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Home My WebLink About09-8441f , Burton Neil & Associates, P.C. By: Robert J. Kane, Esquire ID. NO. 209794 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. JANE ZULLINGER IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. (A- 8y4 ( LivilTerm 105 Fogelsanger Road, Shippensburg Pa 17257-9704 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-29025 Burton Neil & Associates, P.C. By: Robert J. Kane, Esquire ID. NO. 209794 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 NO. JANE ZULLINGER 105 Fogelsanger Road, Shippensburg Pa 17257-9704 Defendant : CIVIL ACTION - LAW Complaint 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 Jane Zullinger, who resides at 105 Fogelsanger Road, Shippensburg, 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 credit card with account number ending in 5046 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 $2,075.36 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 $2,075.36, and the costs of this action. Burton Neil & Associates, P.C. By: Robe f J. ane, Esquire Atto ey or Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. 10 ?a 10 C tf1 . O ISO N a o N M r ! + ` X 33 O ° mvlrtr V ti Ti • a ? G rl rr C 0= ?a a Et a ? P N ? N W . Q QQ ?? N Q Q ?N Qj C N OO 11RI N M N C c N 7 ? O < N d C N J U 9 C< i Qqj 'S ' y 0 - :t c 2 E_ O N O \ /i J O , x > N M V) jib WW _ __ _ :maid pail __ __- chK k n ^ ?_ Total New Balance: MWmum Amount Due: Payment Due Date: 08/17/!009 i? W 2 Z? r? .g +Q E 1 A. ?O rf w O • N N M T a Q O 0 0 O M CO ?Z ? E W n 30 z a: ?EEZ Z YY d? 0 Ny O tM M T Vyl C M C le N 3 d r ?? a t y V CL Ca V j ?g W> d ?0 co T Vr N E e d? N y 2 e 9 N V d E 0 0 y ? J N O M9 CM X M t N > C V W w d ?0 O LO w C N Q >- 00 - D.twh aw !0160. wymw a.huOAM on rwwo me. da wAkwCltl Cards d;? :7 46 / n Peym.M rt.nt M ntMnd Oy 5:00 PM loe.lt.n. on tM.aym.M W. cw. 000000 PW 32 A 0 JANE MONGER 105 FOGELSANGER RD CITI ARDS SHIPPENSBURGPA17257.9704 CP.O. OX1564 OL MBUS?OH43218-2564 EXHIBIT c N ? ?P• ?IV 4 T Va,u? EN A L r" .N A y 'O y d4.N d Vs N'V ` N O ?6 a?ya aaro >s aro? V N E 7 y F- Tn A m w 9?E G q w ? 0. 41 .NS.. Y E G A A V ? Y ?d9 T N MSaC c?N t N 000 z ?5?c u Ra 7 ? V?> N A zg r4yR Is Verification I Leole Phenix ; am employed by Citicorp Credit Services, Inc. (USA) (hereafter CCSI), a subsidiary of plaintiff, Citibank (South Dakota), N.A. CCSI is a service provider for plaintiff in that it services credit card accounts owned by plaintiff. I am authorized to make this verification on behalf of plaintiff. The statements of facts set forth in the complaint are true and correct upon my information and belief and are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. A Sign ff (w e C-29025 Jane Zullinger Account number ending in 5046 1000 0 Orm 20 DEC .1 ph i=Z3 "Mawle x s.60 po ATM ev-'v 4pssso "y (p37 CITIBANK (SOUTH DAKOTA), N.A. 701 East 60th Street N, Sioux Falls, SD 57117 Plaintiff V. JANE ZULLINGER 105 Fogelsanger Road Shippensburg PA 17257-9704 Defendant To the Prothonotary: IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 09-8441 CIVIL TERM : CIVIL ACTION - LAW Praecipe for Default Judgment _10 c, C__ °i N 0 N .p- C?D 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: $2,075.36 TOTAL $2,075.36 r? mr rn no _--I C7 -n C' M v 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 AND DAMAGES ASSESSED AS ABOVE. 36 Neil ?r, Associates,,P.C. Daniel A. Payne?quire Attorney for Plai iff I.D. NO. 202294 1060 Andrew Drive, Suite 170 West Chester, PA 19380 The law firm of Burton Neil & Associates is a debt collector. C-29025 G?k ?lU. m Pcl o? Ck..d?`? 3Q33 CITIBANK (SOUTH DAKOTA), N.A. : IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 09-8441 CIVIL, TERM JANE ZULLINGER Defendant : CIVIL ACTION - LAW TO: Jane Zullinger 105 Fogelsanger Road Shippensburg PA 17257-9704 DATE OF NOTICE: December 30, 2010 IMPORTANT NOTICE C-29025 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 paper to your lawyer at once. If you do not have a lawyer, go to or telephone the office 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 REFERENCE AND INFORMATION SERVICE Cumberland County Bar Assoc. 32 South Bedford Street Carlisle, PA 17013 Telephone No. 717-249-3166 or 800-990-9108 P.C. In making this communication, we advise our office is a debt collector. iorn eA A V , 4 ?J? l A.Payne, Esqun ey for Plaintiff Identification No. 202294 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 Burton Neil & Associates, P.C. By: Daniel A. Payne, Esquire ID. NO. 202294 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA), N.A. Plaintiff V. JANE ZULLINGER Defendant IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-8441 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 1 I If you have any questions concerning the at Daniel A. Payne, 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. IN THE COURT OF COMMON PLEAS JUDICIAL DISTRICT CUMBERLAND COUNTY BRANCH, PENNSYLVANIA Citibank (South Dakota) N.A. vs. Jane Zullinger Civil Division Case No: 09-8441 SUGGESTION OF BANKRUPTCY To Prothonotary: r? C_ cnr-- M o, zC) - oc; ?? .. ?M ? rv Please note upon the record that Jane L. Zullinger, the defendant in the above- captioned action and James W. Zullinger, filed a Voluntary Petition in Bankruptcy with the United States Bankruptcy Court for the Middle District of Pennsylvania at Harrisburg, PA, on, at July 1, 2011 at 12:11 o'clock P.M., which petition was docketed to 1-1 1-04744-RNO. PURSUANT TO THE PROVISIONS OF 11 U.S.C. §362(A), AN AUTOMATIC STAY IS IN EFFECT FOR ALL PROCEEDINGS INVOLVING THE ABOVE-NAMED DEFENDANT. CERTIFICATE OF SERVICE I, Richard L. Bushman, Esquire, attorney for the above captioned defendant in the bankruptcy proceeding before the United States Bankruptcy Court for the Middle District of Pennsylvania, do hereby certify that on the date set forth below I served the within "Suggestion of Bankruptcy" by depositing a copy of the same in the United States Mail, postage prepaid, at Spring Run, Pennsylvania, addressed to the parties or attorney's of record as follows: Citibank Citi Burton, Neil & Associates P.C. 701 East 601h St. N. PO Box 6241 1060 Andrew Dr., Ste. 170 Sioux Falls, SD 57117 Sioux Falls, SD 57117 West Chester, PA 19380 Date: July 5, 2011 r S i ohJ mag_ k, - L1__U_ Richard L. Bushman, Esquire (TLS) 16767 Path Valley Road P.O. Box 51 Spring Run, PA 17262-0051 [717] 349-7657 USBC PAM - LIVE - VERSION 3.4 United States Bankruptcy Court Middle District of Pennsylvania Notice of Bankruptcy Case Filing A bankruptcy case concerning the debtor(s) listed below was filed under Chapter 7 of the United States Bankruptcy Code, entered on 07/01/2011 at 12:11 PM and filed on 07/01/2011. James W. Zullinger 105 Fogelsonger Rd Shippensburg, PA 17257 717-532-7122 SSN / ITIN: xxx-xx-8230 aka Jim William Zullinger Jane L. Zullinger 105 Fogelsonger Rd Shippensburg, PA 17257 717-532-7122 SSN / ITIN: xxx-xx-9257 aka Jane Louise Zullinger aka Jane M. Zullinger The case was filed by the debtor's attorney: Richard L. Bushman PO Box 51 16767 Path Valley Road Spring Run, PA 17262-0051 717 349-7657 The bankruptcy trustee is: Leon P. Haller (Trustee) Purcell, Krug and Haller 1719 North Front Street Harrisburg, PA 17102 717 234-4178 The case was assigned case number 1: 11 -bk-04744-RNO to Judge Robert N Opel. Page 1 of 2 In most instances, the filing of the bankruptcy case automatically stays certain collection and other actions against the debtor and the debtor's property. Under certain circumstances, the stay may be limited to 30 days or not exist at all, although the debtor can request the court to extend or impose a stay. If you attempt to collect a debt or take other action in violation of the Bankruptcy Code, you may be penalized. Consult a lawyer to determine your rights in this case. If you would like to view the bankruptcy petition and other documents filed by the debtor, they are available at our Internet home page http://ecf.pamb.uscourts.gov/ or at the Clerk's Office, U.S. Bankruptcy Court, Ronald Reagan Federal Building, PO Box 908, Harrisburg, PA 17108. You may be a creditor of the debtor. If so, you will receive an additional notice from the court setting https:Hecf.pamb.uscourts.gov/cgi-bin/NoticeOfFiling.pl?213167 7/4/2011 IN THE UNITED STATES BANKRUPTCY COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA IN RE: James W. Zullinger a/k/a Jim William Zullinger Jane L. Zullinger a/k/a Jane Lousie Zullinger Debtors James W. Zullinger a/k/a Jim William Zullinger Jane L. Zullinger a/k/a Jane Lousie Zullinger Movants vs. Citibank (South Dakota), NA Respondent CHAPTER 7 Xm a rri- x? ,a o , X C n Case No. 1 -11 -BK-04744-RNC ORDER OF COURT GRANTING JUDICIAL JUDGMENT LIEN AVOIDANCE Motion for Judicial Judgment Lien Avoidance having been made on July 27th , 2011, and an Order of Court entered, directing service of said Motion, and a certificate of service having been filed with the Clerk of this court, pursuant to said Order, and no answer having been filed by the Respondent, now, therefore, IT IS ORDERED that Respondent's judicial lien [docketed to Cumberland County Court of Common Pleas # 09-8441 CIVIL TERM] upon the real property of Movant located at 105 Fogelsonger Rd., Shippensburg, PA and more fully described in Cumberland County Record Book S21, Page 417, and the household goods and furnishings is declared invalid under §522(f)(1) of the United States Bankruptcy Code. IT IS FURTHER ORDERED that the Respondent execute any releases necessary to clear such liens from any public record and the filing of a copy of this Order with the Prothonotary of Cumberland County shall serve as a release of the lien of said judgment upon the real and personal property of Movants above described. By the Court, Dated: November 8, 2011 Robert N. Opel, II, Bankruptcy Judge (RQ 8. M QA B 7APMA e* f0(16 t?4l`-a&q'f4? Case 1:11-bk-04744-RNO Doc 27 Filed 11 /08/11 Entered 11 /08/11 09:32:04 Desc Main Document Page 1 of 1