HomeMy WebLinkAbout10-3792Burton Neil & Associates, P.C.
By: Derek C. Blasker, Esquire ID. NO. 202150
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 CUMBERLAND COUNTY, PENNSYLVANIA
V.
VICTORIA J HOHNEY : NO.
184 Virginia Avenue
Carlisle PA 17013-1067
Defendant CIVIL ACTION -LAW
Complaint - Notice
You have been sued in court. If you wish to defend against the claims set i:orth 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
C-33329
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2010 J'J i -7 Ph 3: ?u
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IN THE COURT OF COMMON PLEAS
Carlisle, PA 17013
Telephone No. 717-249-3166 or 800-990-9108
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Burton Neil & Associates, P.C.
By: Derek C. Blasker, Esquire ID. NO. 202150
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
V.
VICTORIA J HOHNEY
184 Virginia Avenue
Carlisle PA 17013-1067
IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
NO.
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 Victoria J Hohney, who resides at 184 Virginia Avenue, 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(n) AT&T
Universal credit card with account number ending in 2045 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
Plaintiff
Defendant
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 $7,325.77 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 $7,325.77, and
the costs of this action.
Burton $618# 4sociates, P.C.
By:
DZrek C.?Blasker, Esquire
Attorney for Plaintiff
The law firm of Burton Neil & Associates, P.C. is a debt collector.
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dele [eitl -- ----- ertount Geid ___ ___--check A _______ Detach and follow
payment instructions on reverse
Mokecheck payable te:AT&T Universal Card
New Balance:
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Account Number:
$7,325.77 X045
Minimum Payment Due: `-' Amount Enclosed:
-
$7,325.77
Payment Due Date:
0105/2070 Payment must be received by 5:00 PM
local time on the payment due date.
000000 MC 32 A 0
VICTORIA J HOHNEY
184 VIRGINIA AVE AT&T UNIVERSAL CARD
CARLISLE PA 17013-1067 P.O. BOX 182564
COLUMBUS, OH 43218-2564
EXHIBIT_______4
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Verification
Marv E. C.r1im
I,
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.
11 1 C &-??
Signature
C-33329
Victoria J Hohney
Account number ending in 2045
1000
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
SOIICItOr
~~,~,,tit~ of ~~anrb~rt,~~~
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QFPiGE CJF THE St+ERIFF
~~~~ ~ "l
2010 JE1N 21 ~ g` 0~+
Ct.~B
Citibank (South Dakota) N.A. Case Number
vs. 2010-3792
Victoria J. Hohney
SHERIFF'S RETURN OF SERVICE
06/17/2010 08:47 PM -Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on June 17,
2010 at 2045 hours, he served a true copy of the within Complaint and Notice, upon the within named
defendant, to wit: Victoria J. Hohney, by making known unto herself personally, at 184 Virginia Avenue,
Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to her
personally the said true and correct copy of the same.
TIM BLAO'K. DEPUTY
SHERIFF COST: $33.40
June 18, 2010
SO ANSWERS,
RONI~S~ R ANDERSON, SHERIFF
(c) CountySuite Shenft. Telaosoft. Inc.
CITIBANK (SOUTH DAKOTA), N.A.
701 East 60th Street N, Sioux Falls, SD 57117
Plaintiff
v.
VICTORIA J HOHNEY
184 Virginia Avenue
Carlisle PA 17013-1067
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYI~JA1~
~~
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NO. 10-3 792-CNIL TERM
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CIVIL ACTION -LAW '~- W ~r.'
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- Praecipe for Default Judgment
To the Prothonotary:
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
$7,325.77
$7,325.77
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.
NOT GIVEN UND PA.R.CIV.P. 236
c. )
Pro rP ofl-ionotary
Burton lei Associates, P.C.
By:
De C. Blasker, Esquire
Atto ey for Plaintiff
I.D. 0.202150
1060 Andrew Drive, Suite 170
West Chester, PA 19380
The law firm of Burton Neil & Associates is a debt collector.
C-33329
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C# 800156
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C-33329
CTTIBANK {SOUTH DAKOTA), N.A. : IN THE COURT OF COMMON PLEAS
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 10-3792-CIV1L TERM
VICTORIA J HOHNEY
Defendant :CIVIL ACTION -LAW
TO: Victoria J Hohney
184 Virginia Avenue
Carlisle PA 17013-1067
DATE OF NOTICE: July 13, 2010
IMPORTANT NOTIC£
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-~0-9108
In making this communication, we advise our office is a
debt collector.
Burton I~ei~ ~ Associates, P.C.
By:_
Derek C. sker, Esquire
Attorney for Plaintiff
Identification No. 202150
1060 Andrew Drive, Suite 170
West Chester, PA 19380
(610) 696-2120
Burton Neil & Associates, P.C.
By: Derek C. Blasker, Esquire ID. N0.202150
1060 Andrew Drive, Suite 170
West Chester, PA 19380
610-696-2120
Attorney for Plaintiff
CITIBANK (SOUTH DAKOTA), N.A.
Plaintiff
v.
VICTORIA J HOHNEY
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 10-3792-CNIL TERM
CNIL ACTION -LAW
Rule of Civil Procedure N0.236 (Revised)
Notice is given that a JUDGMENT in the above captioned matter has been entered
against you on ~f~.~/D
Prothono
By: ~
putt'
If you have any questions concerning the above, please contact:
Derek C. Blasker, 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.