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HomeMy WebLinkAbout10-5670FILED-0 '1CE C)F T, 3F P'-- T,..! _:' 10TAPY CUM F-"'. ; 'O COUNTY FEN411ZYLMN A Burton Neil & Associates, P.C. By: Brit J. Suttell, Esquire ID. NO. 204140 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. FLOYD E RAUDABAUGH 863 Carlwynne Manor Apt B 105 Carlisle PA 17013-1530 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 10 - 5&170 C,t v i t Ta-M 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 $qa.00 p o A T1-/ C-38251 Telephone No. 717-249-3166 or 800-990-9108 C-f $au 0a 0 Zq 7 (oil Burton Neil & Associates, P.C. By: Brit J. Suttell, Esquire ID. NO. 204140 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. FLOYD E RAUDABAUGH 863 Carlwynne Manor Apt B 105 Carlisle PA 17013-1530 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 Floyd E Raudabaugh, who resides at 863 Carlwynne Manor Apt B105, 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) Home Depot credit card with account number ending in 8594 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 $4,482.81 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 $4,482.81, and the costs of this action. Burton Neil & Associates, P.C. By: `C Brit uttell, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. Account Statement Send Notice of Billing Ertors nd Customer Service: Customer Service Inquiries to: myhomedepotaccount.com HOME DEPOT CREDIT SERVICES or 1-866-458-7683 PO BOX 653000, DALLAS TX 75265-3000 Account Number: 8594 ?Z to Z °Z co Z ? I oZ °o Z o Z oZ o I oZ ?Z Z Z z z Z Summa of Account Activity Mailed payments must be received by 5:00 PM at the Payment Information address for payments by the P due date. te Previous Balance $4,339.80 New Balance $4 4 men Pay -$0.00 Minimum Payment Due $833 00 re Other Cre Other -$0.00 . Payment Due Date April 18 2010 Purchases +$0.00 , L t P W Fees Charged +$39.00 a e ayment arning: If we do not receive your minimum payment by the date listed above, you may have to pay a late fee up to $39 00 Interest Charged +$104.01 . . Minimum Payment Warning: If you make only the minimum a ment each New Balance $4,482.81 Past Due Amount $645.00 p y period, you will pay more in interest and it will take you longer to pay off your balance For example Credit Limit $0.00 Available Credit $0.00 Only the minimum payment 24 years $12,065 Statement Closing Date 03/22/2010 $183 3 years $6,587 Next Statement Closing Date 04/21/2010 (Savings=$5,478) Days in Billing Cycle 32 If you would like information about credit counseling services, call 1-877-337-8188. To avoid interest charges pay $4,482.81, plus any promotions expiring this period, by 04/18/10 (residual interest may apply). ry?? SAVE STAMPS, Register now for Paperless TIME.. Statements and more at AND TREESi myhomedepotaccount.com We may be able to temporarily reduce your monthly payment and interest charge. Our Account Resolution Specialists are available to provide assistance. Please contact us at 1-866-752-0874visit us online at mvhomedeootaccount.com , or go to your local The Home Depot store. Your late fee was based on an account balance of $4,339.80, which was your account balance on the late fee transaction date. Your tax refund Can hey make It Many customers have resolved overdue amounts by using their tax refund money. It's simple rT,, and convenient. If you're not expecting a refund, we may have payment options available. 'R Gall 1-866-518-6159 today! We have payment options and plans that you may not be aware of. So It's Important for you to call today. NOTICE: SEE REVERSE SIDE FOR IMPORTANT INFORMATION-------- Page 1 of 4 This Account is Issued by Citibank (South Dakota), N.A. ----------------------------------------------- ------------------------------------------------------------. + Please detach this portion and return with your payment to insure proper credit. Retain upper portion for your records. + Your Account Number 1 New Balance 1 Payment Due Date 1 Past Due Amount E 11 1 594 $4,482.81 APRIL 18, 2010 $645.00 Make Checks Payable to: HOME DEPOT CREDIT SERVICES KBAVHDI 2 3/22/10 0 A O o IIIIIIII?I?I?IIIIIIIIII???II?I?III?'?'?IIIIIIIII?II?IIIIIII'lll' w FLOYD E RAUDABAUGH 863 CARLWYNNE MANOR APT 8105 CARLISLE, PA 17013-1530 Print address changes above in blue or black ink. Minimum Amount Payment Due Enclosed $833.00 $ Starting February 22, 2010, minimum monthly payments are required on new promotional purchases. HOME DEPOT CREDIT SERVICES PROCESSING CENTER DES MOINES, IA 50364-0500 III II 111111111111111111111111111111111111111111111111111In111111 EXHIBIT- /q Idorntatles About Your Account . • YON ACCOUNT MUM BY CMUNK (SOUTH DAKOTA), N.A. • &VANCE SUBJECT TO RN?KE CHARGE • TWO-CYCLE MOM ONLY BALANCE (INCLUDING NEN TRANSACTIONS) Method C. I the periodic rate fisted in the Finns Charge Surmmy Section at rife slalemw is followed by a'C', we figure a pardon ofhfkurcehugaonyouracceuduchdaybynwlBplyinolhedei balarhceforeachbatamax(ta,eaclr purchase x*ct to promotional terms, other regular revolve ?aee??tt p__? n anr major purchase plan purchases) try the applicable daily periodic rate. We do the each nay ltd the b ting P:: including the Chasing Dais. In addition, for each balance, we multiply toddy balance for each day of the previous filling period by the applicable daily periodic rate, unless your account was credited for the amount required to got the grace period on Pac - flbed below In the *MW the Orm Period on Purclim or a periodic I! nance charge already blibd on ft bbalance. To plat tine dalk balana• we taW a Mee beer ItoHo for each I my day, add wry near purctsees, lees, apd aN ftnna charge on the previous dogs balance, subtract any credits or payments credied as of that day, not make ether adjustments. A credit balance b tneted as a balm of am The r mullplyy tie current cycle Balance Subject to Finance Charge by the the appliabe doll periodicrata, and you multpl the previous rate d?thesetwofip restogetherrtheresult will be the periodic AVERAGE DAILY BALANCE MG NEW TRAMSACf10Naj-Malted H. I the periodic rate listed in the Fkance Charge Summary soon of this doomed is hollowed by a'H', we figure a portion of the franca charge on you account each day by multiplying the dal, belanoe for each babna (e.g., each purchase subject to promotional terns, other regular revolve credit plan purchases and other major purchase plan purchases) by the cep habledailyperiedicrate.WedatlnisearhdayofthebillingperTad indudkiglsCbaing0ele.Togeltfedai, tea once, we talnete lteoming balance for each balance every dry, addj any new purchases and arty farah= derye on tlhe previeus days batan= subtract wry credite or peymats tract lad a ot tat day and male or edjustmenb. A crednt talaree la keeled a a belalloe d mro. its Balaaca Suhjact to Finance Ctarpe are tilt averepes ot the rrnpedive etail)r 6elanc?a during the billing period. I you muitply this figure ter eherA balance by the number d days in the bills period and by the appliwbb daily peiorfic rata, the result will be tilt periodic finance dsrp? assessed ter ?Mlerne, eoteq fa mnror varaBoro rased by raundirg. AVERAGE DALT BALANCE ((NN:LINNMG MEN TRAlISI1C110NS)•Melined I. I the periodic rats listed in the Finance Charge Sumary SaclIon of this statement Is followed by an 1', we use to following alallalhhn method. To get the Baku= Subled to Finance Charge for each balance (e q., each purctme subject to promotional temp, other regular nwohe credit plan purchases and o1w major purcase plan purchases) we tale the booming balsa for that balance every day (locating finance a du rges Ir posed in prevlaus biting Wads), add any new purdmes, subbad any Gelb or payments cradled a of 1st day, and rtabe cdhar adjustments. A aedl balance is treated as a balance at are. This gores is thedot, balance. We add tip at Ire dally baia=for thedlIIng period (including sbalances on the Clrakno Dnta) and divide by to told member of days i? the billing perbd. This gives us dotSubject to Finance arge for that balance. We figure a portion of your nano charge on by the g?subject to to this calculation method by multiplying the applicable nnonth, pedDdic rate for tgt balance AVERAGE NtILY n Firm C?tEW?tTRU IW )H1sUIOd K. If to periodic role listed in the Fnnce Charge Suimary n of this obtained is followed by a'K', we use the totowinp calculation method. To got the Ba lwaSu d to Finance Chagefor each balance (tg.. each purchase subjedto promotional terms. of erregular rmlw cmedh plan purctasesandother major purclme plan puchaa) we tallethobeginnimg balance for the When every day and subtract any credits or payinarris credited as of tal day and any unpaid finance charges We do not add in any new purchases. A credit balma is traded as a balance of mm. This gives us the daily hence. We add up ail the doi, balances for the bill'mp perled {indu ing the balancces an the Closing Oahe) and divide by the total number of days in the billing period This gives us the Balsa Subject to Finance Charge for that balance. We figure a portion of your finance chaps on transactions subject to this calculation method by multiplying to applicable monad} periodic roe for that balance by the Babe= Subject to Finance Chargqee (wing new transactions). AVERAGE DAILY BALANCE ppNCLLM NG NEW TRANSACTiONS)•Msftd L I the paredic rate toed in the Finance Charge Sunmary Section of ft stelenent is followed an I!, we use the MW&ing calculation method. To getVa Baen=Subjedto Finance Ctsrgat to each balance (&g., each purchase subject to promotional balms ter did t dauce every credit add any new rwrclma, and major purchase any credo or paymentwe We the s aedw as of that day and any U aid finance charges. A well balance is healed as a balsa of zero. This glva us the daffy balance. We add up at the dally b dances for the billing period (Including the balance on the Closing Dale) am divide by the toil number of days in the billing period. This gives us the Balance Subject to From Cher far that balmca. Nk figure a portion of your finance charge an transactions subject to Ibis WwlaBm meta by (muAirrpgqying Ire apphaabbll?)e monthly periodic rate for that balmicir by the Balance Subject to Finance Charge AVEdMGE DALYW ANCE (INCLUDING MEIN TRANSACTgVl,d wd M. I the periodic rds listed ante Finance Charge Summary of this domed b tellawed by an'FA', we on the following calculation method. We alwlab pedodc fnana charges seperelslyy for each balance. Balances irsiude regular purchases and different promotional balance. To get a daily balne% we start with the balance as d the end of the previns day. We add any periodic finanoe charge on the previous days bales. (This msulte in daily compou and rm ake odorll adjusl. ct rrente A cred t re balance Is tre M as a ft ft at en n. We Use the p?xl* finance by mcdtlglong the dalgi balance by its dal, periodic tale We do this for each day In the b11117 periodcharge . The BapnaSubJectto Finance Charges is the average olthrdai, boances duringthebtiBng per?d. you muld* this figure foreach balance by ib dal, perladlc r& and byte number of drys fn tine bi III ng pe-rioq the result is the total periodic Irons tier an cat balance. Ron lrg may cause a small Serves. PROMOTIMI. We may offer you ro motional terms for all or aped of belarm Any promotional temp may apply for a IM M period of time. rm will be governed by the lams of k promotional otter and your Card Agreement. They, may Include the No ktemest, 0%. and Equal Payment Plan offers described below. Your promotional terms may end if you detwl under the Card Agreement beauser you do not make the minimum payment when due, go ova the credit line, or make & p"no a us that is not honored • No' 1 1. No finance charges wil I be imposed on this balance if you pay the balance in full by the end of Ire promotional period, We wiI impose /dance Barges an leis balance if you do not pay the balance in full by the and of the promotional period or the promotional tame are terminated. We will impose these finance drapes from the date of purchme until the balance is paid in full. The promdharal otter will spedy the amount of any minimum paymed required on itds balance. • O% No fnarn charger are imposed on this balance during the promoltonal period. The promotional offer will specify to amount of any mmmun payrnerd required on this balance. • Egal PopmmN Ran This balance will be repaid in equal minimum payments The promotional after will specilly the amount of the minimum payment required on this balance. aMlll OATE, At our discretion, Ihis sensed may include charges, tees, and payments on the Closing Date. GRACE PERIOD ON PURCHASES. You can avoid periodic finance charges of purchases. This is aced a grace period on purchases. The grace period is at bast 20 days To get the grace period on purchases, pay the following amounts by the due date every billing paned: • the New Balance, lass any No Interest, 0% and Equal Payment Plan balances that spire after the paymerd due date, plus • the minimum month, payments required for you No Interest, 0%. and Equal Paymerd Plan bawas Nat espke ahem the payrt due dale. I you do not, you will not gd a grace period cemless you pay the above amounts by the due doh for two billing pentads In a raw. In 20lon, certain promotional offers may take away the grace period on purchases. Other promotional otters, In addition to No tnherest, 0% and Equal Payment Pharr olars, mayalso allow you to have a graceperlad on purchases will haviing ro pay all or a portion of the promotional ballancs by the due date. I either Is the cam, the ppromotional a will describe what happens, BILLNtO RIGHTS $UMMNtY. In Can of Erton or OSaletts Atim Your 1111. If you think your hill is wrong, or I you need more information about a transaction on your bill, write us at the Billing Em address on this slatma as soon as pmsbe. War mud hear ham you no late than 6D days alter we send you the first bill n which the error or problem appeared. You an telephone us, but doing so will not preserve your rinds. In you later, give us the following Information: • You name and mount number. • The dollar amount of the error. • Describe the enter and explain. if you an, why you believe there is n error. If you need more idarmation, describe the ben you are unsure about. Pleas be sure all correspondence is signed bythe primarycard older. You do not have to pay any amount in question while we are in ng. But you are still oblipded to pay tie pads of you bill that are riot in question. While we invedigae your question, we and report you as delinquent on the dlepuded gain or take any edton to cried the amount you question. Spalod Relit fa Credit Card ParhAnaa. Iyw have aproblem withthe quality ofgoods orservices thit you purchased with a credit card, and you have tried in good faith to carted the problem with the merchant. your may not have to pay the remaining amount In on the goods or services. You have this protection only when the pucfine pra is more Ihan $50 and the purchase Is made in your home oft or within 100 miles of your mailing addrea. (B we own or operate Ice merchant, or t we milled you ft advertisement for la property or services, all purchases are covered regardless d amount or location of purchase.) KEY CREDIT TERMS -NO NI TEREST IF PAID IN RILL WRHM N MONTHS`. ON NNdmom Pushm Resuind- Minbr wim Pa-m-¦ae Ier wdlmd Ir"r.:r rdir r...h.rrr.d •• , . miliguat M Not rdmn slob If Got pagdoglow bolollle nllltlio ronalumo tort lonad aedN InltWleo b not old RI hilt wNMo S mw to w N you Mini a toed a d. *With credit approval for qual n u rchases made on The Home Depot or ON Design Center Consumer Credit Card For accounts In good standing, APRI up to 21.91% Penalty APR up to 2G.G1;6 (fafesmayvary.Minimum lN CHARDE:$2.Lowrerrates mayapply. Seeardagreementfordebits including when thepereKyrate applies.0fferisat,wlidiorconsumer accounts andissubject to change without notice. IMPORTANT PAYh1ENT INSTRUCTIONS. Crediting 11"nols. We must receive your mailed payment in proper form at our processing facility by 5 p.m. local time there. I we do, it will be credited a of thd day. (Pleas refer to the top right hand carrier an to been of your statement for processing taciliry lime mro.) A payment mcohred at the processing facility in props inn after that time will be credbd a of the crud aiy. Allow 5 e 7 days for payments by regular mill to react us. There may be a delay of up to 5 days in crediting a paymed we receive that is not in proper form or is not sent to the correct address. The correct dress for a payment swot by regular mail is the address listed on The return mwelope at on the front at the payment coupon. A payment made In' a is not sent to tae correct address. The correct address for a payment sent by courier or express mai I is the Express Payments Address shown below. Proper Farm. For a Wrest sent by mail or courier to be In proper term, you must: • Eiden a valid Meek or money order made payable to Home Depot Credit Services. No cash, oil cards, or foreign currency please. • ledede your name and account number on the frond of your check or money order. I Vol and an @Npbb shad with Bole ppmat eoupa, ym Made us to ampbb your payment by at dusk ddL N M do, the padding a, P,-- will ke IeI " in to manual on firs Out We my do this a son as ft day we male this sheet. Abe, tie dnok will be duxltsyel. Copy Fee. We carpe $5 for each copy of a bli ng slaement that does back 3 months or more. We add the fee to a balance of our choosing. We reserve the right to add Ns fee to balances subject to a higher annual percentage rata. We wain the fee it your request for the copy relates to a biflirg error or disputed purchase. PAYMENT OPI=$ OTHER THAN REGULAR MAIL. • Ord Ime Paymab. Vlsk myhanedepotaccoudcom and sign up for free angina payments. Enrollment may take alawdays. If we reodveyour request to mate an online payment by5 p.m. Eadem time, we will credit your payment as of that day and itwill past within I mee bustress days. II we receive your request to male an online Payment alter that time, we will credit your payment a of the nag day and It will post within three business days. For secuNy reasons, you may be unable to pay your entire New Balance with your first online payment. • Pay by Phmm Smela. You may use this service all= tamale apWM by phone, ifyouracomnt Is eligible. You wig be clanged $14.95 to use this service. Call by 5 p.m. Eaden time to have your owned credled as of tall day and posed within three bustntess days. I you call dff ltd Ime, your payttatd will be oft a of IN red dry and posed within three business days. We may prooass your payment ehdrnh=Ny alter we verity your idemtfiy. • Expron PiVmmb. You an send payment by courier or wpm mail to the Bq)mss Payments Address: Customer Service Getter, Attention: Payment Mail Opening, 8725 W. Sahara Ave., La Vegas, NV 09117. Paymera mast be received in proper form at the proper address by 5 pm. Pacific time to be credited as of heal day. All payrnerhe received in proper form at the proper address all t hol will be credited a of the next day. • In Sin Pahymsde. For your added commence, payments an be made al The Home Depots stores with no service in. Payments made at the stare prior to the store closing time will be posted to your =writes d that day but avalbbillty may be subject to verification of funds. REPORT A LOST OR SATEEN CARD IIMlEDUMY. You may call Customer Service 24 hours a day, 7 days a week. HD/EII FEB10 Page 2 of 4 Account: **** **** **** 8594 WZ co Z o Z m Z W I oZ o Z o Z to Z °o Z NZ Z Z Z Z Z TRANSACTIONS Trans Date Description Reference # Amount FEES 03/18 LATE FEE Q sa nn TOTAL FEES FOR THIS PERIOD $ 39.00 INTEREST CHARGED 03/22 Interest Charge on Purchases $ 104.01 TOTAL INTEREST FOR THIS PERIOD $ 104.01 E ANNUAL PERCENTAGE RATE on the account: 26.99y* " The 'ANNUAL PERCENTAGE RATE on the account' includes all transaction and periodic interest charges imposed this billing period on all balances on which interest charges were imposed. If the 'ANNUAL PERCENTAGE RATE on the account' is WA, no interest charges (after adjustments) were imposed this billing period. Interest charges may be accruing on promotional balances and may be billed to your account under the terms of the promotional offer. Refer to the corresponding APR for the APR that applies to each balance. INTEREST CHARGE CALCULATION Your Annual Percenta a Rate APR is the annual interest rate on our account Revolving Balance 26.99% (M) $4,396.00 $104.01 Page 3 of 4 Account: **** **** **** 8594 Page 4 of 4 Verification I, Mark Molinario , 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. r Signature C-38251 Floyd E Raudabaugh Account number ending in 8594 1.025 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ~ ~~ ~ ~ ~~F, e~' ~~, ~•ir r `^ i ~~Ry Jody S Smith Chief Deputy Richard W Stewart Solicitor Citibank (South Dakota) N.A. vs. Floyd E. Raudabaugh PEIti+`rti'SYi.V~lq ~ ~~ cr-~ 1 ~ ~~~ 8~ 53 Case Number 2010-5670 SHERIFF'S RETURN OF SERVICE 09/09/2010 03:30 PM -Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on September 9, 2010 at 1530 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Floyd E. Raudabaugh, by making known unto Michael Vaughn, adult in charge at 863 Carlwynne Manor, Apartment B105, Carlisle, Cumberland County, Pennsylvania 17013 its contents and a1 the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $33.40 September 10, 2010 o' ~- rS DEN FRY, U SO ANSWERS, RON .~ R ANDERSON, SHERIFF t CITIBANK (SOUTH DAKOTA), N.A. 701 East 60th Street N, Sioux Falls, SD 57117 Plaintiff v. FLOYD E RAUDABAUGH 863 Carlwynne Manor Apt B 105 Carlisle PA 170131530 Defendant To the Prothonotary: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 10-5670 CIVIL TERM CIVIL ACTION -LAW Praecipe for Default Judgment n ~ ~.., d o -~ -~ -~, r,-y sz~ ° ~ -+ ~ -*1 -,.f°C1 ~-,:. ~ r.°~ --~ m~ . -v cl'i ~ rv r ,i ~ p -~?~ r~ co ~o ..~ ~,~ -~ r; ~~ ~ -~ ~=c~ ~ -._ ca ~~ n rn ~ D `~' ° `~' ~ -< 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 $4,482.81 $4,482.81 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. NOTICE .GIVEN UNDER PA.R.CIV.P. 236 Pro B n Neil & Asso fates, P.C. B: aniel A. Pa Esquire Attorney for Pl ntiff I.D. N0.202294 1060 Andrew Drive, Suite 170 West Chester, PA 19380 The law firm of Burton Neil & Associates is a debt collector. C-38251 I'~•o0 P O Airy c~~ R#a5o~5~ l~lcsl-;c.~ Ma~lec~ CITIBANK (SOUTH DAKOTA), N.A. : III THE COURT OF COMMON PLEAS C-38251 Plaintiff C[IMBERLAND COUNTY, PENNSYLVANIA v. NO. 10-5670 CIV)L TERM FLOYD E RAUDABAUGH Defendant : CML ACTION -LAW TO: Floyd E Raudabaugh 863 Carlwynne Manor Apt B 105 Carlisle PA 170131530 DATE OF NOTICE: October O5, 2010 1MPORTANT NOTICE You are in default because you have failed #o 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 Iawyer 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 maybe 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 170]3 Telephone No. 717-249-3 ] 6b or 800-990-9108 In making this communication, we advise our office is a debt collector. B n Neil Associ s, P.C. By: 'L Daniel A. Payne, Esquire Attorney for Plaintiff Identification No. 202294 1060 Andrew Drive, Suite 170 West Chester, PA I9380 (610)696-2120 Burton Neil & Associates, P.C. By: Daniel A. Payne, Esquire ID. N0.202294 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA), N.A. Plaintiff PENNSYLVANIA v. FLOYD E RAUDABAUGH Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, NO. 10-5670 CIVIL TERM CIVIL 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 one B ~!0 By: If you have any questions concerning the above, please contact: Daniel A. Payne, 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.