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HomeMy WebLinkAbout10-2252PL F E!CE Burton Neil & Associates, P.C. By: Neil Sarker, Esquire ID. NO. 203465 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. CHAD E MOSER 1402 Bradley Drive, Apt. 314 Carlisle PA 17013-1248 Defendant 2010 APli -5 PH 3: 36 liNITY pr !1<,N/ /0 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 16 - a145a alw'li erm 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 REl ERENCE AND INFORMATION SERVICE Cumberland County Bar Assoc. 32 South Bedford Street 0 Carlisle, PA 17013 qa. co PD Al" Telephone No. 717-249-3166 or 800-990-9108 CL# 7a'7 lq C-30206 (?,* .13%;z Burton Neil & Associates, P.C. By: Neil Sarker, Esquire ID. NO. 203465 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. CHAD E MOSER 1402 Bradley Drive, Apt. 314 Carlisle PA 17013-1248 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. /0° j.1 C-;"' , 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 Chad E Moser, who resides at 1402 Bradley Drive, Apt. 314, Carlisle, 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 1897 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 $4,387.80 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 $4,387.80, and the costs of this action. Burton Neil & Associates, P.C. 01 By: Neil Sarker, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. 11 m m » 11, o a S V) A t N C S V »? h V J G A ? O a o ? E te' ` o x l? V ?^ 3 Tix?C A Q N a a, v, M N O m Ne O 04 uo < N ON go ?o J Y ? e E a 4 t. m a E rc ae N €N 3 >g _ '7 !W ° D a a 3 i da b N 88 Va V » it 1011 d < O 41a 41 O < a a? ° p a o aQ m ?N o r n CD m it Mn W z aair [aid --- ---- a-"' t ca+.i _----- Total New Balance: $4,397.80 Minimum Amount Due: $+,7.60 Payment Due Date: 09/01/2009 000000 MC 32 A 0 CHAD E MOSER 1402 BRADLEY DR APT 314 CARLISLE PA 17013-1248 E ) ) C i < I! as I W 2-C yysyy}} ?u aw; ?g :w Lo W M W ?FW m ? F IL I -K o g A M r Eaa O ? Z t O y O O Jr a P Q 5 ? Y Y? a e e N E S 2 r -° K C a e V, > w O O O O O v) M O N y, tD ? tow w c y a o3: E ? c-E a c 7 tl '? e7 0 g a + gdEE C ,0 dHmP O ° E co _ ?ca ? 7'd d N e p p ? U'N e d ,e W W.0 L? N ,o A , E M a, 5 E ?. E y c 0'0 a d d `>t1p a to to W C 1: J J 3 ?? m U dcor N p 0 ...C _ J u IE5 w N < dd Zd t d & Un) ?- > N C d d'?V „ M 'm L 'm o IN a3 2 u cntt A a__ _____ Detaa aM follow Payaleln ltWmetio» an reeese Maeaeasavosl.w.Chl Cards 0'. 50do6 Account u r. 1897 Amount Enclosed: Payment must be molved 6V S-.00 pal local tlma on the Dayment due data. CITI CARDS P.O. BOX 162564 COLUMBUS, OH 43218.2564 EXHIBIT Verification I, 61& wffn , am employed by Citicorp Credit Services, Inc. (USA) (hereafter CCSI), a subsidi 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. C-30206 Chad E Moser Account number ending in 1897 1000 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Edward L Schorpp Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY r ~,;r,.t~ of ~ nir,l;~ ~~ '~'-~, ~~ ~~ c. ~r~ Citibank (South Dakota) N.A. vs. Chad E. Moser Case Number 2010-2252 SHERIFF'S RETURN OF SERVICE 05/11/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Chad E. Moser, but was unable to locate him in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant Chad E. Moser. The Carlisle Postmaster advised Deputies Chad E. Moser's new address is 69 Channel Drive, Carlisle, PA 17013. However, this information was not received before the Complaint and Notice had expired. SHERIFF COST: $38.40 SO ANSWERS, ~^ May 11, 2010 RON R ANDERSON, SHERIFF ZOf~~1A~ i2 A~1 8~ 49 CtfM~s~.~.w•~ %;~~UN~Y Pc.Ntv'SYI_VAhiIA (ri Cour;'y5uib "CE:.~caT. li^~_ ~ Final Protection From Abuse Order No: 2010-2317 ~ 3 36 S3 Page 1 of 5 FINAL PROTECTION IN THE COURT OF COMMON PLEAS OF FROM ABUSE ORDER CUMBERLAND COUNTY, PENNSYLVANIA Extended Order ~ Amended Order NO. 2010-2317 1. PLAINTIFF ~ Stacey Lynn Ferry ~ ~ First Middle Last Suffix Plaintiff DOB Name(s) of All protected persons, including minor children and DOB. Chance David Johnson 10/7/1993 V. DEFENDANT David Allen Johnson First Middle Last Suffix Defendant's Address: 36 Town Mills Shippensburg PA 17257 CAUTION: WeaponInvolved Weapon Present on the Property Weapon Ordered Relinquished DEFENDANT ID ENTIFIERS DOB 8/31/1970 HEIGHT 5 ft. 8 m. SEX Male WEIGHT 220 RACE White EYES Green HAIR Brown SSN DRIVERS LICENSE # EXP DATE STATE The Court Hereby Finds: That it has jurisdiction over the parties and subject matter, and the Defendant has been provided with reasonable notice and opportunity to be heard. The Court Hereby Orders: ® Defendant shall not abuse, harass, stalk or threaten any of the above persons in any place where they might be found. © Except as provided in paragraph 4 of this order, Defendant shall not contact Plaintiff, or any other person protected under this order, by telephone or by any other means, including through third persons. © Additional findings of this order are set forth below. Order Effective Date May 11, 2010 Order Expiration Date November 11, 2010 NOTICE TO THE DEFENDANT VIOLATION OF THIS ORDER MAY RESULT IN YOUR ARREST ON THE CHARGE OF INDIRECT CRIMINAL CONTEMPT WHICH [S PUNISHABLE BY A FINE OF UP TO $1,000 AND/OR A JAIL SENTENCE OF UP TO SIX MONTHS. 23 PA.C.S.A. §6114. VIOLATION MAY ALSO SUBJECT YOU TO PROSECUTION AND CRIMINAL PENALTIES UNDER THE PENNSYLVANIA CRIMES CODE. A VIOLATION OF THIS ORDER MAY RESULT [N THE REVOCATION OF THE SAFEKEEPING PERMIT, WHICH W[LL REQUIRE THE IMMEDIATE RELINQUISHMENT OF YOUR FIREARMS, OTHER WEAPONS AND AMMUNITION TO THE SHERIFF. PLAINTIFF'S CONSENT TO CONTACT BY DEFENDANT SHALL NOT INVALIDATE THIS ORDER WHICH CAN ONLY BE MODIFIED BY FURTHER ORDER OF COURT. 23 Pa.C.S.A. § 6108(8). THIS ORDER IS ENFORCEABLE IN ALL FIFTY (50) STATES, THE DISTRICT OF COLUMBIA, TRIBAL LANDS, U.S. TERRITORIES AND THE COMMONWEALTH OF PUERTO R[CO UNDER THE VIOLENCE AGAINST WOMEN ACT, 18 U.S.C. §2265. IF YOU TRAVEL OUTSIDE OF THE STATE AND INTENTIONALLY VIOLATE THIS ORDER, YOU MAY BE SUBJECT TO FEDERAL CRIMINAL PROCEEDINGS UNDER THAT ACT. 18 U.S.C §§2261-2262. IF YOU POSSESS A FIREARM OR ANY AMMUNITION WHILE THIS ORDER IS IN EFFECT, YOU MAY BE CHARGED WITH A FEDERAL OFFENSE EVEN IF THIS PENNSYLVANIA ORDER DOES NOT EXPRESSLY PROHIBIT YOU FROM POSSESSING FIREARMS OR AMMUNITION. 18 U.S.C. §922(8x8). https://www.pfad.state.pa.us/PFADLive/finalorder.asp?FinalOrderID=175342&cmdMove... 5/11 /2010 Final Protection From Abuse Order No: 2010-2317 Page 2 of 5 Plaintiff or Protected Person(s) is/are: [X] spouse or former spouse of Defendant [X] parent of a child with Defendant [X] current or former sexual or intimate partner with Defendant [ ] child of Plaintiff [ ] child of Defendant [ ] family member related by blood (consanguinity) to Defendant [ ] family member related by marriage or affinity to Defendant [ ] sibling (person who shares parenthood) of Defendant Defendant was served in accordance with Pa. R.C.P. 1930.4 and provided notice of the time, date and location of the hearing scheduled in this matter. Appearances by Parties and/or Counsel: Plaintiff appeared personally and is represented by: Abraham Prozesky, Attorney at Law Defendant appeared personally and is unrepresented. AND NOW, this 11th Day of May, 2010 the court having jurisdiction over the parties and the subject-matter, it is ORDERED, ADJUDGED and DECREED as follows: This order is entered by agreement without an admission. Without regard as to how the order was entered, this is a final order of court subject to full enforcement pursuant to the Protection From Abuse Act. Plaintiffs request for a final protection order is granted. 1. Defendant shall not abuse, stalk, harass, threaten or attempt to use physical force that would reasonably be expected to cause bodily injury to Plaintiff or any other protected person in any place where they might be found. 2. Except as provided in Paragraph 4 of this order, Defendant is prohibited from having ANY CONTACT with Plaintiff either directly or indirectly, or any other person protected under this order, at any location, including but not limited to any contact at Plaintiff s or other protected party's school, business, or place of employment. 3. Except as provided in paragraph 4 of this order, Defendant shall not contact Plaintiff, either directly or indirectly, or any other person protected under this order, by telephone or by any other means, including through third persons. 4' Temporary custody of the minor children: https://www.pfad.state.pa.us/PFADLive/finalorder.asp?FinalOrderID=175342&cmdMove... 5/11 /2010 Final Protection From Abuse Order No: 2010-2317 1. Chance David Johnson shall be as follows: Page 3 of 5 . Primary physical custody of the minor child/ren is awarded to Plaintiff. . Defendant shall have no partial physical custody/visitation rights. . The Defendant consents, without admission, to the Protection From Abuse Order for a period of 6 (six) months. For the duration of this period, the custody order entered under case no. 06-3895 amended with this order. Plaintiff will have full physical primary physical custody of Chance Johnson, born October 7, 1993. Defendant is allowed to have non-threatening, non-harassing telephonic contact with Chance Johnson. THIS ORDER SUPERSEDES ANY PRIOR ORDER RELATING TO CHILD CUSTODY. 5. A certified copy of this Order shall be provided to the police department where Plaintiff resides and any other agency specified hereafter: Pa State Police Dept. 6. All provisions of this order shall expire in 6 months on November 11, 2010. NOTICE TO THE DEFENDANT VIOLATION OF THIS ORDER MAY RESULT IN YOUR ARREST ON THE CHARGE OF INDIRECT CRIMINAL CONTEMPT WHICH IS PUNISHABLE BY A FINE OF UP TO $1,000 AND/OR A JAIL SENTENCE OF UP TO SIX MONTHS. 23 PA.C.S.A. §6114. VIOLATION MAY ALSO SUBJECT YOU TO PROSECUTION AND CRIMINAL PENALTIES UNDER THE PENNSYLVANIA CRIMES CODE. A VIOLATION OF THIS ORDER MAY RESULT IN THE REVOCATION OF THE SAFEKEEPING PERMIT, WHICH WILL REQUIRE THE IMMEDIATE RELINQUISHMENT OF YOUR FIREARMS, OTHER WEAPONS AND AMMUNITION TO THE SHERIFF. PLAINTIFF'S CONSENT TO CONTACT BY DEFENDANT SHALL NOT INVALIDATE THIS ORDER WHICH CAN ONLY BE MODIFIED BY FURTHER ORDER OF COURT. 23 Pa.C.S.A. § 6108(g). THIS ORDER IS ENFORCEABLE IN ALL FIFTY (50) STATES, THE DISTRICT OF COLUMBIA, TRIBAL LANDS, U.S. TERRITORIES AND THE COMMONWEALTH OF PUERTO RICO UNDER THE VIOLENCE AGAINST WOMEN ACT, 18 U.S.C. §2265. IF YOU TRAVEL OUTSIDE OF THE STATE AND INTENTIONALLY VIOLATE THIS ORDER, YOU MAY BE SUBJECT TO FEDERAL CRIMINAL PROCEEDINGS UNDER THAT ACT. 18 U.S.C §§2261-2262. IF YOU POSSESS A FIREARM OR ANY AMMUNITION https://www.pfad.state.pa.us/PFADLive/finalorder.asp?FinalOrderID=175342&cmdMove... 5/ 11 /2010 Final Protection From Abuse Order No: 2010-2317 WHILE THIS ORDER IS IN EFFECT, YOU MAY BE CHARGED WITH A FEDERAL OFFENSE EVEN IF THIS PENNSYLVANIA ORDER DOES NOT EXPRESSLY PROHIBIT YOU FROM POSSESSING FIREARMS OR AMMUNITION. 18 U.S.C. §922(g)(8). Page 4 of 5 NOTICE TO SHERIFF, POLICE AND LAW ENFORCEMENT OFFICIALS The police and sheriff who have jurisdiction over Plaintiffs residence OR any location where a violation of this order occurs OR where Defendant may be located, shall enforce this order. The court shall have jurisdiction over any indirect criminal contempt proceeding, either in the county where the violation occurred or where this protective order was entered. An arrest for violation of paragraphs 1 through 4 of this order may be without warrant, based solely on probable cause, whether or not the violation is committed in the presence of the police or any sheriff. 23 Pa.C.S.A. §6113. Subsequent to an arrest, and without the necessity of a warrant, the police officer or sheriff shall seize all firearms, other weapons and ammunition in Defendant's possession that were used or threatened to be used during the violation of the protection order or during prior incidents of abuse and any other firearms in Defendant's possession. The Sheriff of Cumberland County shall maintain possession of the firearms, other weapons or ammunition until further order of this court. When Defendant is placed under arrest for violation of this order, Defendant shall be taken to the appropriate authority or authorities before whom Defendant is to be arraigned. A "Complaint for Indirect Criminal Contempt" shall then be completed and signed by the police officer, sheriff OR Plaintiff. Plaintiff s presence and signature are not required to file the complaint. If sufficient grounds for violation of this order are alleged, Defendant shall be ~ arr~gned, bond set, if appropriate and both parties given notice of the date of the _1 he~tng. ~= "~'~ ~ -: C".~ N _~ ~ y ~ ~ BY THE COURT: ~- CL ~ ?-~ ~. ., < ~ yXT --i ~.~ J W a ~ ~" M. L. Ebert, Jr. c°v U r Date Entered pursuant to the consent of plaintiff and defendant: J~ ~~ Plaintiffs Signature Defendant's Signature Distribution to: ~~~ /Yt~I~L Legal Services "T~ ~ . ~iQpz+fS~y' ~. ~1c3~Sa.J S~l~~~ https://www.pfad.state.pa.us/PFADLive/fina order.asp?FinalOrderID=175342&cmdMove... 5/11/2010 Final Protection From Abuse Order No: 2010-2317 Transmitted to PSP Page 5 of 5 https://www.pfad.state.pa.us/PFADLive/finalorder.asp?FinalOrderID=175342&cmdMove... 5/ 11 /2010 - • s+a«~ vs. ~na~a L n~• ~-f'Y ~~I~n TO~nSo~ 1 n fi)u ~G u~ f' Q ~ -"ins ~V4~-,~~ y Nu ~~ ~'~~ C~~n~ ~~ iu z3 i ~ C'-~v- ~ e ~ e'n!/~A n,~ ~~N S Erl~ Tb ~F/~ a~~ E~2 f~ 1~ e ~r1 l e~v~ U T CI aYt~~r f U,r ~ e~~ ~~ ~ ~~~Ya~~~o~ of (h.3 ~~'v~~ / ~ / e y~~~c~`'~l u'Y~~~ Gl~ J' ~ J1 l ~ Q me ~ u ~ U6 -- 3~9 iS t w~iTh t~~ s Or~P~. P(ain~ ~ ~ wi 11 h~~c ~~ ~~ Y,' ~~ ~~~~G~c~ C~1~~-~ o~" Chd1~~e TOhn~u~ hU ', Vl U t1-f ~, ~" ~Gt-r '~ ~ Yl v ~ -~l GI r G 5Jt tC. ~t 1'I U r1 i c. C U rl ~'01 CSI ~' n ~,-~ ~- Ch ~ T tip, i 0 7 ~i J Urlnsbs~ 1~ ~- u }~~ lj ~~~ ,~~ ~'r Morrow, Irene From: ra jnetoperations@state.pa.us Sent: Wednesday, May 12, 2010 11:23 AM To: Morrow, Irene Subject: PFAD Document Confirmation No.20102317 against JOHNSON, DAVID PFAD Document Confirmation No.20102317 against JOHNSON, DAVID filed by FERRY, STACEY RECORD ACCEPTED BY CLEAN: 2010-05-12 11:22:402 FILED-OFFICE , OF THE PROTHONOTARY 2012 JAM 17 AM 11: 21 CU PE NSYLVANIA TY Burton Neil & Associates, P.C. By: Neil Sarker, Esquire ID. NO. 203465 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 v. Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA NO. 10-2252 CIVIL TERM CHAD E MOSER 69 Channel Drive, Carlisle PA 17013 Defendant : CIVIL ACTION - LAW Praecipe to Reinstate To the Prothonotary: Please reinstate the Complaint. Burton Neil & Associates, P.C. By: Neil Sarker, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates is a debt collector. C-30206 ?T) 0N4 11311' *ab 9??9 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson t` i' 0' ur 6 ff:: Sheriff ir.? f tt. f'+U-?' f'f 0 f?0 T?? f?•x o??pt? oftr,n6rrf??A Jody S Smith Chief Deputy 2012 FEB 13 AM 9:15 Richard W Stewart CUMBERLAND COUNTY Solicitor ` M e :F THE `"?R'rf: PENNSYLVANIA Citibank (South Dakota) N.A. Case Number vs. 2010-2252 Chad E. Moser SHERIFF'S RETURN OF SERVICE 02/08/2012 11:52 AM - Shawn Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on February 8, 2012 at 1152 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Chad E. Moser, by making known unto himself personally, at 69 Channel Drive, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to him personally the said true and correct copy of the same. 1 ;1 H GUTS L, DEPUTY SHERIFF COST: $40.45 February 09, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF (ci GountySute Shell f, Te!eOSOtt, Inc CITIBANK (SOUTH DAKOTA), N.A. 701 East 60th Street N, Sioux Falls, SD 57117 Plaintiff V. CHAD E MOSER 69 Channel Drive Carlisle PA 17013 Defendant : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA 1) h? U a rv 10-2252 CIVIL TERM NO . ~ N r? CIVIL ACTION - LAW Praecipe for Default Judgment To the Prothonotary: ?r -? c.. 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 $4,387.80 $4,387.80 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 ENTE D AND D*MA A SED AS APPVE. NOTICE GI PA.R.N.P. 236 Protary Burton Neil & Assoc' es, P.C. By: Neil Sarker, Esquire Attorney for Plaintiff I.D. NO. 203465 1060 Andrew Drive, Suite 170 West Chester, PA 19380 The law firm of Burton Neil & Associates is a debt collector. 5-D pet 11?31? C-30206 / 221 CITIBANK (SOLITH DAKOTA), N.A. IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 10-2252 CIVIL TERM CHAD E MOSER Defendant : CIVIL ACTION - LAW TO: Chad E Moser 69 Channel Drive Carlisle PA 17013 DATE OF NOTICE: March 06, 2012 IMPORTANT NOTICE C-30206 / 265 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 In making this communication, we advise our office is a debt collector. Burton Neil & Associates, P.C By: / Neil Sarker, Esquire Attorney for Plaintiff Identification No. 203465 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 Burton Neil & Associates, P.C. By: Neil Sarker, Esquire ID. NO. 203465 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 Plaintiff V. CHAD E MOSER CUMBERLAND COUNTY, PENNSYLVANIA : NO. 10-2252 CIVIL TERM Defendant : 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 P 1 6t? ?l1 / Prothono By: Depu ` If you have any questions concerning the above, please contact: Neil Sarker, 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.