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HomeMy WebLinkAbout09-4488 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 FIA CARD SERVICES, N.A. f/k/a BANK OF AMERICA, N.A. (USA) 4161 Piedmont Parkway Greensboro, NC 27410 Plaintiff V. ROBERT A SNYDER 328 Old Stonehouse Road South Boiling Springs PA 17007-9667 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. Oq - qq Sa 0;vli Term 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 117458 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 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. ROBERT A SNYDER 328 Old Stonehouse Road South Boiling Springs PA 17007-9667 Defendant NO. M- : 7 ??.- f Grr?1 CIVIL ACTION - LAW Complaint 1. The plaintiff is FIA CARD SERVICES, N.A. f/k/a BANK OF .AMERICA, N.A. (USA), a national banking association with place of business located at 4161 Piedmont Parkway, Greensboro, NC. 2. The defendant is Robert A Snyder, who resides at 328 Old Stonehouse Road S, Boiling Springs, Cumberland County, Pennsylvania. 3. Plaintiff furnished consumer credit to defendant by means of a consumer line of credit with account number ending in 3607, which was subsequently changed to account number ending in 1699. 4 Defendant accepted the line of credit by making balance transfers and/or other debits on the account. 5. Monthly statements were sent to defendant each month which detailed the credits, balance transfers and/or other debits made to the account for the prior month. 6. The balance due on the account is $12,135.97. 7. Defendant did not pay the balance due on the 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 account. 8. Although demand has been made by plaintiff upon defendant to pay the sum of $12,135.97, defendant failed and refused to pay all or any part thereof. Wherefore, plaintiff demands judgment against defendant in the sum of $12,135.97 and the costs of this action. Burton NeX & .Associates. P.C. By: D'erek'C. lasker, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. '. l Verification Cea4. .1'a" is,? f for FIA CARD SERVICES, N.A. DWaBANK OF AMERICA, N.A. (USA), the within plaintiff in this action. He/she verifies that the statements of fact made in the foregoing pleading are true and correct to the best of his/her knowledge and belief. The undersigned understands that the statements made herein are subject to the penalties of 18 Pa. C.S. Section 4904, relating to unworn falsification to the authorities. Date: .zs a„oP 117458 Robert A Snyder Nam- 1 ,,flags INIT!", k J °° `SAD?_ k C, 0 OF THE 2 V ? 9 JU, -6 P 1 L: 4 9 4L,l$.50 Pp q'tW Ct,* 5103'18 (?.T# OU15340 Sheriffs Office of Cumberland County R Thomas Kline Sheri rtitr of ??ambrrl ??y? ,??? Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant 0MCE y rt r,+= S?-;RIFF Edward L Schorpp Solicitor FIA Card Services vs. Robert A. Snyder Case Number 2009-4488 SHERIFF'S RETURN OF SERVICE 07/16/2009 04:45 PM - Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on July 16, 2009 at 1645 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Robert A. Snyder, by making known unto himself personally, defendant at 328 Old Stone House Road Boiling Springs, Cumberland County, Pennsylvania 17007 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $33.40 July 17, 2009 SO ANSWERS, R THOMAS KLINE, SHERIFF ??- ';P%? Dep ty Sheriff FILED-OFFICE OF THE PROTHONOTAPY 2009 JUL 21 AM 11:08 t'ENi`'?LVANOA. I ?rj , FIA CARD SERVICES, N.A. f/k/aBANK OF AMERICA, N.A. (USA) 4161 Piedmont Parkway, Greensboro, NC 27410 Plaintiff V. ROBERT A SNYDER 328 Old Stonehouse Road S Boiling Springs PA 17007-9667 Defendant To the Prothonotary: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 09-4488 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 $12,135.97 $12,135.97 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 Bur AND DAMAGES ASSESSED AS ABOVE. NOTICE GIVEN UNDER PA.R.CIV.P. 236 By: !1/ khj f. l n Pro Prothonotary " Y# PIN Associates, P.C. Desk UBlasker, Esquire Attorney or Plaintiff I.D. NO. 202150 1060 Andrew Drive, Suite 170 West Chester, PA 19380 The law firm of Burton Neil & Associates is a debt collector. 117458 FIA CARD SERVICES, N.A. f/k/a : IN THE COURT OF COMMON PLEAS BANK OF AMERICA, N.A. (USA) Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 09-4488 CIVIL TERM ROBERT A SNYDER Defendant : CIVIL ACTION - LAW Notice of Intention to File Praecipe for Default Judgment TO: Robert A Snyder 328 Old Stonehouse Road S Boiling Springs PA 17007-9667 IMPORTANT NOTICE 117458 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 800-2S DATE OF NOTICE: August 13, 2009 In making this communication, we advise our office is a debt collector. Burton By: Derek C. la r, Esquire Attorney for Plain iff Identification No. 202150 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 5,1ii'll, IL .rr FLED-O riCE Or. i 2009 AUG 28 Pry 1- 3 ldl! .:. # 4/? o #? ft?? Uq q -3 1 OA/a Mai ti 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 FIA CARD SERVICES, N.A. f/k/a Plaintiff PENNSYLVANIA IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, V. ROBERT A SNYDER Defendant NO. 09-4488 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 d/ 0w0/?? Prothonotary By: &a4 r lint Deputy 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.