HomeMy WebLinkAbout10-6044d - L OF F I CE_
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Burton Neil & Associates, P.C.
By: Trenton A. Farmer, Esquire ID. NO. 209422
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.
RICHARD WRIGHT
724 Middle Lane, Camp Hill PA 17011
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. !b - 100q y l._??
I tvi?
: 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 v ?.no
Carlisle, PA 17013 ^T'(
Telephone No. 717-249-3166 or 800-990-9108 CIG 81,753
C-40627
Burton Neil & Associates, P.C.
By: Trenton A. Farmer, Esquire ID. NO. 209422
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.
RICHARD WRIGHT
724 Middle Lane, Camp Hill PA 17011
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO.
CIVIL ACTION - LAW
Complaint
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 Richard Wright, who resides at 724 Middle Lane PO Box 664, Camp
Hill, 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 7179 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 $8,742.88 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 $8,742.88, and
the costs of this action.
Burton Neil & Associates, P.C.-
BY:
Trenton A. Farmer, Esquire
Attorney for Plaintiff
The law firm of Burton Neil & Associates, P.C. is a debt collector.
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date p;Io pai.1--- --cnecM a -- --
www.citicards.com
New Balance:
$8,742.88
Minimum Payment Due:
$8,742A8 f
Payment Due Date:
05/23/2010
000000 MC 32 A 0
RICHARD WRIGHT
Po BOX 664
CAMP HILL PA17 001-0 664
N
Detach and follow Wyman WlStlyltt'ha on r...
Make check Wyakleto:Citl Cards
Account Number:
7179
Amount Enclosed:
Payment must be received by 5:00 PM
local Lima on the payment due date.
CITI CARDS
P.O. BOX 182564
COLUMBUS, OH 43218-2564
LANIT
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Verification
I Abbie Motley , 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 unworn falsification to authorities.
f
Signature
C-40627
Richard Wright
Account number ending in 7179
1000
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
~~,~~atc~ o'f ~uarit~~r~~~~
Jody S Smith
Chief Deputy
p<:
Richard W Stewart
Solicitor = F '` '`~ `~~'~"
Citibank (South Dakota) N.A.
vs.
Richard Wright
Case Number
2010-6044
SHERIFF'S RETURN OF SERVICE
09/27/2010 05:03 PM -Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on September
27, 2010 at 1703 hours, he served a true copy of the within Complaint and Notice, upon the within named
defendant, to wit: Richard Wright, by making known unto Kimberly Wright, Wife of defendant at 724
Middle Lane, Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time
handing to her personally the said true and correct copy of the same.
SHERIFF COST: $41.50
September 28, 2010
l
DENNI RY, DEPU
SO ANSWERS,
RON R ANDERSON, SHERIFF
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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. 10-6044 civil term
RICHARD WRIGHT `
724 Middle Lane
CD
pq
Camp Hill PA 170111721 !
Defendant : CIVIL ACTION - LAW `
; j
tn Z'
Praecipe for Default Judgment
To the Prothonotary:
r.j
;N0
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
$8,742.88
$8,742.88
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
A" TD DAMAGES ASSESSED AS ABOVE.
Nit ICE GJVEN UNDER PA.R.CIV.P. 236
'?)_ ? ) ?d
Pro Protho otary
Burton Neil As is C.
By:
Trenton A. Farmer, Esquire
Attorney for Plaintiff
I.D. NO. 209422
1060 Andrew Drive, Suite 170
West Chester, PA 19380
The law firm of Burton Neil & Associates is a debt collector.
C-40627
?? AA.
?`?CO
i1'5?'
o
CITIBANK (SOUTH DAKOTA), N.A. : IN THE COURT OF COMMON PLEAS
CA0627
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V.
NO. 10-6044 civil term
RICHARD WRIGHT
Defendant : CIVIL ACTION - LAW
TO: Richard Wright
724 Middle Lane
Camp Hill PA 170111721
DATE OF NOTICE: October 20, 2010
IMPORTANT NOTICE
You are in default because you have failed to enter a written appearance personally or by attomey 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 Neil & Associates, P.C.
Bic:../?
Trenton A. Farmer, Esquire
Attorney for Plaintiff
Identification No. 209422
1060 Andrew Drive, Suite 170
West Chester, PA 19380
(610) 696-2120
Burton Neil & Associates, P.C.
By: Trenton A. Farmer, Esquire ID. NO. 209422
1060 Andrew Drive, Suite 170
West Chester, PA 19380
610-696-2120
Attorney for Plaintiff
CITIBANK (SOUTH DAKOTA), N.A.
Plaintiff
PENNSYLVANIA
V.
RICHARD WRIGHT
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY,
NO. 10-6044 civil term
: 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 114 4 /d
If you have any questions concerning the at
Trenton A. Farmer, 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.