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Home My WebLink About09-50371. Blatt, Hasenmiller, Leibsker & Moore, LLC Daniel Santucci Attorney I.D. #92800 Gregory R. Dye Attorney I.D #205316 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 800-850-1079 Attorney for Plaintiff, CITIBANK (SOUTH DAKOTA) N.A. CITIBANK (SOUTH DAKOTA) N.A. c/o Blatt, Hasenmiller, Leibsker & Moore, LLC 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 Plaintiff, vs. ROBERT J MAXWELL AKA ROBERT J MA; 3 MARSHALL DR CAMP HILL PA 17011-1146 Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. t? _ 503'1 0,-y it Te iK SR PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY: Kindly ENTER my appearance in the above-captioned matter on behalf of PLAINTIFF CITIBANK (SOUTH DAKOTA) N.A.. Papers may be served at the address set forth below: Blatt, Hasenmiller, Leibsker & Moore, LLC 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 Telephone Number: 1-800-850-1079 ext. 4151 BLATT, HASENMIL & MOORE, LLC Dated: May 21, 2009 By: Daniel Santucci Gregory R. Dye EIBSKER 2301481 PPTXPEAI 111111111 1111 III 111111 II111 IIIII 11111 IIIII 11111 IIIII IIIII 1111 IIII RLLU'{Jt`4F1("E OF THE PP7-!n-' !STAR 2009 JUL 24 PH 12= tl 9 PEI* i,14ti7YLVAINJIiA t 4 Blatt, Hasenmiller, Leibsker & Moore, LLC Daniel Santucci Attorney I.D. #92800 Gregory R. Dye Attorney I.D #205316 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 800-850-1079 Attorney for Plaintiff, CITIBANK (SOUTH DAKOTA) N.A. CITIBANK (SOUTH DAKOTA) N.A. c/o Blatt, Hasenmiller, Leibsker & Moore, LLC 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 Plaintiff, vs. ROBERT J MAXWELL AKA ROBERT 3 MARSHALL DR CAMP HILL PA 17011-1146 Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. CR - 503'1 0,-,vi I Tern. SR NOTICE TO DEFEND 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 twenty (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 claims 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. 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 REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 267-2032 2301481 PPTCHDFI Blatt, Hasenmiller, Leibsker & Moore, LLC Daniel Santucci, Attorney I.D. #92800 Greg R. Dye, Attorney I.D. #205316 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 800-850-1079 Attorney for Plaintiff, CITIBANK (SOUTH DAKOTA), N.A. CITIBANK (SOUTH DAKOTA), N.A. c/o Blatt, Hasenmiller, Leibsker & Moore, LLC Plaintiff, vs. ROBERT J MAXWELL AKA ROBERT J M IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. 09- 5-639 SR 3 MARSHALL DR CAMP HILL PA 17011-1146 Defendant(s). COMPLAINT Plaintiff, CITIBANK (SOUTH DAKOTA), N.A. claims as follows: 1. The Defendant(s), ROBERT J MAXWELL, is a resident of Cumberland County, Pennsylvania. 2. In the usual course of business, the Defendant requested that Plaintiff open, and Plaintiff did open a credit account. Defendant was the cardholder under the account. 3. The Defendant(s) did use the account to make purchases of goods and/or services and/or to receive cash advances. There is a balance due and owing of $9672.74. 4. Plaintiff properly billed Defendant for payment of the charges on the account. Defendant has failed to pay the amounts due and owing. Thus, Plaintiff declared Defendant(s) to be in default and demands payment of the balance. 2301481 PPTCCITI WHEREFORE, the Plaintiff, CITIBANK (SOUTH DAKOTA), N.A., prays for judgment in its favor and against Defendant(s), ROBERT J MAXWELL in the amount of $9672.74, plus costs. By: Respectfully submitted, CITIBANK (SOUTH CTA), N.A. One of its Attorneys Daniel Santucci, Attorney No. 92800 Greg R. Dye, Attorney I.D. #205316 Blatt, Hasenmiller, Leibsker & Moore, LLC 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 (800) 850-1079 Dated: May 21, 2009 VERIFICATION Leola Phenix is 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 including but not primarily limited to collecting delinquent debt. 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). The foregoing averments of fact in the within COMPLAINT are true to 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: Signature 2301481 PPTXCITI Exhibit "A" PPTXEXAI ? R 04/20/09 $9672.74 $9672.74 SITE:KC-CL TM:CO-5000 ACID:KC80219 ainF ? " ? We 04/24/09 22:30:36: CITI CARDS PO BOX 183051 ROBERT J MAXWELL COLUMBUS, OH ATTNY ACCOUNT-CODE=CSBE 43218-3051 CAMP HILL PA 17011-1146000 Atl® Platinum Select" Card .+ccount Number ;309 0814 3001 9155 Customer Service: 1-800-950-5114 Total Credit Line Available Credit Line Cash Advance Limit Available Cash Limit PO Box 44167 $8450 $0 $4000 $0 Jacksonville, FL 32231-4167 Statement/ Closin Data 03/25 2 Amount Over Credit Line Post Due Purch/Adv I?Inimum Due / 09 $1222.74 $1597.33 5303.02 Sale Date Post Date Reference Number Activity Since Lost Statement Standard Purch 3/25 8PURCH0000*FINANCE CHARGED*PERIODIC RATE 3/25 Standard Adv 188.64 70000000000 84VAN0 00 INANCE CHARGE*OPERIODIC RATE 18.38 170000000000 Help is available! Please call the toll-free number shown above to learn about our special payment options. Call Monday- Friday, 7 am to 9 pm, or Saturday, 8 am to 5 pm, Central Time. Please give us the opportunity to assist you. Account summary ___'-- . --11 -, % -I'ay1V1mz Balance & Advances & Credits tTj rjns?nuc CHARGE (_) New PURCHASES ADVANCES $8 625.51 $840 21 0.00 1 0.00 $188.64 Balance $8 814.15 TOTAL . $9,465.72 0.00 0.00 0.00 10.00 $18.38 $207.02 4858.59 $9,672.74 Days Th is Bolin Period: 29 'late Summary Balance Subject Finance Charge o Pori-odic Rate om>na ANNUAL `' RCHASES APR PERCENTAGE RATE tandard Purch 'VANCES $8,716.24 0.07463%(D) 27.240% 27.240% candard Adv $849.05 0.07463%(D) 27.240% 27.240% Ex #1 j C A#','%, New Balance $9672.74 Minimum Amount Due $9672.74 0 PLED-0F ROE OF TNG U? H-) NOTARY 2009 JUL 24 HI 12= 49 +'78.50 PC) Aral co 50x1 11 pj4 aa$ 3q5 Sheriffs Office of Cumberland County R Thomas Kline Sheriff Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor ,a?rtr OFF iC E OF rHE S-ERIFF 7 V iy OF THE THE 2099 AUG -:3 Ails j: 29 rh 1 Citibank (South Dakota) N.A. vs. Robert J. Maxwell Case Number 2009-5037 SHERIFF'S RETURN OF SERVICE 07/29/2009 08:23 PM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on July 29, 2009 at 2023 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Robert J. Maxwell, by making known unto himself personally, defendant ai 3 Marshall Drive Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $41.50 July 30, 2009 SO ANSWERS, ?i ???? gal R THOMAS KLINE, SHERIFF Deputy Sheriff Blatt, Hasenmiller, Leibsker & Moore, LLC Attorney for Plaintiff, Daniel Santucci CMBANK (SOUTH DAKOTA) N.A. Attorney I.D. #92800 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 800-850-1079 ext. 4151 CITIBANK (SOUTH DAKOTA) N.A. c/o Blatt, Hasenmiller, Leibsker & Moore, LLC 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 Plaintiff, VS. ROBERT J MAXWELL AKA ROBERT J MAXWE 3 MARSHALL DR CAMP HILL PA 17011-1146 Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. 09-5037 SR PRAECIPE FOR ENTRY OF JUDGMENT BY DEFAULT FOR FAILURE TO PLEAD TO THE PROTHONOTARY: Kindly ENTER a JUDGMENT BY DEFAULT FOR FAILURE TO PLEAD against the DEFENDANT ROBERT J MAXWELL in this matter in the amount of $9,672.74 plus court costs. I also hereby certify that a true and correct copy of the Notice required by Pa.R.C.P. 237.1(a)(2) was mailed separately to each defendant on 7/29/09 by regular mail. A true and correct copy of each Notice is attached hereto. Dated: September 17, 2009 2301481 PPTJPFJI By: Respectfully submitted, BLATT, HASENMILLER, & MOORE, LLC / 11111111 IN I I IIIHI ICI 111111111/ 111111111111111111 IN Blatt, Hasenmiller, Leibsker & Moore, LLC Attorney for Plaintiff, Daniel Santucci, Attorney I.D. #92800 CITIBANK (SOUTH DAKOTA) N.A. Gregory R. Dye, Attorney I.D. #205316 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 800-850-1079 CITIBANK (SOUTH DAKOTA) N.A. c/o Blatt, Hasenmiller, Leibsker & Moore, LLC 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 Plaintiff, VS. ROBERT J MAXWELL AKA ROBERT J MAXWE 3 MARSHALL DR CAMP HILL PA 17011-1146 Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. 09-5037 SR AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: County of Chester: I, Daniel Santucci/Gregory R. Dye, being duly sworn according to law, depose and say I am the attorney for Plaintiff and I am authorzied to make this affidavit on Plaintiff's behalf. I hereby certify that the Defendant is at least 18 years of age and not in the Military Service of the United States, nor any State or Territory thereof or its allies as defined in the Servicemembers' Civil Relief Act of 2004 and any amendments thereto. I also herby certify that the statements made in the foregoing Affidavit of Non-Military Service are true and correct to the best of my information, knowledge, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities. BLATT, HASENMIL./EIBSKER & MOORE, LLC Dated: September 17, 2009 By: Gregory R. Dye 2301481 uu PPTJCNMI 1 11111111111 AMIII [Ell 1111111 l? 11 VIII CITIBANK (SOUTH DAKOTA) N.A. Plaintiff, VS. ROBERT J MAXWELL 3 MARSHALL DR CAMP HILL PA 17011-1146 Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. 09-5037 TO: ROBERT J MAXWELL AKA ROBERT J MAXWELL SR Date of Notice: August 31, 2009 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" 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 PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. 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 REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 267-2032 By: BLATT, & M001 LEIBSKER 0 Santucci d-" - 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 800-850-1079 x 4151 This is a communication from a debt collector. This is an attempt to collect a debt and any information obtained will be used for that purpose. 2301481 PPTNLRSI 1111111 NI N III M IH? VIII III ?H 1111111111111 IN 2301q'00 Sheriffs Office of Cumberland County R Thomas Kline Sher of t Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant o of na: sHee Edward L Schorpp Solicitor Citibank (South Dakota) N.A VS. Robert J. Maxwell Case Number 2009-5037 SHERIFF'S RETURN OF SERVICE 07/29/2009 08:23 PM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on July 29, 2009 at 2023 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Robert J. Maxwell, by making known unto himself personally, defendant at 3 Marshall Drive Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $41.50 SO ANSWERS, July 30, 2009 R TFIOMAS KLINE, SHERIFF 4yr'z? Deputy Sheriff AA Ttf-W&ANY 2009 SEP 30 PM 1: 13 CUM t. coum -41+. oo Po ATT-1 Ct, U 5910 e d31o147 IJokec. LloAScl' CITIBANK (SOUTH DAKOTA) N.A. Plaintiff, VS. ROBERT J MAXWELL Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. No. 09-5037 TO: ROBERT J MAXWELL NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Default Judgment has been entered against you in the above proceeding. PROTHO A Y Dated: _ By: IF YOU HAVE ANY QUESTIONS CONCERNING THE ABOVE, PLEASE CONTACT: Attorney of Record for Plaintiff: Blatt, Hasenmiller, Leibsker & Moore, LLC Daniel Santucci Attorney I.D. #92800 P.O. Box C3800 Southeastern, PA 19398 800-850-1079 2301481 PPTNDJNI I I'II?I I?I? II III?I il??) ?? ??I ? ? ?? II'?I ?I II'I