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Home My WebLink About04-3887 o BURTON NEIL & ASSOCIATES, P.C. By: Burton Neil, Esquire Identification No. 11348 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 Attorney for Plaintiff CITmANK (SOUTII DAKOTA) N.A. 701 East 60th Street North, Sioux Falls, SD Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA v. JUDITH G NORRIE 1126 Linn Drive, Carlisle PAl 70 13-4248 Defendant NO. 64~ ~ ~ g7 ~ : 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, P A 17013 Telephone No. 717-249-3166 or 800-990-9108 C-2314 BURTON NEIL & ASSOCIATES, P.c. By: Burton Neil, Esquire Identification No. 11348 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff CITmANK (SOUTH DAKOTA) N.A. 701 East 60th Street North, Sioux Falls, SD Plaintiff IN THE COURT OF COMMON PLEAS v. CUMBERLAND COUNTY, PENNSYLVANIA NO. mDITH G NORRIE 1126 Linn Drive, Carlisle, P A Defendant : CIVIL ACTION - LAW Complaint 1. The plaintiff is Citibank (South Dakota) N.A., with place of business located at 701 East 60th Street North, Sioux Falls, South Dakota. 2. The defendant is Judith G Norrie, who resides at 1126 Linn Drive, Carlisle, Cumberland County, Pennsylvania. 3. Plaintiff, a national banking association, engages in various types of banking business including consumer lending through the issuance of credit cards. 4. PlaintitJ furnished consumer credit to the defendant by means of a credit card with account number 5491492014517506 hereinafter referred to as the credit card account. 5. Plaintiff maintained an accurate and running record of all debits and credits to the credit card account in its books of account. 6. Plaintiff mailed defendant a written statement each month which accurately stated the debits and credits to the credit card account for the prior billing period. 7. Defendant received the monthly statements from plaintiff for the credit card account including the statement attached hereto as Exhibit A statement without protest, dispute or objection. 8. Defendant in not protesting, disputing or objecting to the statements including the Exhibit A statement thereby assented and agreed to the correctness of the balance due on the credit card account so as to constitute an account stated. 9. The amount due plaintiff on the account stated, less credits, if any issued subsequent to the Exhibit A statement, is $15,788.01. Wherefore, plaintiff demands judgment against defendant for the sum of $15,788.01, and the costs of this action. n Neil, Esquire rney for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. 06/21/04 lMitlM~W;~i' $9999.99 iNE;w.ltiilfi $15788.01 ~i~~g 5ITE:KC-CL TM:CO-5000 06/01/04 ACID:KCB7150 17:27:52: JUDITH G NORRIE ATTNY ACCOUNT-CODE=LC34 CARLISLE 17013-4248000 MELLON P.O. BOX 8118 5 HACKEN5ACK, NJ 07606 -8118 PA Platinum Account Number 5491 4920 1451 7S06 Customer Service: 1-877-888-5132 PO Box 44167 Jacksonville. FL 32231-4167 S.1e Oat. Post Date Available Credit Line Cash Advance Limit $0 $25000 Amount Over liredU line Past Ou. '0.00 $3324.88 Activit, Since Lat statement Total Credit Line $25000 Statement! Clo,ln9 Oat. OS/26/2004 Reference Number @ Mellon Available Cash limit $0 Purch/Adv Minimum Due $333.00 Hew Balance $15788.01 Minimum Amount Due $15788.01 Amou.t Please note that payments must be received by 1:00 p.m., local time. on a bank business day at the payment processing facility that handles your payments. in order to be credited to your account as of that day, and ~avments must conform to the payment instructions set forth on the reverse side. All conforming payments received at the payment processing facillty after that time will be credited as of the following bank bus0gess day. Help is available! Please call the toll-free number shown above to learn about our special payment options. Call Monday - Friday. 7 am to 9 pm. or Saturday, 8 am to 5 pm. Central Time. Please give us the opportunity to assist you. Account SUmmary PURCHASES AOVANCES TOTAL Previous Balance $15,711.24 $76.77 $15,788.01 (+} Purchases & Advances fO.oo 0.00 0.00 (-) Payments & Credils fO.oo 0.00 0.00 R.t. Summary PURCHASES Standard Purch Offer 5 AOYANCES Standard Adv Offer 4 Balance Subject to Finance Charge Periodic Rate $0.00 $0.00 $0.00 $77.48 0.06573%(0) 0.06S73%(0) 0.06573%(0) 0.06573%(0) (+) FINANCE CHARGE fO.oo 0.00 0.00 (=) New Balance $15.711. 24 $76.77 $15,788.01 Days This 81111n9 PerIod: 29 Nominal ANNUAL APR PERCENTAGE RATE" 23.990% 23.990% 23.990% 23.990% EXH Jt3'~ Th 23.990% 23.990% VERIFICATION SUSAN CARS)' Attorney Management Specialist for Citibank (South Dakota) N.A. the within Plaintiff in this action, and that the statements of fact made in the foregoing Complaint are true and correct to the best of the undersigned verifier's 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 authorities. Date: 7/1ll~ .[. )w~.L ~i V Judith G. Norrie 5491492014517506 ~~ ~ ()} ~ -zS. DC' (/) ~ ~. ~ ,-,"" c- p~ '~ --=> C) r;:; <.~~) C~; ",/ u 0' ChCJ J v:- r' ~ :.;'''. ,~, .~ I (J', SHERIFF'S RETURN - REGULAR CASE NO: 2004-03887 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITIBANK SOUTH DAKOTA NA VS NORRIE JUDITH G SHANNON SHERTZER , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon NORRIE JUDITH G the DEFENDANT at 1800:00 HOURS, on the 12th day of August 2004 at 1126 LINN DRIVE CARLISLE, PA 17013 by handing to DONALD HENDRICKSON, ADULT IN CHARGE a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: ~~ .~ . 18.00 3.70 .00 10.00 .00 31.70 R. Thomas Kline 08/13/2004 BURTON NEIL Sworn and Subscribed to before By: & ASSOC # cj~~1/V\ t. Deputy SFieri me this I ",A" day of .Jf~ c211(J'1 A.D. r! ~,. 0. /r1'u,L-- ~ '- I Prothonotary . Re: Citibank vs. Judith Norrie No. 04-3887 Citibank vs. Donald Hendrickson l&D HENDRICKSON 1126 Linn Drive Carlisle, PA 17013 Bespons e. No. 04-3886 Civil Action Praecipe for Default Judgment To Whom It May Concern: Following is my written response to the claims set forth against me Please take this information into consideration when making your decision. Attached is also my budget sheet, which shows my current financial situation and a copy of the contract and POA I have signed with American Debt Negotiation & Settlements to settle my debts. It is my wish that a reasonable solution can be worked out through them. We currently live on a limited income. I was diagnosed with ovarian cancer in April 2003 and have undergone extensive medical procedures. Prior to this diagnosis, I was employed full-time to rectifY our debt. Due to the rigorous treatment schedule along with side effects, I am no longer able to work. My husband was diagnosed with bladder cancer in 200 I and recently had a cancerous tumor removed from his arm in December 2003. Initially, we attempted to contact our creditors to ask for assistance; that due to our situation our finances were tight and we requested to possibly adjust, lower our payment or interest rate to assist in alleviating our financial struggle. We were informed by the representatives that there was nothing they could do because we were still current and would need to be past due on our accounts. In an effort to avoid bankruptcy because we had always been responsible people in rectifYing our debts, we turned to American Debt Negotiations & Settlements, LLC (now NLDC) to help us with our financial situation. We regret that this action needed to be taken, but if we had not done this, we were looking at declaring bankruptcy immediately. We welcomed the opportunity for a more honorable way to resolve this serious situation, and want to do the best we can for the creditors affected. We thank you for your patience and understanding. Sincerely, ~U~/l~~,<<'7'1- Judith G. Norrie - Hendrickson ;21ndd /~/'c?t.~/.,----, A- Donald Hendrickson Budget Sheet Income vs. Expenses Client Name: Judith G. Norrie and Donald Hendrickson Total Monthly Income: Retirement Social Security (1) Social Security (2) TOTAL: Monthly Expenses: Home Payment Home Insurance Car Payment (I) Car Payment (2) Car Insurance (I) Car Insurance (2) Health Insurance Dental Insurance Life Insurance: AAA Legions Veterans PremPlus (I) PremPlus (2) Walmart life ADNS Payment Utilities (electric/water) Telephone Medication (approx) Food Gas for Car 550.00 1200.00 1050.00 $2800.00 884.26 47.33 477.18 550.03 56.83 56.39 187.66 55.44 150.09 8.17 25.98 30.50 22.20 13.20 50.04 1300.00 337.00 40.00 240.87 400.00 100.00 245.00 Hospital Exp/Dr. Bills (7 doctors per month) Misc. Expenses 100.00 (glasses, hearing aid expenses) TOTAL EXPENSES: $5,228.08 As you can see our total monthly expenses far exceeds our monthly income. Weare fortunate to have two children who provide monetary support to supplement our income in assisting with expenses. However, our children are not able to harbor our debts to our creditors as well. FAX TO: (818) 238-0012 Attn: Annette Hochman ADNS APPLICATION FOR SERVICES 1. ENGAGEMENT. The undersigned ("Clientn) hereby applies for Debt Negotiation Services and grants to American Debt Negotiation and Settlement ("The Company") the exclusive right to negotiate with The Client's creditors, and to settle creditors' claims. The Company shall not have the right to bind Client to any settlement without Client's prior consent. The Company does not furnish any legal advice or legal services, nor advise Client regarding any legal issues or as to the legal effect of any settlement. AU infonnatiOl1 regarding Client's financial condition is the sole responsibility of Client. Client understands it is important to immediately discontinuc all electronic debits that their creditors are deducting from their checking accounts. Client agrees to indenmify and hold The Company and its principals harmless from any liability incurred by The Company based on false or misleading information provided by Clieut. 2. DEBTS TO BE SETTLED. The Client has provided The Company a list of Unsecured Debts to be negotiated by The Company totaling approximately 5130.000.0q The Client Attests that tbese are all of their Unsecured Debts, unless otherwise mentioned herein. 3. MONTHLY DEPOSITS. The Client will make monthly deposits of51.300.00. The funds will be transmitted via check each month to a Client Reserve Account for the purpose of settling the debts, in approximately 48-60 months, or less if there is a mortgage refinancing, or some other form oflump sum that may be applied toward settling the unsecured debts more rapidly. It is understood that this is an estimate only and that The Company will make best efforts to settle The Clients debts within this time and that The Client can accelerate settlements by making additional deposits, at any time. 4. FEES. The Client agrees to pay The Company fees, as follows, which are deducted from their Monthly Deposits, which remains the same throughout the term of this agreement, however may be added to in order to accelerate settlements: a. The Company shall be entitled to a fee in an amount equal to twenty five percent (25%) of the differencc between the creditor's claim and the amount, which the creditor agrees to accept in full settlement of its claim.1fthe settlement is for payment of the full amowlt ofthe creditor's claim, but the settlement calls for installment payments. or for one or more deferred payments, then the Company shall be entitled to a fee in an amount equal to seven percent (7"10) of the amount ofthe creditor's claim. All settlements must be agreed upon and signed by The Client and The Company, prior to funds being released from the Client Reserve Account. b. Client agrees to pay a One-Time Nonrefundable Set Up fee equivalent to 3.5% of their total Unsecured Debt amount to be managed by The Company. c. Client agrees to PtIy a Service Fee of Fifty Dol1ars ($50.00) per month for the first ten accounts and Five Dollars ($5.00) per month for each account over ten (10). This monthly fee will entitle the client to ful1 service of their account for the life of their account. This includes but is not limited to full client services, full ereditor services. AIl,r'- Initial Here: tT VV ""' 800!1:00 Ifl xv ~ B8: ~o POOllOllpo 5. RESPONSffiILITlES OF TIIE COMPANY AND CLIENT. The Company ..ill perform the services called for under this contract, keep Client informed of developments. and respond promptly to Client's inquiries and communications. Client will be tnlthful and cooperative with The Company, keep The Company reasonably informed of developn'ents, and of its address, telephone number, and whereabouts; and Client will timely make anJ' and all payments required to be made under this contract. 6.NO GUARANTEED OUTCOME. The Company will perform professional negotiation services on Client's behalf to the best of its ability, however The Company cannot make and has not made any guarantees regarding results, Client understands that Clients credit rating can be affected due to the nature of these negotiations. The Company's expressions about the outcome of any matter are its best professional esrimates only, and are limited by its knowledge at the time they are expressed. 7 . TERMINATION, The Company may withdraw from representing Client if Client fails to promptly pay The Company's fees, if Client misrepresents or fails to disclose any material facts, if Client acts contrary to The Company's advice, if Client does not retum The Company's phone calls in a timely manner, or if anything else occurs that in The Company's judgment impairs an effective relationship. Client shall have the right to terminate The Company's services at any time, effective on thirty (30) day's written notice. 8. FEES ON TERMINATION. In the event of the termination of this ContraCt by cither party, any accrued fee. shall be immediately due and payable. If Client agrees to a settlement with any creditor within one year after the termination of this Contract, on terms substantially the same as those negotiated by the Company, and presented to Client before termination ofthi. Contract, then the Company shall be entitled to the payment of all fees as though this Contract had not been terminated prior to Client's agreement to the settlement. 9. RETURNED CHECK FEE. There will be a fee of $20.00 charged for any returned check. 10. LEGAL DISPUTES. In the unforeseen event of any dispUte arising out of, or relating to this Contract, both The Client and The Company agree to resolve the dispute with neutral binding arbitration in accordance with the laws of the slate of Alabama. In the event that any provision hereof is detennined to be illegal or unenforceable, such determination shall not affect the validity or enforceability of the remaining provisions hereof, an of which shan remain in full force and effect. This Agreement constitutes the entire agreement between The Company and the Client relating to the specific subject matter hereof. There are not temlS. obligations, covenants, representations, statements, or conditions, other than those contained herein. No variations or modifications of this Agreement or waiver of any of the terms of provisions hereof shall be deemed valid unless in writing and signed by both parties. I have read, fully understand and agree with all terms and conditions Slated above. 'u<.- tk~: 6-;;f.03 ~Juh Client Signaturc(s): Client Name(s); Accepted by; coo/coo IfJ XYJ ac:zo pooz/oz/po SPECIAL POWER OF ATTORNEY I, J\J~;-l'~ /lJf.U.;t..-II&~h'/cI<~t1~,Born .5'/1'// SS:~SocialSecurityNo. I r:;~ -...JQ..- /1/1 do hereby appoint American Debt Negotiations and Settlements, LLC (its employees, assigns and/or agents, hereafter ADNS) located at 1317N. San Fernando Blvd. #531, Burbank, CA 91504-4272, as my true and lawful attorney in fact for me and in my name and for my use and benefit for the following purpose and with the following powers and none other: Any and all transactions relating to negotiation with my creditors for the purpose of settling their claims against me. Notwithstanding the foregoing, however, no settlement shall be binding on me without my prior written approval. ADNS (and its appointees) are also authorized to do all things reasonably necessary and appropriate to exercise the authority granted to it under this Power of Attorney. In addition, I hereby appoint and authorize ADNS to request, review, and receive any information, verbal or written, regarding my accounts, via internet, fax and/or Mail. This power of attorney shall commence on the ..< 7 day of _ J U AJ(. . ;;'00,7. This Power of Attorney revokes all earlier powers of attorney given by, or on behalf of me relating to the negotiation and settlement of creditors' claims (except for powers, if any, given to Attorneys at law); and shall be effective, and binding on me until revoked by an instrument in writing executed by me. Signed under penalty of perjury of the laws of the State of~"r>S,// flfil'li IJ that the foregoing is true and correct. Executed this .;l7 day of JU)lt.. (' vrnA t LLAtll', , State of , .;loo3 in the County of -:J>A- 7~cM I1avu, -~ (Client) \) ud:4.. JJ,,#;t-/HA.tIf~ted Name) ~ (Wi-) ,.Iou~" Io/.U-" (PrintoIN_J _ ~ (Witness) Af;c~ lu/I 'or!'.,,!') (Printed Name) . - SPECIAL POWER OF ATIORNEY I, :J)otJA.l.1> ,,/',,-,,//:r,k..J OM . Born/d....Jll!~---' Social Security No. .J I V -,;71 -.,;1,:2 U-ao hereby appoint American Debt Negotiations and Settlements, LLC (its employees, assigns and/or agents, hereafter ADNS) located at 1317 N. San Fernando Blvd. #531, Burbank, CA 91504-4272, as my true and lawful attorney in fact for me and in my name and for my use and benefit for the following pUIpOse and with the following powers and none other: Any and all transactions relating to negotiation with my creditors for the pUIpOse of settling their claims against me. Notwithstanding the foregoulg, however, no settlement shall be binding on me without my prior written approval. ADNS (and its appointees) are also authorized to do all things reasonably necessary and appropriate to exercise the authority granted to it under this Power of Attorney. In addition, I hereby appoint and authorize ADNS to request, review, and receive any information, verbal or written, regarding my accounts, via internet, fax and/or Mail. TIlls power of attorney shall commence on the ,;)7 day of J \A,..(.. . ~o3. TIlls Power of Attorney revokes all earlier powers of attorney given by, or on behalf of me relating to the negotiation and settlement of creditors' claims (except for powers, if any, given to Attorneys at law); and shall be effective, and binding on me until revoked by an instrument in writing executed by me. Signed under penalty of perjury of the laws of the State of ;)(",,<...., J 4'1 ;/<" that the foregoing is true and correct. r recuted thisdL day of ~ JWL ,,~L.<I'" D . State of , ;).00:1 in the COlmly of +='Ir ~eM4~~"JH' ~'~ ... ~4t~ (Client) .UON}hD UinO~.~...,,j (PrintedName) (Witness) {"" JtJt /~Al Nor/,'(... (Printed Name) (Witness) JJ.cJ( :n 11'0".(;/70') (Printed Name) (") ~; < -0'-;-:; ~..\:," ~rrl 2~i'::::~ (j)':';" (:$ ;;: .._('i ;i> .,-~ "?" l; ","',-', j;.x! c;:; $ . ....., = = .c- (/) ....., -U '" -.J (") -n --f It"! nl-' - Fi :8ci.j C' r _~~n - .,;:<"' "'... -i' 1,:)_,..1 5fT~ ,--1 I" ,,"<'-, :.< "" :x 9 N 0". ..' . BURTON NEIL & ASSOCIATES, P.C. Yale D. Weinstein, Esquire, Id. no. 89678 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attornev for Plaintiff CITIBANK (SOUTH DAKOTA) N.A. Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 04-3887 JUDITH G. NORRIE Defendant: CNIL ACTION - LAW Motion of Plaintiff for Judgment on the Pleadings Now comes plaintiff by its undersigned attorneys, and moves this Honorable Court pursuant to Rule 1034 of the Pennsylvania Rules of Civil Procedure, for judgment on the pleadings and in support thereof states: 1. Plaintiff filed a complaint against defendant for the credit card account balance due it. 2. Defendant filed an answer to the complaint. 3. The pleadings are closed. 4. There are neither factual nor legal issues before the Court creating a need for trial. Therefore, plaintiff is entitled to judgment as a matter of law. Wherefore, plaintiff moves this Honorable Court for judgment on the pleadings. BURTON NEIL & ASSOCIATES, P.C. In making this communication, we advise our firm is a de t ollector. eins ,squire for Plaintiff ----- .-,-'" o c: " -::)': Q)f' :2: !, . U>.', -<:' r;:,_ ~~. ~-:.'" :r> '" . L;:. ~-, -;> '-, ,..., = 5: """ -0 "'" ", cr- -0 ~ o -n :r-n P'E :::;8 S~Qi -:--:...,., (~~~, '.:::... ,> '.'n :< - ()1 <.n - PRAECIPE FOR LISTING CASE FOR ARGUMENT {Must be typewritten and submitted in duplicate) TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please list the within matter for the next Argument Court. -------------------------------------------------------------------------------..-------------------------------------------- CITIBANK (SOUTH DAKOTA) N.A. Plaintiff vs. mDITH G NORRIE Defendant NO. 04-3887 Civil 1. State matter to be argued (i.e., plaintiffs motion for new trial, defendant's demurrer to complaint, etc.): Motion for Judgment on the Pleadings 2. IdentifY counsel who will argue case: (a) for plaintiff: address: Burton Neil, Esquire c/o Burton Neil & Associates, P.C. 1060 Andrew Drive, Suite 170, West Chester, PA 19380 b) for defendant: address: pro se 1126 Linn Drive, Carlisle, PA 17013-4248 3. I will notifY all parties in writing within two daYSlhat"th7:ase has been listed for argument. Argument Court Date: August 24:, 2005 i / / B4~~, Attorney for the Plaintiff 4. The law firm of Burton Neil & Associates is a debt collector. BURTON NEIL & ASSOCIATES, P.C. By: Burton Neil, Esquire Identification No. 11348 1060 Andrew Drive, Ste 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA) N.A. Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 04-3887 JUDITH G NORRIE Defendant : CIVIL ACTION - LAW CERTIFICATE OF SERVICE I, Burton Neil, Esquire do hereby certifY that a I served a true and l:orrect copy of the within Praecipe for Argument on defendant Judith G Norrie at her address of record via first class mail, postage prepaid on the date set forth below. I ~ 1-4./ D~ IL & ASSOCIATES, P.C. Date: "BY: i Burton N~, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates is a debt collector. " .., =- 'z;\ '-- S~i ...-,- r" -' '~S -<. " .... -- .~, _:.-'" o -n _-I ~~ ~rlcJ ~:;~, ~? ;-,)-.:;} -,,: () '4~P") '::.:::~ '21 :-,:,;.: <!? o N - BURTON NEIL & ASSOCIATES, P.C. BY: Yale D. Weinstein, Esquire Identification 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, PENNSYL V ANM. VS. : NO. 04-3887 JUDITH G NORRIE Defendant : CNIL ACTION - LAW PRAECIPE TO DISCONTINUE TO THE PROTHONOTARY: Kindly discontinue the above-captioned action without prejudice. B . . einstein, Esquire orney for Plaintiff The law firm of Burton Neil & Associates is a debt collector. 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