HomeMy WebLinkAbout10-5631OF TF!F F; a"'I (71MY
14 AUG 3 ! AM 11: Q
LUMP, &1 -=i%D GUUN1I
PFNNSYLVAM
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.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
ERIC J SNYDER : NO. 10 - S(v3I 3wTerm
15 North Corporation Street
Newville PA 172411127
Defendant 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 /ON
Carlisle, PA 17013
Telephone No. 717-249-3166 or 800-990-9108 ew?? P? AT7^{
C-39181 $lSQg
Ot a y 750 6
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.
ERIC J SNYDER
15 North Corporation Street
Newville PA 172411127
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
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 Eric J Snyder, who resides at 15 North Corporation Street, Newville,
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 8897 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 $4,518.14 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 $4,518.14, and
the costs of this action.
Burton )Kell & Aoocktes, P.C.
Y ei em, Esquire
me or Plaintiff
The law firm of Burton Neil & Associates, P.C. is a debt
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Bete (a i,j ttrOVni Cnii7 _ _'r-k
www.cglcards.com
New Balance:
S4sla_u
Minimum P
E
ayment Due:
$4.518.14 /
Payment D ue Date:
04/21/2010
000000 MC 32 A 0
ERIC J SNYDER
15 N CORPORATION ST
NEWVILLE PA 17241-1127
0
Detach and follow payment Instructions on revaree
Make check payabhto:Cltl CardS
A&count Number
897
Amount Enclosed:
Payment must be received by 5:00 PM
local t1M on the payment due date.
CITI CARDS
P.O. BOX 182564
COLUMBUS, OH 43218-2564
EXHIBIT-,,I _
.
Verification
I, Mark Molinarin , am employed by Citicorp Credit Services, Inc. (USA)
(hereafter CCSI), a subsidiary of plaintiff, Citibank (South Dakota), N.A. CCSI is a service
provider for plaintiff in that it services credit card accounts owned by plaintiff. I am authorized to
make this verification on behalf of plaintiff. The statements of facts set forth in the complaint are
true and correct upon my information and belief and are made subject to the penalties of 18 Pa.
C.S. Section 4904, relating to unsworn falsification to authorities.
d
Signature
C-39181
Eric J Snyder
Account number ending in 8897
1000
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson FLED-07CCE
Sheriff `'F TP10' P:D' ?ITAPY
Jody S Smith c? -$ p I Q 2 110 Chief Deputy
Richard W Stewart
. F .. ;.._ CWN;ir'?..k `, COUNTY
Solicitor PENNSYLVANIA
Citibank (South Dakota) N.A. Case Number
vs. 2010-5631
Eric J. Snyder
SHERIFF'S RETURN OF SERVICE
09/02/2010 11:18 AM - William Cline, Corporal, who being duly sworn according to law, states that on September 2,
2010 at 1118 hours, he served a true copy of the within Complaint and Notice, upon the within named
defendant, to wit: Eric J. Snyder, by making known unto himself personally, at 15 N. Corporation Street,
Newville, Cumberland County, Pennsylvania 17241 its contents anWthe time handing to him
personally the said true and correct copy of the same.
NE, D TY
SH ERIFF COST: $38.80
September 03, 2010
SO ANSWERS,
RON R ANDERSON, SHERIFF
o; ceuny5uite sheriff f elee.=.o`t Inc.
CTTIBANK (SOUTH DAKOTA), N.A.
701 East 60th Street N, Sioux Falls, SD 57117
Plaintiff
v.
ERIC J SNYDER
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 10-5631 CNIL TERM
15 North Corporation Street ~ o
Nevwille PA 17241-1127 .,o ~ o
Defendant : CNIL ACTION -LAW ~~
~~
-'
r
Praecipe for Default Judgment ~~ °'
To the Prothonotary: ~° -G+
x c~
s
Please enter judgment by default for want of an answer in the above case in faf tjie
plaintiff and against the defendant, and assess damages as follows: ~ t-r'
Principal:
TOTAL
$4,518.14
$4,518.14
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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 Bw
AND DAMAGES ASSESSED AS ABOVE.
NOTICE GIVEN UNDER PA.R.CIV.P. 236 By:
Pro Pro onotary
The law firm of Burton Neil & Associates is a debt collector.
C-39181
P.C.
~Yale~~nstein, Esquire
Attorney for Plaintiff
LD. NO. 89678
1060 Andrew Drive, Suite 170
West Chester, PA 19380
~ik.oa?cL~.C~Y
Nc~rlt~ M~.ol£~l~
~- ~
CITIBANK (SOUTH DAKOTA), N.A. IN THE COURT' OF COMMON PLEAS
C-39181
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. ] 0-5631 CNIL TERM
ERIC J SNYDER
Defendant : CNIL ACTION -LAW
TO: Eric J Snyder
] 5 North Corporation Street
Newville PA 172411127
DATE OF NOTICE: September 28, 2010
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 (] 0)
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
Neil/c'~1~ociates. P.C.
In making this communication, we advise our office is a
debt collector.
Y
wire
Ayl'orney for Plaintiff
entification No. 89678
1060 Andrew Drive, Suite 170
West Chester, PA 19380
(610) 696-2120
. ,... . ......., ...-.. ...-..~....-~. w-r-..,....: .. ..,. ... ~
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
Plaintiff
CUMBERLAND COUNTY, PENNSYLVANIA
v.
ERIC J SNYDER
NO. 10-5631 CIVIL TERM
Defendant :CIVIL ACTION -LAW
Rule of Civil Procedure N0.236 (Revised)
Notice is given that a JiJDGMENT in the above captioned matter has been entered
against you on f,( ~ f ~ ~ ~~
Prothono
By:
If you have any questions concerning the above, please contact:
Yale D. Weinstein, 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.