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HomeMy WebLinkAbout09-6237Burton 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 US BANK NATIONAL ASSOCIATION ND 9321 Olive Boulevard St. Louis, MO 63132 Plaintiff V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANI? (? II II YOUNG M CHOI NO. 6Q- (pa37 l.tV t ( ??f 49 Creek Bank Drive Mechanicsburg PA 17050-1814 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 Y pages, you must take action within (20) days after this complaint and notice are served, entering a written appearance personally or by attorney and filing in writing with the co your defenses or objections to the claim set forth against you. You are warned that if you fail do so, the case may proceed without you and a judgment may be entered against you by the co without further notice for any money claimed in the complaint or for any other claim or re ief requested by the plaintiff. You may lose money or property or other rights important to yb . 11 YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU D NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TH OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL ELP THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING) i LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE AB E TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFF LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FE . 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 126570 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 US BANK NATIONAL ASSOCIATION ND : IN THE COURT OF COMMO 9321 Olive Boulevard N PLEAS St. Louis, MO 63132 Plaintiff V. CUMBERLAND COUNTY, PENNSYLVANIA YOUNG M CHOI NO. 6 9 - .L 3 ? C i u; l / er rh 49 Creek Bank Drive Mechanicsburg PA 17050-1814 Defendant CIVIL ACTION - LAW Complaint 1. Plaintiff is US BANK NATIONAL ASSOCIATION ND, with place of business located at 9321 Olive Boulevard, St. Louis, Missouri. 2. D I' efendant is Young M Choi, who resides at 49 Creek Bank Drive, Mechanicsbur 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) Korean Air credit card with account number ending in 9200 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 billin 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. ,III. 8. Defendant's actions as set forth above constituted an account stated betty for the sum of $5,576.08 which sum reflects the Exhibit A statement een Pill ties balance less credits, lif any, which were applied subsequent to the date of Exhibit A. Wherefore, plaintiff demands judgment against defendant for the sum of $5,576.08,1 and the costs of this action. /? II Burton l alb,,. ;?+o n ,. By: The law firm of Burton Neil & Associates, P.C. is a debt collector. "Cj-Cx V- 131asker, Esquire Attorney for Plaintiff C ban!S, "REUMIK JUL z • Februarryy Statemen# for activity from Jan. 27, 2009 through Feb. 27, 2009 liigrie: l =8-2 YOUNGM CH01 BNK 35 page Activity Summary Credit and Payment Information Previous Balance ................................. $6,750.18 Credit Line ........................................... Payments and Credits ................. $7,0 7,095.53 Available Credit....,............... ............................... Purchases, Advances & Other Debits 0.00 Minimum Payment Due Current Month)... FINANCE CHARGES ......................... 0.00 Minimum Payment Due (Past Due) ........... New Balance ....................................... $6,576.08 Total New Minimum Payment Due.......... Payment Due Date .................................... Mar.1 To reduce or avold paying additional finance charges on your purohase balance, pay the total new balance of $6,676.08 by 031 Any cash balance or balance transfer balance wfN ocnNnue to aoorue dally Interest unNl the dare yourpsyment is rooked. Payments 02,27 and Credits 0227 02/27 02/27 BALANCE TRANSFER $0.0o PURCHASES 3,638.83 ADVANCES 3,668.70 .00 w.vvesuaan?o 00 0.0768849E VARIABLE $0.00 27.99% 0.00% N 8.63 0.0768849E VARIABLE $88.78 27.999E 27.99% Y 63ASS.70 0.076684% VARIABLE $87.32 27.99% 27.99% N Each time you or a third Far' on your behalf, pays your bill by personal check, you authorize us to convert that into an electronic debit. I the check is processed electronically, the checking account will be debited for the amo the check and the debit will appear on your account statement. If you have any questions, please contact us at t inquiries phone number located on this statement. VIII i i i End of Statement Please detach and send coupon with check payable to: U.B. Bank 0347192785652892000000000000005576087 1'. ?ban!S,, YourAcoorrntNumber. QQQ Total Now Balance: $5,576.08 Mlnknum Payment Due. $0.00 To change your address or for Cardmember Servloe please call: ray 10- , oe. 1-866-288-ViSA Every Hourl ;Every Dayl Mar. 19, 2009 000000694 1 SP 106481096811926 a YOUNG M OHOI 49 OREEK BANK DR MEOHANIOSSURG PA 17060-1814 ?IlII1i1101i1161111111t11111fIhr111loll lll"Ii11111111'li'llll on U.S. Bank P.O. Box 790408 St. Louis, MO 63179-0408 n111Jill 1111111111111»11111n1111111r111u111111111111lIII?I111 EXHIBIT A In 0080 of Errors or Questions About your all, it you think that your bill is wrong or if you possible: Y need more information about a transaction on our bill, Please verify the foAowing as soon as 0- if other members of your household may have participated in the transaction. ? Review your reoefpts for this dollar amount as it may have posted to your statement with a difterent merchant name. ? That you have contacted the merchant in an attempt to resolve the issue. If you wish to dispute the transaotion please phone Oardmember Service at the telephone number on the front of this statement and have the following Information available: 10- The date and dollar amount of the transaction you are questioning, ? An explanation of why you believe there Is an error or why you need additional information along with an d have to support your dalm. 10- The date you contaoted the merchant to attempt to resolve this Issue and marohanYs response, any oownentation you may Many inquiries can be oorreoted over the phone, but phoning alone does not preserve your rights. In order to preserve must receive your written communication no later than 60 days after we sent you the first bid on which the error or problem appeared. 25-6335. r 681 Please send a letter with your name, account number and the above information to: Qa your rights, D have to of your bill that re not in quaetlon While j oblAny we count I question while we are tnvealigating,bbut you still rreemaln obligated j ND You do the amount in question. Your dispute, we cannot report you as delinquent or take any d 0335, to teanyd to actipay n t oco Fargo, i peat Special Rules for Credit Card purchases: it you have a problem with the quality of property or services that you purchased with your orecit to oorreot the problem with the merchant, you may not have to pay the remaining amount due on the card, d you have tried in protecdon only when the purchase pdoe is more than $60 and the purchase was made in proper is oh' or in miles good of faith ourreM mailing address. The oondltions do not rvioos. You have this the services: 8pedal rules for credit card puroh not do ly If notes n the mer u aohanrhthor if we ?n?n ion ?Ae sement 100 the pro a your to ade with apply P emeM for the property kr Important Information Regarding Your balance transfer oheds. 1. Amounts subject to interest: We calculate the periodic rate or Interear portion of the FINANCE C Applicable daily periodio rate by the Average Daily Balance (Including new trarhsaotions of the Puce, d multiplying Transfer categories (-Amounts 8ubjeot to interest), and then multiplying that result by the number of days in the bffiing oyol billed e. Average r category, we tale the beginning balance of those account categories eaoh day n get unpaid inters teas credit insurance oharges , and other charges), add any new transactions, Interest; fees and charges, and subtract any payments or credits applied against &aoount balances that day. (Purchase, Advance and Balanoe Transfer transactions are added to account balances on the later of their unpaid account oharges and transaction fees for these categories transaction added to aa? M b a? the the account Billed and unpaid interest for these oategores is added to account balances eaoh month on the sta statement Pew Billed and This gives us the daily balances of the Purchase Advance and Balance Transfer categories. Then we add up al the they are charged to the for these categories for the billing ® lament closing date.) result billin Daily Balance (and the Amounts ubject to jrt eraaq of he Purydtthe asso Advance days Balanoe T anar Yale. gives I y the dally Payment Information: Make checks payable to U.S. Bank National Association ND. Use the enclosed return envelope to malt your payment to: U.B. Bank National Association NB, P.O. Box 790408and aeoompahnled by the payment coupon will be oredited to your aooount on the day of receipt If received at this address by 00 p.m. C8T on any banking day. Banking days are all calendar clays; except Saturday, Sunday and federal holidays. Other payments will be credited to your aooount within five banldng days of receipt y U.S. Bank W may repo?re,ati our account to oredit bureaus, late payments, missed payments or other defaults on may be refie? your credit rep ort your account Verification UNDO 13UDA (Name of authorized representative) is Recovery Manap, (Title or Position) for, US BANK NATIONAL ASSOCIATION ND, the within Plaintiff in this actio and statements of fact made in the f n ore that e going Complaint are true and correct to the best of the undersigned verifier's knowledge and belief. made The undersigned understands that the statements herein are subject to the ' penalties of ,The C.S. Section 4904, relating to unworn falsification to authorities. Date: 4 sine 126570 Young M Choi Account number ending in 9200 1326 O v? *'18. 5D PD krry Clf' it a3a P,Twa3o(051 Sheriffs Office of Cumberland County R Thomas Kline Sheri Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor ?.ta at Climb" 1*,t44 QFF1CE Oa "E SHERIFF FII-E j 4' OF THE F ?r 0 `,CRY 20109 SEP 28 PCt 12= 54 US Bank National Association Case Number vs. Young M. Choi 2009-6237 SHERIFF'S RETURN OF SERVICE 09/25/2009 11:45 AM - Jody Smith, Sergeant, who being duly sworn according to law, states that on September 25, 2009 at 1145 hours, she served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Young M. Choi, by making known unto herself personally, at The Cumberland County Sheriffs Office 1 Courthouse Square Room 303 Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $46.00 1;?I? fem. September 25, 2009 R THOMAS KLINE, SHERIFF By 0, 0 C "-?- Serg ant +US BANK NATIONAL ASSOCIATION ND 9321 Olive Boulevard, St. Louis, MO 63132 Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. ~ NO. 09-6237 CNIL TERM ~' `~ -_+ YOUNG M CHOI '' ~ y -'~ 49 Creek Bank Drive - - ~~ ' ~ `~~ ~' Mechanicsburg PA 17050-1814 -r Defendant :CNIL ACTION -LAW - `' -- r~ ' 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 $5,576.08 $5,576.08 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 Burto Associates, P.C. AND DAMAGES ASSESSED AS ABOVE. NOTICE GIVEN UNDER PA.R.CIV.P. 236 By: e C. Blasker, Esquire ~ Attorney for Plaintiff Pro Prothonota I.D. NO. 202150 1060 Andrew Drive, Suite 170 West Chester, PA 19380 The law firm of Burton Neil & Associates is a debt collector. 126570 ~ I ~F. oo P p ~Jrn! C~~ 73 Ala o ~c~.e~t. ~~~ US BANK NATIONAL ASSOCIATION ND Plaintiff v. YOUNG M CHOI Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-6237 CTVII., TERM CIVIL ACTION -LAW Notice of Intention to File Praecipe for Default Judgment TO: Young M Choi 49 Creek Bank Drive Mechanicsburg PA 17050-1814 IMPORTANT NOTICE 126s7a You aze 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. 717-249-31 b6 or 800-990-9108 DATE OF NOTICE: December 23, 2009 Associates, P.C. By: Derek cer, Esquire :.,= In making this communication, we advise our office is a debt collector. cc: Andrew H. Shaw, Esquire 200 S Spring Garden St, Ste 11 Cazlisle, PA 17013-2578 Identification ~o. 202150 1060 Andrew rive, Suite 170 West Chester, PA 19380 {610} 696-2120 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 US BANK NATIONAL ASSOCIATION Plaintiff v. YOUNG M CHOI Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-6237 CIVIL, TERM CNIL 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_ 5 ~~// ~ Prothonotary By: ~ eputy 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. r t 2013 Np,y 20 Ail 3, 16 CU118ERLAND co Pry'Vs'YLVAN A � 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 US BANK NATIONAL ASSOCIATION IN THE COURT OF COMMON PLEAS ND Plaintiff CUMBERLAND COUNTY,PENNSYLVANIA V. NO. 09-6237 CIVIL TERM YOUNG M CHOI Defendant : CIVIL ACTION-LAW Praecipe to Satisfy Judgment To the Prothonotary: Mark the judgment Satisfied . Burton N '1 ssociates, P.C. By: Der C. lasker, Esquire Attorney fo 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. 126570 /318 Q 8 q svp C*—4- )wg oS