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Home My WebLink About10-2743Burton Neil & Associates, P.C. By: Yale D. Weinstein, Esquire 113. NO. 89678 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 Attorney for Plaintiff US BANK NATIONAL ASSOCIATION ND dba Elan Financial Services 9321 Olive Boulevard St. Louis, MO 63132 Plaintiff V. STEPHEN J SCHUBACK 312 Bridge Street New Cumberland PA 17070-2166 Defendant a pP? 23 p? ?: t a Zoi 1 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 10 -,2q45 0,,y; I-Texm 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. s 32 South Bedford Street 49a .oo P U f4 Tl `F Carlisle, PA 17013 e,01 73 /c2,9 Telephone No. 717-249-3166 or 800-990-9108 0 aglaq I 133109 Burton Neil & Associates, P.C. B • Yale D Weinstein Esquire ID. NO. 89678 Y• 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 Attorney for Plaintiff US BANK NATIONAL ASSOCIATION ND dba Elan Financial Services 9321 Olive Boulevard St. Louis, MO 63132 Plaintiff V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. STEPHEN J SCHUBACK 312 Bridge Street New Cumberland PA 17070-2166 Defendant CIVIL ACTION - LAW Complaint 1. Plaintiff is US BANK NATIONAL ASSOCIATION ND dba Elan Financial Services, with place of business located at 9321 Olive Boulevard, St. Louis, Missouri. 2. Defendant is Stephen J Schuback, who resides at 312 Bridge Street, New Cumberland, 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) Fulton Bank credit card with account number ending in 6909 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. I he 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 $25,415.78 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 $25,415.78, and the costs of this action. Burton N(I:i1 Mkiociates, P.C. stein, Esquire i for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt RECEIVED FEB 1 0 2010 FultmBank. CONFIDENTIAL LISTENING IS JUST THE BEGINNING.` AugustStaterrtent for activity from Jul. 21, 2009 through Aug. 19, 2009 inquiries: l-866 784-2137 STEPHEN J SCHUSACK ELN 7a , t Page 1 of 2 - - ----------- Aeth?tty Summary Credit and Payment Information Previous Balance ................... ..... $24,820.90 oo $0 Credit Una ................................................... Available Credit........................................... $20 .000.00 None Payments and Credits ......................... Purchases, Advances 8 Other Debits • $38.00 Minimum Payment Due (Current Month)... .. t Due (Past Due) P $644.00 $4,740.00 FINANCE CHARGES New Balance ...................................... $555.88 $25,416.78 ......... aymen Minimum Total New Minimwn Payment Due......... $5,584.00 2009 Se 13 Payment Due Dade .....» ..................... p. , To reduoe or avW paying edcft ief rmance charges on Your purchase balance, pay the total new balenoe of $25,415.7& by 0911M. Any cash balance or balance trensW bafence wiN eWkwe to 9owde deity Infereet W W the date your payment is recshvd. ......_.__..__.._... niFi#Y141.7AllIIITKVfa!nsrr.7:.z?.r?-r..:.-:a.-+?r?... -... .......... LATE FEE - PAYMENT DUE ON 08114 ............................. 39.00 Purchases, 08114 Advances, Debits Finance Charges 08119 -FINANCE CHARGE-INTEREST ................. ................ 555.88 y 00 $0.00 0.074630% VARME $0.00 $0 • 27.24% 0.00% N BALANCE TRA"WER PURCHASES . $25,413.78 $24.828.70 0.074630% VARLME $655.88 00 LE $0 27.24% 27.24% Y 00% N 24% 0 27 ADVANCES . $040 $0.00 0.074630% VARIAB . . ?•?.. n.tr c .:+ `:.:.;. ..:a,rR,.•:c 51 V" . t.• `Eea s ` € 2: ^• ::.,: x• t ; ;% ..... :^;;ri; S' ..J.S::.1 .8 • 'F:`, =,K- ?._.r . ' This year Statement to Daft De$fxipti0ll of Activity 0 0 Net Rewards Poir4c,. ... ............................................................................................. 0 69 28 4 5 NET REWARDS POINTS CONVERSIQN ............................................................. 0 .4 9 28 Total ................................................ , Continued on Next Page Please detach end send OWPon wr7h check Payette to Cardmernber Sewke Fultmfkfl*_ LISTENING IS JUST THE BEGINNING.- - 7o•ahange youraddren or for Cardmember Service please call: 1.866-794-2137 EVery Noa/i EVery Day1 Your Account Number tr 69a9 Total Now eakr"-,• $25,415.78 uko'nwe Pertmd D„e $5,584.00 . s'64 :7C Sep. 13, 2009 , 000035743 1 AT 0.357 106481293807597 P Carcbinember Service STEPHEN J SCHUBACK P.O. BOX 790406 N1EW CCUMBEKNO PA 17070-2166 5t. Louis, Ma 63179-0408 11111'11'1111"Illllillllll,hilyl'11111"tllllirlhllllllll'lll t„? t t,. ,I .I 4, N IIII t . l Il Ili I I I 11 h ll lti I ntil 111111111111 Jill I EXHIBIT__? Iult mRank LISTENING IS JUST THE BEGINNING.' August Statement for activity from Jul. 21, 2009 through Aug. 19, 2009 Inquiries: 1-866-794-2137 STEPHEN J SCHUBACK ELN 78 11 Page 2 of 2 For rewards program inquiries and redemption information call 80G 6574= 24 hours a day, 7 days a week'or visit us at www.tultonbw*.oom to aCCM your account tl,k?ti?t:a;??.:?rs?. `•:;? ,,...,;,,.... ?. ...,,,. If you have not made arrangements with us for payment of your aastdue amount, lers talk about your situation. Then: must be a way to resolve this problem. We urge you to call us at 1-800-2364188. Each time you or a third party an your behalf, pays your bill personal check, you authorize. us to convert that payment into an electronic debt, If the check is processed ilectrorr Ically, the checking account will be debited for the amount on the check and the debit will appear on your account state nen If you have any questions, please contact us at the Inquiries phone number located an this statement. Y? By Telephone: Send In to: Send Payments to: visit ourweMall: Every Hourt Every Day[ cardrnen Voice: 1416&794-2137 P.O. Boor 6354 P.O. Box 790408 www.ktlonbw*.com TDO: 1-086-352-6458 Fargo, NO 58125-6364 SL Louts, MO 63179-0408 Fax 1•$68•$16.1750 End of Statement Verification L"*MA DUDA Remvery Manager is (Name of authorized representative) (Title or Position) for, US BANK NATIONAL ASSOCIATION ND dba Elan Financial Services, the within Plaintiff in this action, and that the statements of fact made in the foregoing Complaint are true and correct to the best of the undersigned verifier's 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 authorities. Date: f ame 133149 Stephen J Schuback Account number ending in 6909 1317 FdL~:I~-~a :=~~F 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 US BANK NATIONAL ASSOCIATION ND dba Elan Financial Services Plaintiff v. STEPHEN J SCHUBACK Defendant Fk~+ ti~ ~'~V,'-~4~!A IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 10-2743 CIVIL TERM CIVIL ACTION -LAW Praecipe to Discontinue To the Prothonotary: Kindly discontinue the above-captioned action Bur~6n Neil By: Y. The law firm of Burton Neil & Associates is a debt collector. P.C. Einstein, Esquire for Plaintiff 133109