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HomeMy WebLinkAbout10-4147~-~ 1810 JUN 21 pN 2; ~~ ~A 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. 70 ] East 60th Street N Sioux Falls, SD 57117 Plaintiff v. S MINOR aka SOPHIA MINOR 504 E Elmwood Avenue, Apt 3 Mechanicsburg PA 17055-4215 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COi1NTY, PENNSYLVANIA NO. ~ Q - ~~ ~ 7 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 HII2ING 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 ] 7013 Telephone No. 717-249-3166 or 800-990-9108 C-35402 ,L ca~ ~9~_u~~ y ~ ~ j7~i~3 Burton Neil & Associates, P.C. Bv_ 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 v. S MINOR aka SOPHIA MINOR 504 E Elmwood Avenue, Apt 3 Mechanicsburg PA 17055-4215 Defendant 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 S Minor aka Sophia Minor, who resides at 504 E Elmwood Avenue, Apt 3, 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 cazds. 4. Plaintiff furnished consumer credit to the defendant by means of a credit card with account number ending in 4764 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 manthly 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 accx~t of tine billing statement or retained the statement without payment. ~- de`fendant's actions as set forth above constituted an account stated between parties ~cr '~ aim of 59.119.22 which sum reflects the Exhibit A statement balance less credits, if any, w~k~ xere applied subsequent to the date of Exhibit A. Wherefore, plaintiff demands judgment against defendant for the sum of $9,119.22, and the atists of this action. Burton Ne~l ~ associates. P.C. By: D~k Blasker, Esquire Attorne for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. c~ r ~8O ` ti S V M O J ~. N • N d ~~ ELI.. e j^ em aoo~ _~ Vmcntn v ~D $ 3 v i v ~ E S ~ Z .V 7 ~ 7 2 < to < Q~ ri ~ • e OO p F s t°- ~~ ~ = i V (~ ~ e_ ~ C ~ --. e ~ e o m ut m > O >o N ~ O d N $• q ~ ~ V ~~ tU > H < Ew ~~ c C ~ o ~ ~ ~' ~ u °~ r N ~ d c ~ u ~ N ~ u A A d u > E ~ ~ Q ~ ~', m ~ 4 ~ '" E E ~ c 'o o cIn ~ ~ w • ow.~ cE ~a~a N HIV Z ~ EF e,= d S.7 3 r ~ ~N i _ G~ ~ >o ~N 7 yy pp.. y C 0~ ~ O N N '.1 ~ >0 C • ~1 T d ~ 4 Q ~ c"' o to ~ N ~ N >aa e E e. e ~ 6'>w v .E O~ E ~ O c n a n ~ t/1 d ~ E «° w Delp peo] __ ___ dm0ufit [6i.] ~~ 2= L~ W =W Z~ ~S +u :rp iE n ~t ,.Ii Yy~ ~i 6~ 6 t + ~a 9• ~ ~~ E `m E d N W , N ~ b J< P <F- '+ u ZW< o: F j7~~ W m d w ~ ~ ~ N M C ~ a0 C pQ N Z o ~ o $s a O E O yy ~P xL ~ N W ~ m o~ .~ N m m > E N .'p, r I°- ~ ~ 00 OO NCO OOO 0' O O O O N N GD O "'~ O O O O P Q P ~ ~ N ~ r ~ ~ ~ ao .... +A W U Q i t Y y u c ~ 'v m e . w E y A o b' u ,~ a U ,,, ~ ~ c >. Y c A w ~ ~ c U g m N $ $ g ~ c ,a > > O E d $ c q E : U q > m U c m o U g d d q .. a d w E c E c ~ ~ g q M a a 0 = m U d a ~ ~ U > d 'O U > d A A a e check tt ___ setaM ana Maw w ymeM Imtrucefaa on revene MYI.<M<b peyabl. t.;Gift Cards New Balance: ~ f~ ~l ~~j1 ~~/7 Accwnt N S9,119.22 ~/~J ;' t/ G/ umber. 4764 Minimum Payment Due: -- Amount Enclosed: $9,119,22 Payment Due Date: O2nO/201O Payment must be receWetl by S.'W PM local tbne on tM payment OIIe date. 000000 MC 32 A 0 S MINOR 504 E ELMWOOD AVE CITI CARDS APT 3 P.0. BOX 182564 MECHANICSBURGPA17055-4215 COLUMBUS, OH 43218-2564 E~(HIBIT~ _~ C ~ 7 V E E s V • C C C ~ ~ CCj N ~ ~ V 00 ` ~ eg N ~ ~ LL's ipQ > «" E u' ~` raj ~ om aO0 S S~ tlmin < ~ W 4 S b <1<-W N ~ O w w i W ~ ° E ~ S 2 < <rcrc +- °' o m rn .o m' LL v 'a° rT n = O 7 C ~ (V U ~ ~ C C ~ ~ CO O c' o< Z d ovi yE O > O O 7 O nv n ° E >. N t a + C ~ N p/ i=. C ._ O N C _ p O "' N N V W 4~ d N NEo a3 m m 3 a ~ a`~ny ~3 C a>C ~~ ~ (p ~ _ N d ~ ~ a ~ d M y pl l C C `+ ~ n ~y 0 w TO yy .nt y p Cy fV ~ U ~ O N v^ V u~ Wes; p~ ~~ ~ N >p; - c ~i~ ~~ plc CN ~U'p~ L Ox 7 m OW W d aTN ~ V N N N d p! 7 C ~N ~OpJ o~y e alp ana Lnp ~ +..r N ~ O me ti ~ E ;o °J O A u i 3v a c O N o ' 4 a, a,c m E~- ~ E ~ ..o w ,~ > m q O ns n ~ o ~, u~ 0 N ~ ~_ N jp a y p+~ ' c q 7~ nt+U O is oo a QE ~ ~pOp ~ >.. 2Na Oar. N N ~. .~ ~, Verification I ~ Kit ~ 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. .-- Sign e C-35402 S Minor Account number ending in 4764 1000 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ~~~~zsr of ~~r~nbr~f~~~ ~i ~~. Jod S Smith ~ .- `~~ ~ t~ ~` Chief Deputy ~:,_ .. ~~, 'j~-} _ ;'', `~ , . ~r1-~Y ~~., ~> ,'r, Richard W Stewart ~`~' ~~ Z~t~ ~,'~~'~,~ z~ ~~~ ~; ~~ Solicitor A~~tt E ~~ ~~F ; ~=~~rr P~~~~ ~~~ ~'~ ~ 1~'~iA >_'~~- Citibank (South Dakota) N.A, vs. Sophia Minor Case Number 2010-4147 SHERIFF'S RETURN OF SERVICE 06/24/2010 08:15 PM -Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on June 24, 2010 at 2011 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Sophia Minor, by making known unto herself personally, at 504 E. Elmwood Avenue Apartment 3, 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 June 25, 2010 ~~ RYAN SURGE , SO ANSWERS, RON R ANDERSON, SHERIFF !cj Couo`y5uite Shenff. 7eleos~ft. Inc. CITIBANK (SOUTH DAKOTA), N.A. 701 East 60th Street N, Sioux Falls, SD 57117 Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 10-4147-civil S MINOR aka SOPHIA MINOR 504 E Elmwood Avenue, Apt 3 o Mechanicsburg PA 17055-4215 ?- Defendant : CIVIL ACTION - LAW r-nr=- v rn 0 C:) Praecipe for Default Judgment o To the Prothonotary: C z- Please enter judgment by default for want of an answer in the above c r:a ase in fa off the C7 rn D plaintiff and against the defendant, and assess damages as follows: __e' W ;:0 Principal: TOTAL $9,119.22 $9,119.22 Understanding that false statements herein made are subject to penalty under 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities, I verify that:: 1. The above are the precise last-known addresses of the judgment debtor and creditor. 2. The annexed notice of intention to file this praecipe was mailed to all parties against whom judgment is to be entered and to their record attorneys, if any, after the default occurred, and at least ten days prior to the date of the filing of this praecipe. 3. Pursuant to Section 201(b)(1)(A) of the Servicemembers Civil Relief Act of 2003 (SCRA), the defendant is not in the military service of the United tates based on information received from the defendant and/or the Department of Defense web. JUDGMENT BY DEFAULT ENTERED Bui AND DAMAGES ASSESSED AS ABOVE. NOTI GIVEN UNDER PA.R.CIV.P. 236 By: Pro P notary The law firm of Burton Neil & Associates is a debt collector. C-35402 Associates, P.C. C. Blasker, Esquire kv for Plaintiff I.D. NOS 202150 1060 Andrew Drive, Suite 170 West Chester, PA 19380 w%A 10 " Ti>a*5 ow CVl S3$ V4 ?? C-35402 CITIBANK (SOUTH DAKOTA), N.A. IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. S MINOR AKA SOPHIA MINOR Defendant TO: Sophia Minor 504 E Elmwood Avenue, Apt 3 Mechanicsburg PA 170554215 DATE OF NOTICE: October 19, 2010 NO. 104147-civil 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 800-99Q-91 08 In making this communication, we advise our office is a debt collector. Burton NeijW jKsociates, P.C. By: quire Derek C. BI k2:2150 Attorney for Plain Identification No. 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 cc: David B Ross, Esquire P.O. Box 310 Coudersport PA 16915 j,. 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. IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 10-4147-civil S MINOR aka SOPHIA MINOR 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 , a If you have any questions concerning the at 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.