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HomeMy WebLinkAbout10-5672T} RLED Fnr- CE CIF - FPS 2: 2 8 CUMB'- ;LA 0 COUNTY PENNSYLvAI?IA 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. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ANTHONY R STILES : NO. 10 - 567a alY i (Te " 313 W Shady Lane Apt F, Enola PA 17025-2259 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 Carlisle, PA 17013 S Telephone No. 717-249-3166 or 800-990-9108 4ga.00 Ph Ate'`( C-38627 Cit SIICIQ6 0 o[-L/76/7 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. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. ANTHONY R STILES 313 W Shady Lane Apt F, Enola PA 17025-2259 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 Anthony R Stiles, who resides at 313 W Shady Lane Apt F, Enola, 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 4544 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 $1,861.46 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 $1,861.46, and the costs of this action. Burton Neil & Associates, P.C. By: Brit J Suttell, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. Account Statement i Send Notice of Billing Errors 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: x!{544 11,9 Summa of Account Activity Mailed payments must be received by 5:00 PM at the Payment Information address for payments by the payment due date. Previous Balance $1,775.04 New Balance $1,861.46 Payments -$0.00 Minimum Payment Due $503.00 Other Credits -$0.00 Payment Due Date April 24, 2010 Purchases +$0.00 Late Payment Warning: If we do not receive your minimum payment by the Fees Charged +$39.00 date listed above, you may have to pay a late fee up to $39.00. Interest Charged +$47.42 Minimum Payment Warning: If you make only the minimum payment each New Balance $1,861.46 Past Due Amount $397.00 period, you will pay more in interest and it will take you longer to pay off your balance. For example { Oil- r=' +++aaa"' a $0 00 it di Li C :. _ ,. Fs a ? . . m re t $4 646 00 $0 Only the minimum payment 16 years , . Available Credit Statement Closing Date 03/28/2010 $79 3 years $2'844 802) (Savings=$1 0 , Next Statement Closing Date 04/27/201 Days in Billing Cycle 32 It you would like information about credit counseling services, call 1-877-337-8188. To avoid Interest charges pay $1,861.46, plus any promotions expiring this period, by 04/24/10 (residual Interest may apply). SAVE STAMPS, Register now for Paperless TIME... Statements and more at AND TREES1 myhomedepotaccount.com mZ mZ 13z W z I ?Z A Z 4Z W Z O O Z Z Z Z Z Z Z 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 myhomedePotaccount.com , or go to your local The Home Depot store. Your late fee was based on an account balance of $1,775.04, which was your account balance on the late fee transaction date. "reP'bir Ikea re,i.f..€9 '+s'SJIn eky'Y 1,'nGK3.4`V. ti- I -..r i fl lil Many customers have resolved overdue amounts by using their tax refund money. It's simple and convenient. If you're rlat expecting a refund, we may have payment options available. Cal! 1-6-51 8-6135 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. -----------------------------------------------------------------------------------------------------------------------------. 't' Please detach this portion and return with your payment to insure proper credit. Retain upper portion for your records. 't' Your Account Number 1 New Balance 1 Payment Due Date Past Due Amount 4544 $1,861.46 APRIL 24, 2010 $397.00 Make Checks Payable to: HOME DEPOT CREDIT SERVICES 4544018614600336000050300104 KBAVHDI 2 3/28/10 0 A 11'11111111111111'll'11111111111111111111'11'll'111'1111111111111 La ANTHONY R STILES 34 LOUIS LN ENOLA,PA 17025-2138 Minimum Amount Payment Due Enclosed $503.00 $ Starting February 22, 2010, minimum monthly payments are required on new promotional purchases. HOME DEPOT CREDIT SERVICES PROCESSING CENTER DES MOINES, IA 50364-0500 11111 11111 11111 111111111111111 11111111111111111111111 111111111111 EAH !31T?N Print address changes above in blue or black ink. oftM4, ? - ?, 0 Irdoraalloa Aboul Year Acimill • YOUR ACCOUNT IS load NY CRMANK (SOUTH DAKOTA), N.A. • OAL AW SULIECT 70 FINANCE CHLW TWO-CYCLE NERABE DAILY LWJICE (INCLUDING NEW TRAIISACiiOI WB*od C. It the periodic role listed in the Finmrce Charge Summary Section at this daunt is followed by a V, we figure a portion ddefinance deep onyx ramzaunt each clay bymltyMiraeMe daily baiaaceforeach balance (e.g., each ptrchase subjai b praraoliorral forms. other regular revoke rseddtl pllaann ppcrreGGneasseess and other major purchase plan p?actr) the applicable daily periodic rate. We do this each day of me biting period, including the Closing DaM In eddtlon, for erA balance, we ni ftp b daily balance to each day of the prevlus billing ported by to appllcabb dally periodic rate, unless youramrwd was credited fatal rrourd regalred to gel the grace period on purchases (described below in the s cton wattled the Gras Period on Purchm) or a periodic finance chop was already blibd on fat balance. To pd the daily balance, we We to beginning balance for each balance every day, add mgr new pudwr es, tea, and any finance large as the provio s dWs trance, su bleed cry credits or payments wedded a of tlW day, and make other mWnems. A dedt balm Is treated as a bdm of zero. The Ballarces Subject to Finance Charge are the naps at Me r sperdve daily balms during the applicable billing periods. If you multiply the current cycle Balm Subject to Fiance Charge by the rumba of days in the billing r and by tie applicable dallyy periodic rate, and you ra ltlqq Me previous ?e Balance SUb)ect a wince (l cLffw* subject to a ibsrnce large) ly thenumbs ddir In Met billing period and by the agdkade daily periodic ran, and add those No figure eG the muk will be the periodical rani change assumed for that beance, raxpt Mr miror vexations aiamdi -AVERAGE DALT IALANCE ING N TIWI?ONSNMelbed H. If to periodic race listed in the Fkslhoe Change Swrrtry teddrin of this sldeosd Is bllowed by a "H', we ligum a portion at the frame charge on your account each dry by multiplying the do beans for each balance (e.g., reach prechoe su4ecl to promotional tams, other regular revolve credit pan pudaaa acrd otor ml purchase plan purchase) by the applicable daily periodic rate. Wedothis each day of 1* billing period, including The Closing Dote. To gel the dal balance, we We the beginning balance for each balance every day, add any new purchases and any finance large on the prevous clays balance, subtract any credits or pafmads credited as of tat day, and male other adjustments A credit bdana is keeled ae a belanca of zero. The Balances Scbjm:t to Finerhoe Charge am to average of the respective daily believes during to Wirlg perbd l you moll this figure for each bab re by the number of days in do bill period and by the "llic b daily periodic rate, to rout will be the periodic finance omaed for that tasnce. Dino for minor vo idors cawed by roundi AYBUkGEG DART OALANCE ?IMCLU M MEW TRAM611C MI M*od I. II the pedodh ab listed in the nnmra Clings Summary Season of ibis daunt Is bttowad an "I', we use the following calculation method. To the Became Subjsd to Finance Charge for each balanasg., each purchase subject to pro nodard terms, otherregular revolve credit plan purchases and odor mayor purchase pan purchase) we trio Me beginning balance for il>at beans unary day (inc,! ding inane dirge composed in pmwious billing periods), add wrynew ieaedasaoaiameom ms usinecay amnia maw rear me U•o udaxxs•n no,nnni yaiw audlrg the balances onthe Clos g Date) and dvide by the total number of days n the bfilln0 perod. Th s gives the Babnoe Stigect to Fkwns Charge for thd_.. amhoe. We figure a ponlbn of you Ikorrce charge on 11 gE -001AILYtiALAN6EITDi NE*TRANGCTMNS)-M@MK.Iflreperiodiciatelishedim the FNorrce Chage Surtrrary Sac Ion o (this salaried Is bllawed by a V, we use the following calculation meZW TopolheBalmrcl mm&bodtoFinameCtoWfaeachbaance(q.,achpurclmmsubjedtopromWDmI tents, oft regain rwalve ardt plan purchases and other mayor pudrase pan purchase) we we Me beginning balance for that balance every day and subtract any credits or payments credited as of Rd day and any unpaid finance chops. We do not add in any new purchases. A credit balance is treated as a balance of zero. This gives us the ddy brain. We add cap al the dolly balances for to billing period (ftdudkV the balances on the Closing Dab) and divide by the total amber of dais in to billing period. Tlris give us the Balance Subject to Fiance Charge for Chet town. W! Ague a portion d you finance charge on transactions subject to this calculation method by multiplying So applicable monthly periodic rate for that balance by to Bolero Subject to RrimCe Cep (adudlr?qq row bsrmacdoI AVERAGE GALT KALANCE PNMMM NEW TiWIUPONB)•MMW L g tW pffMlc as ksbd in to Fhence Clergy 5u noner Section of Its statement or idlowad by an 'L', we use the following rtrlculdion method. To gatthe Bolan Subjectte Finance Chrgetor @4 balance (erg., each purchase 3ub*to promotional tams, other regular rewdve credit plan purclum and other magi purchase pan purchase) we We the beginning balance for fat balance emery day, aid any new purchases, and sables any credits or payments credited as at that tl? and any unpaid finance charges. A mg balance is traded as a balance at zero. This gives us the daily balance. ft add up all the daily babncs for the billing prod (Inchding the bafarces on the Closing Date) and d vide by fe tdel nhrlber ol drys in to billing period. This gives a tle Balmy a Subject to Finance Charge for that balance. % figure a portion d your firence dhrge on transecdons subject to Cris calculation method by multiplying k applicable madly periodic rate for that balance by the Bell Subject te Film Charge (AV IERAGE DALY BALANCE (MCWMSG NEW TRMLWTMNSHbftd M. H fo periodic de listed in theFirarmt]srgeSuneeryofthis debased isfollowedbyin'M',wemethefollowingcalculalhon md*.Wacakanbleperiodicfirenactergesseparately forashbalance. Balances include regular purchmas and different Windmill balances. To get a daily balance, we start with tie balance as d the end of the prowas day. Vh add xy periodic finance charge on to previous days balance. (This result in dairy mm; oundlrrpp of ffnrroe dwgu.)Wo add any row damp. Ulm subbad arty new me* or paym mla and mat other rdjuslinis b. A cridlt balance a tre6d as a bWarim d i a. Wo f" the pubk lnarimcharge by Muhl p the dally toonce by is daffy, periodic rala We do this tot each ? In to billing period Tla galarhos?y?yOoFiranceChrgalsareawerageolfadallybalaroedurhVfeb ling Iod.Iyoumurdpty this Ion for nth balance bbyy I i dally ppeeriodic rate and bbyy the mftw d days In the nil pried, tie result a the WW periodic finance eherge car tht balance. Itourdkg may came a small dKlrena. PROMOTIONS. We may ohm you promotional tams for allot apart of any halarhoa. Any promotional tams nay apply ban a limited period of time. They will be governed by the terms of the pronollonal olfa and you Card Agrearait They mmay ay Include Me No e if you dad under ar0%. and e Card Equal amnia t because you do not male the below. Your promotional imum pawned when due, go over thecredit line, a make a paymeMto us tot is not honored, • No' I . No finance drops will be imposed on the beance if you p? fib balance In full by the and at are romotond period We wiII impose Ina charges an this balance if you do not pay to bait= in full by fo and of the promotional period athe promotional tame are terminded. We will impose these inane drages from the dale of Dutch= until the balance is paid in full. The promotional otter will specly the amount of any nlnlnanm payrrad required on ids balance. • IS No finance charges are imposed an this balance during the promotional period. The promotional offer will sportily are amount of any rreemm payment required on this balance. Equal Palmed Plan. This balance will be repaid in equal mhrum paynerds. The promotional after will spa* the aarorr of the rdninno payment "lead on fie baaace. CLOMIM GATE. k our dscrdion, thissmarted may inckedaehmge%amt, and payments on the Closing Dole. GRACE PERIOD ON PURCHASES. You can avoid periodic Iran charges on purchases. This is called am period on purchases. The grace period Is d bast 20 days. To got the grata period m purchases, pay to following amounts by the due date every bil Iinpp period: • the hew Balance, lass wry No Inbresl, 0% and Equal Payment Plan balances thatuplre afar to payment due dab, plus • the minimum monthly paymeni required for your No Interest 0%, and Equal Payment Plan balances that mom alai the payrrentdue dam. I you do rat, you will not got a grace period unless you pay the above amounts by the due dab lot two billing periods Ina row. In addition, caraln promotional oleic may take away the grace period on purchases. Other prornotlonal offers, In addition to No Rest, 0% and Equal Payment Pan offers, mayabo allowg to bare a grace period on purchases without having to pay all or a porilon of to promotional ce by rie due ride. I ellher Is the can, the promotional olkr will describe Met happens, SILLINB ROOM SUMMARY. In Cue of Enos or Oeadou Abeat Your 111L If you think your bill is wrong, or 1 you reed more inforrratbn about a Insertion on your bill, write us at to BiIIIrg Eras address on this statement as soon as possible. We rust hearftom you no later than 50 days alter we send you to first bill on which tle error or problem appeared. You can telephone us, burl doing so will not preserve your rights. In your Idler, give us the iottaning idomation: • Your name and account number. • Thedollrxouddfesuapectederror. • Describe the mar and eaplain, if you can, why you bel ieve there is an error. I you reed more information, describe ft ban you am unsure about Pbese be sae all canespahdence is signed by to pprrmnry cardholder. You do not hve to pay any mod in question while we are 1rems ri BN you re sill ehKpsbd to Pay the parts of your bill that are not in question. Mlb win invielpis your question, we canal repot you or delinquent on the disaled tom or take any adkn to called to armed you question. Special role forCrslMCudhrutlua Kyou haveaprobInmwiththequality ofgoods aservimstdyou pudesad witha credit card, and you trove tied in good fafh to cored to probtan wdh the memdsel, you may not here to pay the remaining amount due on the goods or services. You have file protection only what the all address. (t prim we is or operant the and tmerclcat, or rt we is made in mailed you to alvertsemerd for are property or services, all purchases am covered regardless of arnuda locaton of purchase.) KEY CREDIT TERMS - NO Ii FIEST IF PAID IN RILL WITHIN B MONTHS*. $M Mel ream Pardase Required. Minimum Peryaaats Required. Interest will be tharped to your amotmt Imam Ire pattdaa dab N On pmebaae balance (installing premluats for optional adI Inuralra) In not paid In fill wRMo I moafhs or I lea mode a late payment. • ills credh approval for q u rcftases made on The Home Depot or EI Design Center Consumer Credit Card. For amounts In good standing, APft up to 26.99%. Prtally APR tit to 29.90% ay Very). MinimumIN?iDT "MMISE:$2.Lowerratesmayapply.SeecardagreementfordetailsincludingwhentheperiaOyrateapplies,Offerisonlyvalidforconsurrreraccountsandissubject (races may, to charge without ndlce. -- IMPORTANf PAYMT INSTRUCTIONS. CrelRbg hynude. M mud receive your mailed payment in proper tom at our processing facility by 5 p.m. local time thane. K we do, twill be credibd as of Vol day. (Rasa too to ft top rigid hand comer on to bunt at your samrrwn for processing b cilfy Ikea zoo.) A payment received d the practising facility in properform after thattime will be credited as of the nerd day. Allow 5 to 7 days for payneds by regular mail to reach us There may be a delay of up to 5 dip in ring a payment we receive td is not in proper form or is not sort to the correct addreti. The correct address for a payment sent by regular mail is the address listed on the return envelope OF on the front at the payment coupon. A payment made In store Is not sent to tie correct address. The oared address for a payment sent by caller or express mat I is to 6press Payments Address shown below. Proper Far. For a payment serd by mall or courier to be In proper form, you mud: • Ewen a valid deck or money order made payable to Home Depot Credit Services. No rash, phi cards, or foreign aurency place. • Include yor name and amount reenter ontre hod olyour deck a worry order. aetbenn b u lsls r PAYMENT OPTMNS OTHER THAN REGULAR MALL. • Online P"momk. Visit myhomedepoacown eom and sign up for free online payments. Enrollment nay take atewdoys. Iwwe receive your request to make an online peyrrent by4ro. Eatemfirne, we will credit yaw payment as of Ihm day and twill pW Min three bnimso days. I we misiveyor request b male an onlne psyme1 aka final tae, we will credit your payment as of the near day and K will post within three businaa days. For security reasons, you may be unable to pay your entire New Balance with your lbat online payment. • Pay by Pbom Saralee. You my we tlsserAceaytirre to mama payment by phone, ifyour amount iso igible. You will be charged $1495 to use this servka Call by 5 p.m. Easter time to them you payment cradled as of that day and posted witthin three business drys. I you all after f d line, you payrned wi 11 be credited as of ft road chy and posted with three business drys. We may process yaw payment eWronlcaty aber we verly your W*. • Exiooae hymsi You can send paymait by courier or express mail to the Express; Payments Address: Cudomer Safi Center, AM*n: Payment hail Opening, 9725 W. Sahara Ave., has Vegas, ill 017. Payment meat be received in proper form at the proper address by 5 pm. Patilic time to be credited as of that day. All received in props form at to proper address dbritd lime will be credited as at the next day. payments N YOU read an dooms abut MEN iris paynaat urpn, yu u Imp yea - payment by elaYOk dsbA.11 we do, tbs ehsddnt mount will bur dsbiW In use moral on to • In INon Poyrusls. For your added uronvriience, payments an be made all The Hone Depalw slows with no ebur. We my do this as urn u are illative resolve the shear. Also, the shun will be duffl". service to. Payments made at the store prior to are store closing time will be posted to your amaxd as of that day Cop Fes- We large $5 for each copy at a bi Rig sebmenl the daces back 3 months or more. We add the tse but avdlati ly may be subject to verification d funds. to abalaniceof our choosing. ft reserve the right toadditfeetobalanressubjeritoahigher annual percentage REPORT ALOST OR STOLEN CAM IMMSM7&Y.You maycall CustomerSe rvice 24hours aday, rat ft waive to lee If your request for the copy relates to a hitting error or disputed purchase. 7 days a week. HOJEX FEa10 Page 2 of 4 Account: **** **** **** 4544 TRANSACTIONS Trans Date Description Reference # Amount FEES 03/24 LATE FEE $ 39.00 TOTAL FEES FOR THIS PERIOD $ 39.00 INTEREST CHARGED 03128 Interest Charge on Purchases $ 47.42 TOTAL INTEREST FOR THIS PERIOD $ 47.42 F7 ANNUAL PERCENTAGE RATE on the account: 29.99% 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. 4y_ INTEREST CHARGE CALCULATION Your Annual l Percents Rate (APR) is the annual Interest rate on your account. f1 _ • `; L " 0-004 Revolving Balance 29.99% (M) $1,803.93 $47.42 CWD Z co Z oZ co Z I ?Z A Z -4 Z W Z o I °OZ N z z Z Z Z Z Page 3 of 4 Account: **** **** **** 4544 Page 4 of 4 Verification I, /lark 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. d Signature C-38627 Anthony R Stiles Account number ending in 4544 1025 SHERIFF'S OFFICE OF CUMBERLAND COUNTY ?) Ronny R Anderson FILtD Sheriff 0011 G 'H1"? rTHONCITAR' I` Jody S Smith Chief Deputy `?1M 9: 11 Richard W Stewart Solicitor P 7 -1E' ,? !rf M Citibank (South Dakota) N.A. Case Number vs. 2010-5672 Anthony R. Stiles SHERIFF'S RETURN OF SERVICE 09116/2010 08:18 PM - Michael Bardck, Deputy Sheriff, who being duly sworn according to law, states that on September 16, 2010 at 2018 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Anthony R. Stiles, by making known unto himself personally, at 313 W. Shady Lane, Apartment F, Enola, Cumberland County, Pennsylvania 17025 its contents and at the same time handing to him personally the said true and correct copy of the same. MICHAEL BAR CK, DEPUTY SHERIFF COST: $41.50 September 17, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF ;ci GountySuite She,rfP, Teloosoft. Ir?r. t CTTIBANK (SOUTH DAKOTA), N.A. 701 East 60th Street N, Sioux Falls, SD 57117 Plaintiff v. ANTHONY R STILES 313 W Shady Lane Apt F Enola PA 17025-2259 Defendant 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 IN THE COURT OF COMMON PLEAS c~ PENNSYL~~N Y Ifi , CUMBERLAND COUNT °.~ w5 ~ a ~ -n '" ° ~~ ~ e3 NO. 10-5672 CIVIL TERM u,,. i J':;'a ~.> ~,. ,~:= c--~ ~y ~~ ~ = n ~ ~ ~ ~ CN1L ACTION -LAW r~ ;`e{ ~_ - ~ ~; ~ $1,861.46 $1,861.46 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/% 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 re~rotnono 111111 Burton Nei~& Els's~ciates, P.C. By: The law firm of Burton Neil & Associates is a debt collector. C-38627 Yale .Weinstein, Esquire Atto ey for Plaintiff I.D. O. 89678 10 Andrew Drive, Suite 170 W st Chester, PA 19380 l~. 00 P D A">y`1 e~ 87109 ~,'~ a.505~ ~C~ ~IQti(tc~ t - - ~.-.__.. _ .._..,......,..._,._.... CITIBANK (SOUTH DAKOTA), N.A. : 1N THE COURT OF COMMON PLEAS C-38627 Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 10-5672 CIVIL TERM ANTHONY R STILES Defendant :CIVIL ACTION -LAW TO: Anthony R Stiles 313 W Shady Lane Apt F Enola PA 17025-2259 DATE OF NOTICE: October 13, 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 (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. Burton Neit'~i ~soEi~tes, P.C. Ya1L D. Wei ein, Esqu Attorney f laintiff Identification No. 89678 l Ob0 Andrew Drive, Suite l 70 West Chester, PA 19380 (6 i 0) 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 v. ANTHONY R STILES Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 10-5672 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 on ~l ~~ ~/n Prothonot By: Deputy If you have any questions concerning the above, please contact: Yale D. Weinstein, Esquire Attorney for Parry 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.