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HomeMy WebLinkAbout09-7485Burton Neil & Associates, P.C. By: Yale D. Weinstein, Esquire ID. NO. 89678 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 Attorney for Plaintiff FIA CARD SERVICES, N.A. flkla BANK OF AMERICA, N.A. (USA) 4161 Piedmont Parkway Greensboro, NC 27410 Plaintiff V. JOHN M SEMOCK 171 Ridge Road, Biglerville PA 17307 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. Qq - x]485 0-tvi (err- : 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 119477 Burton Neil & Associates, P.C. By: Yale D. Weinstein, Esquire ID. NO. 89678 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. ` JOHN M SEMOCK 171 Ridge Road, Biglerville PA 17307 Defendant NO. 0 g- '7Y PS M?-j Ti l.- 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 John M Semock, who resides at 171 Ridge Road, Biglerville, Cumberland County, Pennsylvania. 3. Plaintiff furnished consumer credit to defendant by means of a credit card with account number ending in 1221, which was subsequently changed to account number ending in 6077. 4 Defendant accepted the credit card account by making purchases, balance transfers and/or cash advances. 5. Monthly statements were sent to defendant each month which detailed the charges and credits made to the credit card account for the prior month. 6. The balance due on the credit card account is $4,427.87. 7. Defendant did not pay the balance due on the credit card 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 credit card account. 8. Although demand has been made by plaintiff upon defendant to pay the sum of $4,427.87, defendant failed and refused to pay all or any part thereof. Wherefore, plaintiff demands judgment against defendant in the sum of $4,427.87 and the costs of this action. Burton Neil &JAsVociates, P.C. By. - Yale p. Weinstein, Esquire Atto ey for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt J Verification Robin Mays is . 4L9! for FIA CARD SERVICES, N.A. f/k/a BANK 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 unsworn falsification to the authorities. Date: Name a?'?,•C?? 119477 ra N O -rots" ?' John M Semock O G ?z =G'? i9LIG ; % U 1/1/IINN 0 FILED-OVRCE OF THE PRO TI ? ONOTARY 2009 OCT 29 PH 2: 10 Ct,wU:? l::? ,L" LJJU MIN PEP 3 LVA N tk PO A-r rY C,k.?' loaat?q Rs aaa15a Burton Neil & Associates, P.C. By: Yale D. Weinstein, Esquire ID. NO. 89678 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) Plaintiff V. JOHN M SEMOCK Defendant IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. © 9- 7V&S : CIVIL ACTION - LAW Praecipe to Discontinue To the Prothonotary: Kindly discontinue the above-captioned action wi Neil 0 associates, P.C. ale D,. Weinstein, Esquire The law firm of Burton Neil & Associates is a debt 119477 2009 NOV --4 P("1 2: 5 b SHERIFF'S OFFICE OF CUMBERLAND COUNTY R Thomas Kline Sheriff ~ - ., ~~`tit~z, of 4alniGr~~~~~x~ ~- ~~~.~':''~ Ronny R Anderson ~' Chief Deputy ', -- <<~.~~ ~ ".. I ;, ''~ `~ ~'in.; Jody S Smith r., „ , Civil Process Sergeant ~~~ ~ ~ ` g~ ~ ~ ~ - i i.' . , Edward L Schorpp Solicitor FIA Card Services vs. Case Number John M. Semock 2009-7485 SHERIFF'S RETURN OF SERVICE 11/16/2009 R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: John M. Semock, but was unable to locate him in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant John M. Semock. Request for service is located in Adams County. Attorney Weinstein was contacted October 30, 2009 for additonal money to deputize Adams County, to date monies have not been received. This Complaint is being returned NOT SERVED. SHERIFF COST: $28.00 November 16, 2009 SO ANSWERS, __.._ .. _. 3 R THOMAS KLINE, SHERIFF {c} Goui-~fiSiite S^enff. Te,e^,..=,ot1 Inr,_