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Home My WebLink About09-4432Burton Neil & Associates, P.C. By: Edward J. O'Brien, Esquire ID. NO. 32985 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 Attorney for Plaintiff PNC BANK, DELAWARE 9321 Olive Boulevard St. Louis, MO 63132 IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. ROBERT L VOGELSONG NO. QQ 55 Glendale Dr Unit G,, Mechanicsburg PA 17050-1546 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 123386 Burton Neil & Associates, P.C. By: Edward J. O'Brien, Esquire ID. NO. 32985 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 Attorney for Plaintiff PNC BANK, DELAWARE 9321 Olive Boulevard St. Louis, MO 63132 Plaintiff V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 0 T-- 41 v.3-Z C 4 c- l1 ,-, ROBERT L VOGELSONG 55 Glendale Dr Unit G, Mechanicsburg PA 17050-1546 Defendant CIVIL ACTION - LAW Complaint 1. Plaintiff is PNC Bank, Delaware, with place of business located at 9321 Olive Boulevard, St. Louis, Missouri. 2. Defendant is Robert L Vogelsong, who resides at 55 Glendale Dr Unit G, Mechanicsburg, Cumberland County, Pennsylvania. 3. Plaintiff is 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 9167 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 $12,518.93 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 $12,518.93, and the costs of this action. Burton„Neil & Associates, P.C. JJ BY: % . Edward J. O'Brien, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. 11 r?,, 1) " -? 7) L, -) PNC Bank Select Rewards Visa@) Platinum Card March Statement for activity from Feb. 22, 2008 through Mar. 25, 2008 Inquiries: 1-866-395-8294 ROBERT L VOGELSONG 814 Page 1 of 2 ??ur Pt+tGG?A?(??efe?R?tvV'?t?s?lFft3a?M`P??i?inu?tt?;rdlaoc?rttnta?ts?gfat3??y?? 74 1rl I l M `' `' L "-{ '4} t W t U !W) J' _ C 1{ 7 14, h1214 h It{`Y?t{IRtY? a 67 r. ri.....3,.....A.. ....._c.., f.. .. .. _1.. .r-..._,.. ni :i?nc4., .. it 1..It4.... .:.'.- .??_...:_: .....u .1. .?..._ Activity Summary Credit and Payment Information Previous Balance ................................. $12,136.84 Credit Line................................................... $10,700.00 Payments and Credits ......................... $0.00 Available Credit........................................... None Purchases, Advances & Other Debits $39.00 Minimum Payment Due Current Month)... $508.00 FINANCE CHARGES ......................... $343.09 Minimum Payment Due (Past Due) ........... $2,514.00 New Balance ....................................... $12,518.93 Total New Minimum Payment Due.......... $3,022.00 Payment Due Date .................................... Apr. 19, 2008 To reduce or avoid paying additional finance charges on your purchase balance, pay the total new balance of $12,518.93 by 04/191va. Any cash balance or balance transfer balanceWH continue to accrue daily interest until the date your payment is received. s ti y ?r?a+? 1 n f?b5t.f11e r 4' ti 5 a ar 1 L... AW Purchases, 03/17 LATE FEE - PAYMENT DUE ON 03/17 ............................. 39.00 Advances, Debits Finance Charges 0325 -FINANCE CHARGE-INTEREST ................................. 343.09 I 1 1 i3 ?: W ........._ '?'?1:._•.::: ?.:.?::A.i?'-i i.:'4'C . ? .. _..... ... ::.:?. :. ?u :. ?_...: u: :u _. .. .. . _ ._, t... C{`-I. ',Lly :Ir, v.:, :..4'. ... This Year Statement to Date Description of Activity NET REWARDS POINTS ........................................................................................ 0 0 Total ................................................ 0 0 For rewards program Inquiries and redemption information, go to www.pne.com or call 1.888-229-8864 between 9 a.m. and Midnight (Eastern Time) Monday through Friday and 9 a.m. and 10 p.m. (ET) on Saturdays and Sundays. Automated account information is 24 hours a day, days a week. If you have not made arrangements with us for payment of your past due amount, IeYs talk about your situation. There must be a way to resolve this problem. We urge you to call us at 1-888-780-3995. Continued on Next Page please detach and send coupon with check payable to: PNC Sank ®?PNCBANK 1340818300017891670003022000012518937 Your Account Number. 9167 Total Now Balance: $12,518.93 Minimum Payment Due. $3,022.00 To change your address or for Paymmrt(Due.pats EnterAmoun3cTAayxt?r#€Enid,: PNC Bank Cardmember Service please call: 1.866-395.8294 Every Hour! Every Day! Apr. 19, 2008 ty 17373PRP T41 PD ROBERT L VOGELSONG PNC Bank 55 GLENDALE DR P.O. Box 790350 MECHANICSBURG PA 17050-1546 St. Louis, MO 63179-0350 JIIrIrIrrIIIII11rIlIIIIIIIIIIdIllrrrrllllrilllll'll?lllrlllldl I'IIIIII'lllllllllll'I'III"IIIIIIIIIIII'llplllllllllllll'Itillll EXHIBIT A „?f{t PNC Bank Select Rewards VisaD Platinum Card March Statement for activity from Feb. 22, 2008 through Mar. 25, 2008 Inquiries: 1-866-395-8294 ROBERT L VOGELSONG Page 2 of 2 I7?[tfi [iIi[[[[t?Iyc am r . ,,SIF1&-fid ' ' A1Jy DBYI Dally Rata CizTlB$ffY, '*"AQFt''" G`laGe Ar, s ?YPs W4 Pa r; PnVlaalta rre rypa J[eret HhFa p?r?Qt? P?frad , r -.1 , A BALANCE TRANSFER $0.00 $0.00 0.085589% VARIABLE $0.00 31.24% 0.00% N PURCHASES $9,504.86 $9,216.19 0.085589% VARIABLE $260.30 3124% 31.24% Y ADVANCES $3,014.07 $2,931.28 0.085589% VARIABLE $82.79 31.24% 31.24% N ikhc+ntaisrladrn9 ''fi:nt::: ?{ r ? r v? i yt67 w '? " ,.. n .? . ..., ,.. .... By Telephone: Send Inquiries to: ® Send Payments to: r ?1 By E-Mail: Every Hour! Every Day! PNC Bank Cardmember Service PNC Bank Visit our website: Voice: 1-866.395.8294 P.O. Box 6371 P.O. Box 790350 www.pne.com Too: 1-888.352-6455 Fargo, ND 58125.6371 St. Louis, MO 63179-0350 Fax: 1-866-720-7210 End of Statement Verification is Rewm Mwapr (Name of authorized representative) (Title or Position) an employee of US Bank National Association, ND, by contract the service provider for plaintiff PNC Bank, Delaware, retained to perform services including but not primarily limited to collecting delinquent debt, custodian of records and execution of documents. I am authorized to make this verification as attorney-in-fact for plaintiff under powers of attorney from plaintiff to US Bank National Association, ND. The foregoing avernients of fact in the within pleading are true and correct to the best of my 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. Date: f 'p-) `-t 123386 Robert L Vogelsong Account number ending in 9167 1318 r Name C 42 2 0 0 9 SJI f t . V78. S 6?cL A,L?y cwt S?ztiS '?- az7sa,3 Sheriffs Office of Cumberland County R Thomas Kline Sheriff 4?t?tr of cklmbr"4 Ronny R Anderson t D Chi 444 t A ' y epu ef Jody S Smith Civil Process Sergeant 'CE,!?F THE s"ERIFF Edward L Schorpp Solicitor PNC Bank, Delaware vs. Robert L. Vogelsong Case Number 2009-4432 SHERIFF'S RETURN OF SERVICE 07/07/2009 08:13 PM - Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on July 7, 2009 at 2013 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Robert L. Vogelsong, by making known unto himself personally, defendant at 55 Glendale Drive Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $37.00 July 08, 2009 SO ANSWERS, R THOMAS KLINE, SHERIFF Deput Sherif N ?c ,. r.. x J _ 1 PNC BANK, DELAWARE 9321 Olive Boulevard, St. Louis, MO 63132 Plaintiff V. ROBERT L VOGELSONG 55 Glendale Dr Unit G Mechanicsburg PA 17050-1546 Defendant To the Prothonotary: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-4432-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 $12,518.93 $12,518.93 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. NOTIC GIVEN UND R PA.R.CIV.P. 236 Pr rothonota Burton e' sociates, P.C. By: Edward J. O'Brien, Esquire Attorney for Plaintiff I.D. NO. 32985 1060 Andrew Drive, Suite 170 West Chester, PA 19380 The law firm of Burton Neil & Associates is a debt collector. 123386 PNC BANK, DELAWARE : IN THE COURT OF COMMON PLEAS 123386 Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 09-4432-CIVIL TERM ROBERT L VOGELSONG Defendant : CIVIL ACTION - LAW Notice of Intention to File Praecipe for Default Judgment TO: Robert L Vogelsong 55 Glendale Dr Unit G Mechanicsburg PA 17050-1546 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: August 3, 2009 In making this communication, we advise our office is a debt collector. BurY'riesn:, iates, P_C. By: Edsquire Attorney for Plaintiff Identification No. 32985 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 F3i ((__ .. ?/`C; 1LL? iv? iiv 2009 AUG ZO AM 11: 2 7 ?4 era, $l4.oo ATt4 CIO Baal aaq X07 )OA?? ?J? Burton Neil & Associates, P.C. By: Edward J. O'Brien, Esquire ID. NO. 32985 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff PNC BANK, DELAWARE Plaintiff V. ROBERT L VOGELSONG Defendant IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-4432-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 8/&0 jol P no'Mie - 7 By: Deputy If you have any questions concerning the above, please contact: Edward J. O'Brien, 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. OF THE PRO ?013 HA Y 28 P1t � COMBERLAND CoUt4,r ' RE1Yp4S) Z.VAp41A Burton Neil & Associates, P.C. By: Brit J. Suttell, Esquire ID.NO. 204140 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff PNC BANK,DELAWARE IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY,PENNSYLVANIA V. NO. 09-4432-CIVIL TERM ROBERT L VOGELSONG Defendant : CIVIL ACTION - LAW Praecipe to Satisfy Judgment To the Prothonotary: Mark the judgment Satisfied. B on Neil &A 'at s, P.C. By: Brit . Suttell, E uire Atforney for Plaintiff This is an attempt to collect a debt, and any information obtained will be used for that purpose. This communication is from a debt collector. 123386/318 q. ST P �3/4/ 2,6/