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HomeMy WebLinkAbout09-4219Burton 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. EUGENE CAMPBELL 5257 Meadowbrook Drive, Mechanicsburg PA 17050-6833 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. oq - ya19 l:?vi I 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-21587 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. IN THE COURT OF COMMON PLEAS 701 East 60th Street N Sioux Falls, SD 57117 Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. EUGENE CAMPBELL 5257 Meadowbrook Drive, Mechanicsburg PA 17050-6833 NO. Defendant 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 Eugene Campbell, who resides at 5257 Meadowbrook Drive, 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 9008 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 $6,533.05 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 $6,533.05, and the costs of this action. NtiftAssociates. P.C. By: Blasker, Esquire for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. seem w" PLUS' EUGENE CAMPSE Account NumberpOS Pape 1 of 2 YOW Account Blltlng Cycle Closing Date 01/28109 Amount Over Credit Una $1,033.05 Amount Past Due $1,563.68 Total Minimum Due $1,661.68 Previous Balance $6,533.05 Payments & Credits A Purchases DeNts $0.00 $0.00 ?t?g eeaa TotalrFlNi ? WE CHARGES $0.00 Account Balance $6,533.05 Your Croon Sunwnary Toted Credit Una $5,500.00 Total Credit Available $0.00 YOUR ACCOUNT IS SERIOUSLY PAST DUE. AMOUNT PAST DUE IS SHOWN ABOVE. ARRANGEMENTS FOR FUTURE PAYMENTS SHOULD BE MADE IMMEDIATELY. Yll Aver"o Con"pon*q Pwiodb Rate Perlodio Rubs 'Rate Virivs Bdmoe B Dolly ANNUAL a TAGE RATE M Dq FINANCE SEARS REGULAR $6,533.05 $0.00 25.18%' .089MD)• $0.00 Days in Billing Period: 30 Effective ANNUAL PERCENTAGE RATE: NIA Mk*nwn FINANCE CHARGE: $0.00 Cwtimsmbsr News The Sale Date is the Transaction Date. Phase follow payment Instrut tlons on reverse side. Pay m- must be received by 5.00 p.m. local time at Payment Due Da/s. sewschowg" Account Nun*er 900ti Account Bain. Dw Dace Mk TOW Ow Amount Ea fond 58,533.05 02!17/08 $1,681.68 is 0000000 III to oI So 1 tirte001 Ise 001 7 or loll 111111111111111111111111111111 lot 1111111 folio 1111111111121 EUGENE CAMPBELL 5257 MEADOWBROOK DR MECHANICSBURG PA 17050-6833 Rosse make address 0wr4ps on reverse side. 1111,$nllnr111+nNlnlr1111r111ulnluulllrrln1111urlll Make check pyade to SEARS CREDIT CARDS PO BOX 183081 COLUMBUS, OH 43218-3081 Cell us at 1-100.017-7700 Go to vnrw seeraoard.com Write to us at PO Boll OM Slolat Fah, SD $71174=3 P eat ON* Dots 02/17/09 EXHIBIT "R.• 9008 SearsCharge PLUS" EUGENE CAMPBELL Account Number: XXXX XXXX XXXX 9008 Page 2 of 2 0 Cardmember News Call us at 1-800-917-7700 Go to www.searscard.com Write to us at PO Box 6283 Sioux Fells, SD 571117-6283 Payment Due Date 02/17/09 The "Effective ANNUAL PERCENTAGE RATE" includes all transaction and periodic finance charges imposed this billing period on all balances on which finance charges were imposed. If the "Effective ANNUAL PERCENTAGE RATE" is N/A, no finance charges (after adjustments) were imposed this billing period. Finance charges may be accruing on promotional balances and may be billed to your account under the terms of the promotional offer. Refer to the corresponding APR for the APR that applies to each balance. Verification I Tea ?-eynolds 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. Signature C-21587 Eugene Campbell Account number ending in 9008 1031 0 Flw..f.1? nr Try it f.7~ i • r- rv [c03 J z 23 f,t r i i 418.50 Po ATTq Gc'? 558x5 R? aago48 Sheriffs Office of Cumberland County R Thomas Kline at tmbf j Edward L Schorpp Sheri, 't0 Solicitor Ronny R Anderson Jody S Smith Chief Deputy Civil Process Sergeant Citibank (South Dakota) N.A. vs. Eugene Campbell Case Number 2009-4219 SHERIFF'S RETURN OF SERVICE 06/25/2009 03:16 PM - Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on June 25, 2009 at 1516 hours, she served a true copy of the within Complaint and Notice, upon the within namec defendant, to wit: Eugene Campbell, by making known unto Nancy Campbell, wife of defendant at 5257 Meadowbrook Drive 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: $37.00 June 26, 2009 SO ANSWERS, f R 14 ' KL E IFF An n r] 4-C e uty Sheriff c ti o d 't' C. CITIBANK (SOUTH DAKOTA), N.A. 701 East 60th Street N, Sioux Falls, SD 57117 Plaintiff V. EUGENE CAMPBELL 5257 Meadowbrook Drive Mechanicsburg PA 17050-6833 Defendant To the Prothonotary: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-4219-CIVIL TERM : CIVIL ACTION - LAW Praecipe for Default Judgment 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 $6,533.05 $6,533.05 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 wAte. JUDGMENT BY DEFAULT ENTERED Bui AND DAMAGES ASSESSED AS ABOVE. NOTICE GIVEN UNDER P .R.CIV.P. 236 By: ro Prothonotary?i The law firm of Burton Neil & Associates is a debt collector. P.C. Der-dk Ci Blasker, Esquire Attorney for Plaintiff I.D. NO. 02150 1060 Andrew Drive, Suite 170 West Chester, PA 19380 C-21587 c ' CTITBANK (SOUTH DAKOTA), N.A. Plaintiff V. EUGENE CAMPBELL Defendant : IN THE COURT OF COMMON PLEAS C-21587 CUMBERLAND COUNTY, PENNSYLVANIA : NO.09-4219-CIVEL TERM CIVIL ACTION - LAW Notice of Intention to File Pmecipe for Default Judgment TO: Eugene Campbell 5257 Meadowbrook Drive Mechanicsburg PA 17050-6833 IMPORTANT NOTTCE 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 80%990-9108 DATE OF NOTICE: July 20, 2009 In making this communication, we advise our office is a debt collector. P.C. By: IM 19 Derek laske, Esquire Attorney for Plaintiff Identification No. 202150 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 FILED-G `HC,E TF Mg AUG -5 Pill 2: 1 ` V144-66 ?CL X Ct?' 57ss? i?6 aza8s? , LC tf- PIS • , 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. Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA V. EUGENE CAMPBELL Defendant : NO. 09-4219-CIVIL TERM 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 Aa? ? r Prothono By: beput9 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.