cure period, US Bank shall thereafter be free to file execution on the judgment provided for under this Agreement, less credit for any payments . ~ ~ ~ ` From: 2104852143 N Pale: 415 ~ Date: 10/9!2009 1:02:25 PM ~ ~ , , made an account, and to employ any remedies available to it hereunder and at law to enforce and collect the j udgment. 5. So long as Hendersons pay in accord with this Agreement, US Bank will not file execution on the judgment to be entered under dais Agreement. b. Upozt receipt and clearance of the final installment of the balance due in accordance with the terms of this Agreement and provided Hendersons have not defaulted, US Bank will file a Fraecipe to Satisfy Judgment and provide a copy to Hendersoats. 7. This Settlement Aga~eement and Stipulation for Entry of Judgneatt is, made under and is to be governed by the laws of the Commonwealth of Perarasylvania. 8. For the purposes of this stipulation and due to the exigencies of time for its filing, a facsimile signature shall have the same force and effect as azt original signature. IN WITNESS WHFREOI~, INTENDING TO BE LEGALLY BQUND HEREBY, the parties hereto have entered into this Settlement Agreement on the date first appearing below. IY ~ ~ ~~v Date ~~-,~~~-~r~l~ Date Date Burton Nei~Ass~ciates, P.C. By: Robert J. Kane, Esqu c.- ~ ~ Attorney for Plaintiff 10b0 Andrew Drive, Suite 170 V~~est ester, PA 193$0 c~ (610 6 62120 _ ,~ / I~. Zn axaakla~ this communication, we advise our officc is a debt collector. Burton Neil & Associates, P.C. By: Burton Neil, Esquire ID. N0.209794 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 ATTORNEY FOR: Plaintiff US BANK NATIONAL ASSOCIATION ND IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 09-2951-CML TERM SUSAN G HENDERSON and CLIFTON H. HENDERSON Defendant :CIVIL ACTION -LAW Rule of Civil Procedure N0.236 (Revised) Notice is given that a JUDGMENT in the above captioned matter has been entered against you on ~1~4 /to Prothonotary By: ~ ~ If you have any questions concerning the above, please contact: Burton Neil, 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. Burton Neil & Associates, P.C. By: Burton Neil, Esquire ID. N0.209794 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff US BANK NATIONAL ASSOCIATION ND 9321 Olive Boulevard, St. Louis, MO 63132 Plaintiff v. SUSAN G HENDERSON and CLIFTON H. HENDERSON 16 Hazelwood Court Mechanicsburg PA 17050-7963 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COiJNTY, PENNSYLVANIA NO. 09-2951-CNIL TERM CNIL ACTION -LAW Certification of Address Understanding that false statements herein are subject to penalty under 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities, I verify that the above are the precise last- known addresses of the judgment creditor and debtor. Neil & Burton Neil, Attorney for P.C. The law firm of Burton Neil & Associates is a debt collector. v~ Burton Neil & Associates, P.C. By: Burton Neil, Esquire ID. N0.209794 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff US BANK NATIONAL ASSOCIATION ND Plaintiff v. SUSAN G HENDERSON and CLIFTON H. HENDERSON Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-2951-CIVIL TERM CNIL ACTION -LAW Affidavit of Non-Military Understanding that false statements herein are subject to penalty under 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities, I verify that 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. Burto eil & sociat By: urton eil, Attorney for P.C. The law firm of Burton Neil & Associates is a debt collector.