HomeMy WebLinkAbout10-4263?{'?FILED-0, ' 0' -r
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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
Plaintiff
V.
ROBERT S GOODRICH
1611 English Drive
Mechanicsburg PA 170550747
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 1401k( ,03 Civil
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 CS
C-33893 Aol,00 PO ArM
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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 S GOODRICH
1611 English Drive
Mechanicsburg PA 170550747
NO.
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 S Goodrich, who resides at 1611 English Drive, 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 credit card with
account number ending in 0472 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 $28,281.20 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 $28,281.20, and
the costs of this action.
Burton N4 & AisodXes, P.C.
By:
Yale P/Weinstein, Esquire
Atto v for Plaintiff
The law firm of Burton Neil & Associates, P.C. is a debt
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Detach and fellow payment instructions on revarse
Make checkpayableto:CIti Lards
A count Nu r-
472
Amount Enclosed:
payment must be received by 5:00 PM
I-at time on the payment due date.
PO BOX 747 CITI CARDS
MECHAN ICSBU RG PA 17055-0747 P.O. BOX 182564
COLUMBUS, OH43218-2564
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If r .3 E2- tAa fl<
date Vail amounl fs,id check k
New Balance:
$28,281.20
Minimum Payment Due:
$28,281.20
Payment Due Date:
12/30/2009
000000 MC 32 A 0
ROBERT S GOODRICH
EXHIBIT
Verification
Marv F
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.
i dkkw r" -
Signature
C-33893
Robert S Goodrich
Account number ending in 0472
1000
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
SHERIFFI
Citibank (South Dakota) N.A.
vs.
Robert S. Goodrich
07/14/2010 07:29 PM -Shawn Han
2010 at 1920 hours, he
defendant, to wit: Robe
Road, Mechanicsburg,
handing to him persona
S OFFICE OF CUMBERLAND COUNTY
Fly `~~ ) ,°~
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~~~ICiE t F r~sE SRIF~ 4" ~
Case Number
2010-4263
HERIFF'S RETURN OF SERVICE
son, Deputy Sheriff, who being duly sworn according to law, states that on July 14
served a true copy of the within Complaint and Notice, upon the within named
t S. Goodrich, by making known unto himself p rsonall , a 1595 W. Lisburn
:umberland County, Pennsylvania 17055 its c ~ts rid a the same time
ly the said true and correct copy of the same.
WN HARRISON, DEPUTY
SHERIFF COST: $46.00
July 15, 2010
SO ANSWERS,
"-.
RON R ANDERSON, SHERIFF
(c) CountySuite Sheriff, Teleosoft. Inc.
I
CITIBANK (SOUTH DAKOTA), N.A.
701 East 60th Street N, Sioux Falls, SD 57117
Plaintiff
V.
ROBERT S GOODRICH
1595 W Lisburn Road
Mechanicsburg PA 17055-5878
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
c?
to-4a?3 ?
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NO. i@ Q64civil terns
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CIVIL ACTION - LAW 50
Praecipe for Default Judgment rn
To the Prothonotary:
?Y'} r
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
$28,281.20
$28,281.20
Understanding that false statements herein made are subject to penalty under 18 Pa. C.S. §
4904 relating to unworn 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 o information
received from the defendant and/or the Department of Defense website. /) 7
JUDGMENT BY DEFAULT ENTERED Burton
AND DAMAGES ASSESSED AS ABOVE.
NOTI GIVEN UNDER PA.R.CIV.P. 236 By:?_
Pro rothonot
9//-S10
The law firm of Burton Neil & Associates is a debt collector.
C-33893
P.C.
Y e D. Weinstein, Esquire
A S,
mey for Plaintiff
o
. NO. 89678
7ED
1060 Andrew Drive, Suite 170
West Chester, PA 19380
414.00 PO ATTY
e-'83cDia
0 (vela!
CITIBANK (SOUTH DAKOTA), N.A.
Plaintiff
V.
ROBERT S GOODRICH
Defendant
TO: Robert S Goodrich
1595 W Lisburn Road
Mechanicsburg PA I7055-5878
DATE OF NOTICE: August 20, 2010
IN THE COURT OF COMMON PLEAS
C-33893
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 10-4264 civil term
: CIVIL ACTION - LAW
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 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.
Bu Neil & Associate///s''',???P.C.
By:
Daniel A. Payne, Esquire
Attorney for Plaintiff
Identification No. 202294
1060 Andrew Drive, Suite 170
West Chester, PA 19380
(610) 696-2120
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.
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
V. tD-42103
NO. i 0-4264 civil term
ROBERT S GOODRICH
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 4 11.31 to
Prothonotary
By:
If you have any questions concerning the above, please
Yale D. Weinstein, Esquire
Attorney for Party Filing
1060 Andrew Drive, Suite 170
West Chester, PA 19380
Phone: 610-696-2120
C
The law firm of Burton Neil & Associates is a debt collector.
1N THE COURT OF COMMOM PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Citibank (South Dakota), N.A. - ~ ~~ =
Plaintiff, Case No.: 10-4263 -_. -'
v. --
_~___
Robert S. Goodrich
Defendants
SUGGESTION OF FENDING BANKRUPTCY PROCEEDINGS
A voluntary petition under Chapter 7 of the United States Bankru tcy Code was filed in the
Bankruptcy Court for the Middle District of Florida, Tampa Division, on ~~~~~~~~ ___ ~ 1 , 2012,
which case is captioned:
In re:
Robert Goodrich and
Lisa Goodrich
Chapter 7
Case No.: ~ '• I ~ b ~ - i f~° ~~ ~.- I
The' filing of this Suggestion does not constitute a Notice of Appearance in these proceedings.
The undersigned represents the Defendant in connection with a federal bankruptcy case, as referenced
above, and is providing this Suggestion for informational purposes only.
Respectf ~ bmitted,
G. Donal en, Fla. Bar No.: tJ l 37080
don@brandonl wyer.com
Joseph B. Battaglia, Fla. Bar No.: 0058199
joe@,brandonlawyer.com
THE GOLDEN LAW GROUP
808 Oakfield Drive, Suite A
Brandon, Florida 33511
Telephone: (813) 413-8700
Facsimile: (813) 413-8701
Bankruptcy Counsel for Defendants
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT, on this 3 i day of ~\C. t`c~l~<. r 2012, a true and correct
copy of the foregoing has been provided via mail to; Attorney fo~Pl~n~~ff; Yale D. Weinstein, Esq.,
1060 Andrew Drive, Suite 170, West Chester, PA 19380. 11
G. Don~ld'Golden, Fla. Bar No.: 0l 37080
Joseph B. Battaglia, Fla. Bar No.: 0058199