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HomeMy WebLinkAbout10-1118FILED l 2010 FEB 16 PM 2, 09 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 CITIBANK (SOUTH DAKOTA), N.A. 701 East 60th Street N Sioux Falls, SD 57117 IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. ROBERT A BECKER : NO. u L? 1093 W. Trindle Road, Mechanicsburg PA 17055-4515 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 q92 •U O ? ?! Carlisle, PA 17013 CK--4/ & 9 4VS. Telephone No. 717-249-3166 or 800-990-9108 C-32400 12-*- a3742E 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 CITIBANK (SOUTH DAKOTA), N.A. IN THE COURT OF COMMON PLEAS 701 East 60th Street N Sioux Falls, SD 57117 Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. ROBERT A BECKER NO. 1093 W. Trindle Road, Mechanicsburg PA 17055-4515 Defendant 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 Robert A Becker, who resides at 1093 W. Trindle Road, Mechanicsburg, 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 8155 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 $8,755.13 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 $8,755.13, and the costs of this action. Burton Non &]Msbciates. P.C. By: D. Weinstein, Esquire nev for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. I]- a,. SNP ^ ? f(yyy Y ?Gf CY H m?m O V ?y 10 14 d? A O. O N N S N ?( O O O O H d d d ? d ? y X88 O N d ? O i I ILy r TO S. N c N al f c O < N ?. N O c o c o c o c o c o c N ` N c f N 0 14 F M N A 41 J/? Y F N 0 0 10 to 0 N i N f N W: i ! ? a W Z 11 ? O O O O O M O M wl t R if N M El ? C.- V Ell e S ? no o' n N ?C c opt ?. G N m 13 6 ??v d o ? " iGy oo tIITS ' 01i V q. ? O O G E C b E? a> 111 1 c r C J J p O 4V)(Ti Y O + 0 ° ?O \ • • v d t 1 y ? ..? ? a + N A - J {? u gr > v $ 21 y o u «•`- Nee 3 0 '? ~ N ?/?? > 7d > _ aEve Z°no 8 N d O ~? H < U (,)12, N SNOT. W# WIf amaml pay ? Ct*C1 • _ IN" iM arm egwa rrr..a.ll. •nfeloa ma*-moanyawelAT&T Universal Card Total Now Balance: sk"11113 MWmum Amount Due: f?•71ti.13 Payment Due Date 68AGAN" 000000 MC 32 A O ROBERT A BECKER 16476 BEACH BLVDD WESTMINSTER CA 92663 C?aco Ace r. 155 nt Endow IMPM AT&T UNIVERSAL CARD PROCESSING CENTER DES MOINES, IA50363-0000 EXHIBIT ? 1? Verification Mary E. Crum 1> , 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. Signature ?. C-32400 Robert A Becker Account number ending in 8155 1000 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy °~au' pt ~tr~nbn~~~~+9 ~~; ~.'r ,1;'r 3 .~ ~ . ~- ~'r. t~ TH~AAIi' 20 { 0 KAR - 3 All ~~ b Z Edward L Schorpp Solicitor £}F~ is E ~tF 'r: -: '." »RIFF ~~~~ Citibank (South Dakota) N.A. vs. Robert A. Becker Case Number 2010-1118 SHERIFF'S RETURN OF SERVICE 02/23/2010 03:26 PM -Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on February 23, 2010 at 1527 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Robert A. Becker, by making known unto Linda Becker, Mother of defendant at 1093 W. Trindle Road, Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $37.00 February 25, 2010 SO ANSWERS, R R ANDERSON, SHERIFF Deputy Sheriff (c CouttiySufte Srer;ff. Teieosoft. Inr,. a___„Sep. 10: 2013 12:28PM No. 1919 P. 2 CITIBANK(SOUTH DAKOTA),N.A. : IN THE COURT OF COMMON PLEAS 701 East 60th Street N,Sioux Falls, SI) 57117 Plaintiff : CUMBERLAND COUNTY,PENNSYLVANIA V. : NO. 10-1118 CIVIL TERM ROBERT A BECKER 1093 W.Trindle Road Mechanicsburg PA 17055-4515 Defendant :CIVIL ACTION-LAW n ti Praeeipe for Default Judgment r To the Prothonotary: r. Please enter judgment by default for want of an answer in the above case iaffvor&the plaintiff and against the defendant, and assess damages as follows: Principal: $8,755.13 ,.,,; TOTAL $8,755.13 `- 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)(l)(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 Burton Neil&Associates,P.C. AND DAMAGES ASSESSED AS ABOVE. NOTICE GIVEN UNDER PA.R.CIV.P.236 By: Yale D. Weinstein,Esquire Attorney for Plaintiff Pro Prothonotary I.D.NO. 89678 1060 Andrew Drive, Suite 170 West Chester,PA 19380 The law firm of Burton Neil&Associates is a debt collector. C-32400 po Ayr/ e 1ato85 0-3(4033'1 Sep. 10. 2013 3: 12PM No. 1930 P. 2 C-32400 CJTh3ANK(SOUTH DAKOTA),N.A. : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY,PENNSYLVANIA v. : NO. 10-1118 CIVIL TERM ROBERT A BECKER Defendant : CIVIL ACTION-LAW Notice of Intention to File Praecipe for Default Judgment TO: Robert A Becker 1093 W.Trindle Road Mechanicsburg PA 17055-4515 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(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:March 18,2010 B 'In Nei • ssociates,P.C. :y: Yale Df e ATV,Esquire Attom for ' aintiff Identi'cation No. 89678 1060 Andrew Drive,Suite 170 West Chester,PA 19380 In making this communication,we advise our office is a (610)696-2120 debt collector.