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HomeMy WebLinkAbout09-5571Burton 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 CITIBANK (SOUTH DAKOTA), N.A. 701 East 60th Street N Sioux Falls, SD 57117 Plaintiff V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CHRISTINA M MOTCHENBAUGH :NO. CA - SS71 tv? L Terms 20 Yankee Drive Mount Holly Springs Pa 17065-1036 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 C-23961 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 CITIBANK (SOUTH DAKOTA), N.A. 701 East 60th Street N Sioux Falls, SD 57117 Plaintiff V. CHRISTINA M MOTCHENBAUGH 20 Yankee Drive Mount Holly Springs PA 17065-1036 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 09- 5571 Ouxa Tt-' 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 Christina M Motchenbaugh, who resides at 20 Yankee Drive, Mount Holly Springs, 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) AT&T Universal credit card with account number ending in 4795 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 $3,744.57 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 $3,744.57, and the costs of this action. Burton Neil & Associates, P.C. V Edward J. O'Brien, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. r r = C N 7m ?OJ ti W 4 • (Op R ? O m l" 4, Opt al N I? j U 1 Q Z W 7 LA b o N ? all • _ 8 O ?N O N < N QB?Q n r$ 0 o EE o L N O J F 40 40W N O date piia 3MMIA paid Total New Balance: "7449? Minimum Amount Out: "714.37 Payment Due Date: 07/Iq/2000 000000 MC 32 A 0 CHRISTINA M MOTCHENSAUGH 20 YANKEE DR MOUNT HOLLY SPR PA 17065.1036 r- o t` of O w? 1 vf O e O 8 8 1 N C? O w m m O O Y O ? O 0 o `R P P C o ° o ,? p? p 0 0 0 = s? 8 ° ° 8 0 o o P O P O !? ! m m W ` 3 ?8 8 ? P o P , ti s. m m 8 8 g 3 C G y ? A < ? 8 4 ? S V < O O O O O N M O 1!1 N nl N ` m M V C N ? V N a? n« $3 d -dam d? ca T o ° O CO "S O V yS ?? ++ C Y,e N? j J E ? Ny te ? _VC a d'!- V , n 9 o? C J J L A 3 C d 0 V a r N 4E' 2 Boa V d < A lLe • .? N .a in c: 7 N . . < N } Z OT F Q U O N _(Wh ll ?__? _ ONWi MN MNw MYn?•K YUlcoitlNN mrW+o MoeeatwP.yMwa,AT&T Univoraal Curd n Account Number: 4795 of !!!/// ??I Amount Enclosed: Poymnt Must be I\co ves by 5:00 PM local time on the ps"Irlt d" sib. AT&T UNIVERSAL CARD P.O. Box 162564 COLUMBUS, OH43216-2564 E%HIBR?3_. .? p ?? ?Y ???? ?? uap V 0 Z W S V H O S Z M Q h T P uv W ?HW ?? ?? $a a 0 u? ?y Verification I, 1 iiegMaN a?aauud 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. C-23961 Christina M Motchenbaugh Account number ending in 4795 1000 0 n " tt -l± ': I ) A J 6 I s -, 418, so P.0 Am/ Ck-* 580o1D aagoaa Sheriffs Office of Cumberland County R Thomas Kline Sheri Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor y?tr at r"44A y OFFICE OF ?- SIERIFF O 7N? ?Ds "r% 2009 AUG 25 Aid 10: Gb CUMPI L ? .?N Y Citibank (South Dakota) N.A. vs. Christina M. Motchenbaugh Case Number 2009-5571 SHERIFF'S RETURN OF SERVICE 08/13/2009 03:27 PM - Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on August 13, 2009 at 1527 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Christina M. Motchenbaugh, by making known unto herself personally, defendant at 20 Yankee Drive Mount Holly Springs, Cumberland County, Pennsylvania 17065 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $34.30 August 14, 2009 SO ANSWE i R THOMAS KLINE, SHERIFF By Deputy Sheriff CITI13ANK (SOUTH DAKOTA), N.A. 701 East 60th Street N, Sioux Falls, SD 57117 Plaintiff V. CHRISTINA M MOTCHENBAUGH 20 Yankee Drive Mount Holly Springs Pa 1706.5-1036 Defendant : CIVIL ACTION - LAW Praecipe for Default Judgment To the Prothonotary: 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 : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-5571 CIVIL TERM $3,744.57 $3,744.57 Understanding that false statements herein made are subject to penalty under 18 Pa. C.S. § 4904 relating to unswom 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. NOTI GIVEN ER PA.R.CIV.P. 236 Pro othonot n Atto rney for Plaintiff I.D. NO.32985 1060 Andrew Drive, Suite 170 West Chester, PA 19380 B Wifard tes, P.C Yen, Esquire The law firm of Burton Neil & Associates is a debt collector. C-23961 CTI'1BANK (SOUTH DAKOTA), N.A. Plaintiff V. CHRISTINA M MOTCHENBAUGH Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-5571 CIVIL TERM CIVIL ACTION - LAW Notice of Intention to File Praecipe for Default Judgment TO: Christina M Motchenbaugh 20 Yankee Drive Mount Holly Springs Pa 17065-1036 IMPORTANT NOTICE C-23961 You are in default because you have failed to enter a written appearance personalty 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 ton (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: September 8, 2009 In making this communication, we advise our office is a debt collector. Neil & Associates, P.C. Attorney tom" ' laib Identification No. 32985 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 cc: Harold W. Shepley, Esquire 209 W Patriot St Somerset, PA 15501 , ?7 ARY T THE 7009 S EP 28 PH 12: 5 j i LV $14.oo Pp AT'r4 ey-* 5g415 e .151 I Z5 No4hee "d Burton Neil & Associates, P.C. By: Edward J. O'Brien, Esquire ID. NO. 32985 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA), N.A. Plaintiff V. CHRISTINA M MOTCHENBAUGH Defendant: : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 09-5571 CIVIL TERM CIVIL ACTION - LAW Rule of Civil Procedure NO. 236 (Revised) Notice is given that a JUDGMENT in the above captioned matter has been entered against you on 9/oZ$f07 rotho 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.