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Home My WebLink About10-6144FII-ED-0 F IG'_ OF - r!IE F't"'R0Ti 0 6-TA o ?949 SEP 2'} FH l2. 00 °Erk114S 'I,_VA 14 1A 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 FIA CARD SERVICES, N.A. Ma BANK OF AMERICA, N.A. (USA) 4161 Piedmont Parkway Greensboro, NC 27410 Plaintiff V. SANDRA R OKUM 1 Nita Court, Mechanicsburg PA 17050 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA II : 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. 119486 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 49a 02 K---d CC- wolgql'o r ov R_V?qg 7S4 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 FIA CARD SERVICES, N.A. f/k/a BANK OF AMERICA, N.A. (USA) 4161 Piedmont Parkway Greensboro, NC 27410 Plaintiff V. SANDRA R OKUM 1 Nita Court, Mechanicsburg PA 17050 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION - LAW Complaint 1. The plaintiff is FIA CARD SERVICES, N.A.f/k/a BANK OF AMERICA, N.A. (USA), a national banking association with place of business located at 4161 Piedmont Parkway, Greensboro, NC. 2. The defendant is Sandra R Okum, who resides at 1 Nita Court, Mechanicsburg, Cumberland County, Pennsylvania. 3. Plaintiff furnished consumer credit to defendant by means of a credit card with account number ending in 66.55, which was subsequently changed to account number ending in 5914. 4 Defendant accepted the credit card account by making purchases, balance transfers and/or cash advances. 5. Monthly statements were sent to defendant each month which detailed the charges and credits made to the credit card account for the prior month. 6. The balance due on the credit card account is $9,205.99. 7. Defendant did not pay the balance due on the credit card account in full upon receipt of the monthly billing statements and also did not make the required minimum monthly payment set forth in the monthly billing statement. As such, defendant is in default on the credit card account. 8. Although demand has been made by plaintiff upon defendant to pay the sum of $9,205.99, defendant failed and refused to pay all or any part thereof. Wherefore, plaintiff demands judgment against defendant in the sum of $9,205.99 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. Verification is for FIA CARD SERVICES, N.A. f/k/a BANK OF AMERICA, N.A. (USA), the within plaintiff in this action. He/she verifies that the statements of fact made in the foregoing pleading are true and correct to the best of his/her knowledge and belief. The undersigned understands that the statements made herein are subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to the authorities. Date: +,?- 7-5 -k,69 119486 Sandra R Okum Name d "?a D( V% SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ~~titr of ~'~taabcr~~ Jody S Smith lr~ ~~ Chief Deputy ~ i ~ ` `? ~ ~"' z~: Richard W Stewart '° Solicitor c~~F~cs ~F r"E s~~~F,it= FIA Card Services vs. Case Number Sandra R. Okum 2010-6144 SHERIFF'S RETURN OF SERVICE 09/27/2010 07:38 PM -Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on September 27, 2010 at 1938 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Sandra R. Okum, by making known unto herself personally, at 1 Nita Court, Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time handing to her personally the said true and correct copy of the same. ,.---~ _ G NOAH CLINE, DEPUTY SHERIFF COST: $37.00 September 28, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF .~ ~ ~ -~r~ r ~ r n :~= ~ -v ~, ~ ~~ .~ ~a -v ~ -,-~ ~ ~ ~~ -.~ -;~ ~ ~ ~ ~~ ~ ~.~ n;~ c~ (cl GountySuite Shenfl. Teleosofi_ Iro. In The Common Pleas Court of Cumberland County State of Pennsylvania Plaintiff: FIA CARD SERVICES Case Number: 10-6144 (BANK OF AMERICA) c% Burton Neil & Associates, P.C. c-~ 1060 Andrew Drive, Suite 170 ~ ° ''~ West Chester, PA 19380 ~ Defendant: Sandra Okum ~~ ~a y ~ ~~ 1 Nita Court a o ~ o Mechanicsburg, PA 17050 zo ~ ~ sy= = o~ ANSWER TO COMPLAINT ."'~ ~° COMES NOW the defendant in the above styled cause to answer the Plaintiff's Complaint as follows: In 2007 my husband, Ronald Okum, was laid off from his job for about 6 months before finding another job. During this time I was able to pay the bills and on time. Since his new job paid significantly less than his previous job it was getting more difficult to keep up with the bills and.make timely payments. I was forced to "rob Peter to pay Paul". However, then the interest rates went up and the payments requested per month went much higher. I did my best to keep up but finally had to resort to Freedom Debt Relief to handle the account. Then in August of 2009 my husband was laid off again from his job for nine months. He did find work again in May of 2010 but again, at a significantly lower pay. I am trying to avoid bankruptcy. I generally disagree with the attorney fees and court costs. Dated this 15~' day of October, 2010 Respectfully submitted, CERTIFICATE OF SERVICE I, the undersigned, hereby certify that I have served the Plaintiff or its attorney with a copy of this pleading by US Mail, postage prepaid, on this 15m day of October, 2010. ,a^` 6~.' A=IL ED-OFF3G"E d s_ i 2011 FEB 18 PM 12: 2 7 P -..+. c+Ji t ?. Burton Neil & Associates, P.C. By: Edward J. O'Brien, Esquire ID. NO. 32985 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff FIA CARD SERVICES, N.A. BANK OF AMERICA, N.A. (USA) Plaintiff V. SANDRA R OKUM Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 10-6144 CIVIL TERM CIVIL ACTION'- LAW Praecipe to Settle, End, & Discontinue To the Prothonotary: Mark the above matter Settled, Ended and Discontinued. Burton sociates, P.C. By: Edward J. O'Brien, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates is a debt collector. 119486