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Home My WebLink About11-3303 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 CITIBANK (SOUTH DAKOTA), N.A. 701 East 60th Street N Sioux Falls, SD 57117 Plaintiff V. ?J ::' THE P OTMONOTAR`f 201 11 r. P28 PM I: 12 rUMBERLAND COUNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PATRICIA A ERDMAN NO. f 1- 3SCS Ci Vl 1419 Yorktown Road Mechanicsburg PA 17050-1951 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 Telephone No. 717-249-3166 or 800-990-9108 C-49104 S) at ,1& Ra c'?1 oA?- 81L#08873 PC257 I V 7 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 CITIBANK (SOUTH DAKOTA), N.A. 701 East 60th Street N Sioux Falls, SD 57117 Plaintiff V. PATRICIA A ERDMAN 1419 Yorktowne Road Mechanicsburg PA 17050-1951 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 Patricia A Erdman, who resides at 1419 Yorktowne Road, Mechanicsburg, 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) CITI MASTERCARD credit card with account number ending in 1549 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 $21,761.41 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 $21,761.41, and the costs of this action. Burton Neil & sociates, P.C. By: 'Edw'ard rien, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. www:citicards.com r '® III 1549 1/06/11 21761.41 $3407.91 20 V1 0296 1 MC 4 PATRICIA A ERDMAN 1419 YORKTOWNE RD MECHANICSBURG 17050-1951000 CITI CARDS P.O. BOX 182564 COLUMBUS, OH 43218-2564 PA c ?9iay Citi® Dividend Platinum Select' Card Account c rd 1549 www.citicards. Summary of Account Activity Previous Balance Payments Other Credits Purchases Cash Advances Fees Charged Interest Charged New Balance Past Due Amount Amt. Over Credit Limit Credit Limit Available Credit Cash Advance Limit Available Cash Limit Statement Closing Date Days in Billing Cycle Customer Service: 1-800-866-9900 BOX 6500 SIOUX FALLS, SD 57117 Payment Information Payment must be received by 5:00 PM local time on the payment due date. $21,390.00 New Balance $21,761.41 - 0.00 Minimum Payment Due $3 407.91 - 0.00 1 Payment Due Date 01/66/2011 + 0.00 + 0.00 +$35.00 Late Payment Warning: If we do not receive payment by the date listed above ou ma your minimum hav t +$336.41 , y yy late fee of up to $35 and your APRs may be to th i bl e o pay a increased up e var a e Penalty APR of 29.99%. $21,761.41 $2,238.09 Minimum Payment Warning: If you make only pa ment each period, yyou will pay more in w ll t k l the minimum interest and it $581.41 i a e you onger to pay off your balan ce. For example: If you make no You will pay additional charges off the balance And you will end u i $21,180 using this card shown on this p pay ng an estimated total $0 $10 9 0 and each month you statement in a of... , $0 p y... about... 12/08/2010 Only the minimum payment 32 year(s) $50 417 30 , $715 3 year(s) $27,997 (Savings= $22,420) If you would like information about credit counseling services, call 1-877-337-8188. Sak Date Post Date Reference Number Activity Since Last Statement Amount Fees 12/08 LATE FEE - NOV PAYMENT PAST DUE TOTAL FEES FOR THIS PERIOD 35.00 35.00 Interest Charged 1208 INTEREST 12/08 INTEREST CHARGED TO PURNPRR10/29110. TOTAL INTEREST FOR THIS PERIOD 2010 Totals Year-to-Date Total Fees charged in 2010 130.00 Total Interest charged in 2010 3,371.54 ****Dividend Dollars Summary**** Previous Statement Dividend Dollars Total 21.47 Base Dividend Dollars Earned 0.00 Total Dividend Dollars Earned this period 0.00 Total Dividend Dollars Available 21.47 0.55 335.86 336.41 EXHIBIT-? SEND PAYMENTS TO: PLEASE REFER TO THE REVERSE SIDE OF THE ORIGINAL STATEMENT FOR PAYMENT INFORMATION. 451 WWW:Citicards.com 20 V1 0296 1 MC 4 PATRICIA A ERDMAN C tl® Sale Date Post Date Reference Number Activky Since Last Statement Amount Your account is seriously past due and your credit privileges have been suspended. Please call the toll-free number shown above to learn about our special payment options. Call Monday - Friday, 7 am - 9 pm, or Saturday, 8 am 5 pm, Central Time. Please be sure to pay on time. If you submit your payment by mail, we suggest you mail it no later than 12/30/2010 to allow for enough time for regular mail to reach us. Interest Change Calculation Type of Balance PURCHASES Standard Purch Purch Prior 10/29/10 ADVANCES Standard Adv Your Annual Percentage Rate (APR) is the annual interest rate on your account. Annual Percentage Balance Subject to Rate (APR) Interest Rate Interest Charge 18.990%(V) $35.27(D) $0.55 18.990%(V) $21,516.89(D) $335.86 25.240%(V) $0.000) $0.00 SEND PAYMENTS TO: PLEASE REFER TO THE REVERSE SIDE OF THE ORIGINAL STATEMENT FOR PAYMENT INFORMATION. 451 Verification I, 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. C-49104 Patricia A Erdman Account number ending in 1549 1008 Patricia A Erdman, Pro Se 1419 Yorktowne Road Mechanicsburg, PA 17050 ri c N C= c IN THE COURT OF COMMON PLEAS OF THE COMMONWEALTH OF PENNSgIVVI I -n IN AND FOR CUMBERLANDCOUNTY? ?rn r -> Cn Cl ? q CITBANK S.D., N.A. q -r---n c7i _ _ C M Plaintiff, _< Co -c Case Number. 11-3303 CIVIL TERM V. PATRICIA A ERDMAN Defendant. ANSWER OF DEFENDANT Pro Se Defendant hereby enters her appearance and answers the Complaint: as follows: 1. Denied. The Defendant is without sufficient information or knowledge to form a belief as to this averment's veracity. 2. Admitted. 3. Denied. The Defendant is without sufficient information or knowledge to form a belief as to this averment's veracity. 4. Admitted. Although Defendant used the credit card, Defendant denies there an agreement exists between the parties. 5. Denied. Defendant is without sufficient information or knowledge to form a belief as to this averment's veracity. Defendant requests Plaintiff produce allocation of all payments, itemized list of charges and payments and itemized charges and fee added to the outstanding balance. 6. Admitted in part. Denied in Part. Defendant admits to receiving monthly statement but denies that the statements accurately contain balances. The statements contain illegal This document was prepared by or with the assistance of an attorney employed by Persels & Associates, LLC, 1-800-498-6761 charges for the Plaintiff benefit thus is not accurate. Monthly statements were created by Plaintiff and without Defendant or other third party involvement. 7. Admitted. Defendant refuses to pay illegal charges. 8. Denied. No agreement exists between the parties. WHEREFORE: The Defendant respectfully requests the Plaintiff's Complaint be dismissed and the relief requested in Plaintiff's Complaint be denied The Defendant Further Answers: 9. Defendant is a Pro Se Defendant during these proceedings. 10. Defendant does not want to avoid a valid debt owed to Plaintiff, but Defendant requires Plaintiff validate its standing and claims against Defendant. 11. Defendant further contests all finance charges and additional fees which are illegal, unreasonable and unconscionable whereby seeks relief that all such charges be voided retroactively. WHEREFORE: The Defendant respectfully requests the Plaintiffs Complaint be dismissed and the relief requested in Plaintiff s Complaint be denied NEW MATTER 12. Plaintiff s Complaint fails to state a cause of action upon which relief can be granted. 13. Plaintiff s Complaint is barred by the Laches Doctrine. 14. Plaintiff s Complaint is barred by the Unjust Enrichment Doctrine. 15. Plaintiff s Complaint is barred by the Estoppel Doctrine. 16. Plaintiff s Claims are barred by the Promissory Estoppel Doctrine. 17. The relief sought by Plaintiff herein if granted would violate public policy. 18. Plaintiff's Complaint is barred because the Defendant did not breach any agreement as a matter of law. 19. Plaintiff s Claims are barred by the applicable statute of limitations. This document was prepared by or with the assistance of an attorney employed by Persels & Associates, LLC, 1-800-498-6761 20. Plaintiff is not entitled to relief based upon any alleged contract, which is expressly denied, because Plaintiff failed to satisfy all conditions precedent to the enforcement of the provisions if such a contract existed. 21. The Answering Pro Se Defendant reserves the right to include additional New Matter which may become available during the course of discovery during this matter. WHEREFORE: The Defendant respectfully requests the Plaintiff's Complaint be dismissed and the relief requested in Plaintiff's Complaint be denied VERIFICATION The Defendant verifies the statements made herein are true and correct based upon his knowledge, information, and belief. The statements are made subject to the penalties under 18 Pa. C.S. Section 4904, relating to unsworn falsificatiomto authorities. y i WV Patricia A Erdman, Pro Se CERTIFICATE OF SERVICE The Defendant HEREBY CERTIFY that on this eS v day of r 1 h 20 iL, a copy of the foregoing pleading was mailed, first class, postage pre-pad to: Edward O'Brien, Esq 1060 Andrew Drive, suite 170 West Chester, PA 19380 t i Patricia A Erdman, Pro Se This document was prepared by or with the assistance of an attorney employed by Persels & Associates, LLC, 1-800-498-6761 '0N 0TA 7011 PR 27 N 11: 37 JMSERLAUD COUNT` PENNSYLVANIA BURTON NEIL & ASSOCIATES, P.C. By: Edward J. O'Brien, Esquire, Id. No. 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA) N.A. Plaintiff 32985 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. PATRICIA A ERDMAN Defendant : NO. 11 - 3303 CIVIL TERM CIVIL ACTION - LAW PLAINTIFF'S REPLY TO DEFENDANT'S NEW MATTER Plaintiff Citibank (South Dakota) N.A., by its counsel Burton Neil & Associates, P. C. hereby replies to defendant's new matter, served on plaintiff's counsel with neither notice to plead nor notice to defend, or so much thereof as is relevant as follows: 9. Denied as a conclusion of law to which no further response is required. To the contrary the statement at the foot of each page of the filing that says it was prepared by or with the assistance of an attorney employed by Persels & Associates LLC" belies it. To the degree this allegation is deemed factual or relevant, denied as after reasonable investigation, plaintiff is without knowledge or information sufficient to form a belief as to the truth of these allegations and the same are deemed denied. 10. Denied as a conclusion of law to which no further response is required. To the degree this allegation is deemed factual or relevant, denied as after reasonable investigation, plaintiff is without knowledge or information sufficient to form a belief as to the truth of these allegations and the same are deemed denied. By way of further response, this allegation pleads no facts therefore it is denied under Pa. R. C. P. 1029( b ). 11. Denied as a conclusion of law to which no further response is required. By way of further response , as a matter of law plaintiff's finance charges and fees are valid, proper, past due and collectible from defendant. By way of further response, this allegation pleads no facts therefore it is denied under Pa. R. C. P. 1029( b ). 12. Denied as a conclusion of law to which no further response is required. By way of further response, to the contrary as courts all over the Commonwealth have determined plaintiff's complaint is legally sufficient. By way of further response, this allegation pleads no facts therefore it is denied under Pa. R. C. P. 1029( b ). 13. Denied as a conclusion of law to which no further response is required. By way of further response, this is, or was, a legal action and laches is an equitable and therefore, inapplicable, defense. See also response to paragraph 19, incorporated herein by reference. By way of further response, this allegation pleads no facts therefore it is denied under Pa. R. C. P. 1029( b ). 14. Denied as a conclusion of law to which no further response is required. To the degree this allegation is deemed factual or relevant, denied as after reasonable investigation, plaintiff is without knowledge or information sufficient to form a belief as to the truth of these allegations and the same are deemed denied. By way of further response, this allegation pleads no facts therefore it is denied under Pa. R. C. P. 1029( b ). 15. Denied as a conclusion of law to which no further response is required. To the degree this allegation is deemed factual or relevant, denied as after reasonable investigation, plaintiff is without knowledge or information sufficient to form a belief as to the truth of these allegations and the same are deemed denied. By way of further response, this allegation pleads no facts therefore it is denied under Pa. R. C. P. 1029( b ). 16. Denied as a conclusion of law to which no further response is required. To the degree this allegation is deemed factual or relevant, denied as after reasonable investigation, plaintiff is without knowledge or information sufficient to form a belief as to the truth of these allegations and the same are deemed denied. By way of further response, this allegation pleads no facts therefore it is denied under Pa. R. C. P. 1029( b ). 17. Denied as a conclusion of law to which no further response is required. To the degree this allegation is deemed factual or relevant, denied as after reasonable investigation, plaintiff is without knowledge or information sufficient to form a belief as to the truth of these allegations and the same are deemed denied. By way of further response, this allegation pleads no facts therefore it is denied under Pa. R. C. P. 1029( b ). 18. Denied as a conclusion of law to which no further response is required. To the degree this allegation is deemed factual or relevant, denied as after reasonable investigation, plaintiff is without knowledge or information sufficient to form a belief as to the truth of these allegations and the same are deemed denied. By way of further response, this allegation pleads no facts therefore it is denied under Pa. R. C. P. 1029( b ). 19. Denied as a conclusion of law to which no further response is required. To the degree this allegation is deemed factual, defendant last paid on account of the credit card at issue in this case on August 3, 2010. Plaintiff's complaint was filed on March 28, 2011. Plaintiff believes and therefore avers the applicable limitations period is four years as set forth at 42 Pa. C.S.A. Section 5525. Plaintiff further believes and therefore avers payment tolls limitations and as a result plaintiff's action was timely filed. By way of further response, this allegation pleads no facts therefore it is denied under Pa. R. C. P. 1029( b ). 20. Denied as a conclusion of law to which no further response is required. To the degree this allegation is deemed factual or relevant, denied as after reasonable investigation, plaintiff is without knowledge or information sufficient to form a belief as to the truth of these allegations and the same are deemed denied. By way of further response, this allegation pleads no facts therefore it is denied under Pa. R. C. P. 1029( b ). 21. Denied as a conclusion of law to which no further response is required. WHEREFORE, plaintiff moves the Court enter judgment for it and against defendant as per its complaint. BURTW NEIL & ASSOCIATES, P.C. By:_ Edward .O'Brien ireT Attorney for Plaintiff NOTICE: Burton Neil & Associates, P.C. is a debt collector. C-49104 Verification Edward J. O'Brien, Esquire, attorney for plaintiff, CITIBANK (SOUTH DAKOTA), N.A., makes this statement on its behalf as to the truthfulness of the facts set forth in the foregoing Reply to New Matter subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Counsel, rather than an officer or other representative of plaintiff is verifying the foregoing Reply to New Matter because plaintiff's officers and/or representatives are outside the jurisdiction of the court and the verification of none of them could be obtained within the time required to file this pleading. Plaintiff's counsel is verifying plaintiff's Reply to New Matter based upon information and belief from information in his file. Date: ward J. O'Brien, Esquire 4 l 1 . 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 CITIBANK (SOUTH DAKOTA), N.A. IN THE COURT OF COMMON PLEAS Plaintiff V. : CUMBERLAND COUNTY, PENNSYLVANIA NO. 11-3303 CV PATRICIA A ERDMAN Defendant : CIVIL ACTION - LAW Certificate of Service I, Edward J. O'Brien, Esquire do hereby certify that I served a true and correct copy of the within Reply to New Matter on Pro-Se defendant, Patricia A. Erdman at her address of record via first class mail, postage prepaid on the date set forth below. Date: Burton Neil & tes, P.C. By. EdvO rd J. O'Brien, E; Attorney for Plaintiff The law firm of Burton Neil & Associates is a debt collector. C-49104 Burton Neil & Associates, P.C. By: Edward J. O'Brien, Esquire ID. NO. 32985 1060 Andrew Drive, Suite 170 West Chester, PA 19380 Telephone: 610-696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA), N.A. Plaintiff V. PATRICIA A ERDMAN Defendant ICE .?.?, Ole .Sltl 3?? "? ?? ?v °,4J BAR SY?VN N IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 11-3303 CV CIVIL ACTION - LAW Praecipe for Entry of Judgment on Stipulation To the Prothonotary: Pursuant to the authority set forth in the attached agreement between the plaintiff and defendant, enter judgment on behalf of the plaintiff, CITIBANK (SOUTH DAKOTA), N.A., and against the defendant, PATRICIA A ERDMAN and assess damages in the sum of $21761.41, plus costs. B n ZdwarcrJ'. ssociates, P.C. B O'Brien, Esquire Attorneys for Plaintiff aw,Ailgoopd 5kl? a4 0- tGsosli ? And now, this 5*4" day of , 2011, judgment is entered on behalf of the plaintiff, i2lk o1?D! 3yS Ncyti;ce rV1A? le' CITIBANK (SOUTH DAKOTA), N.A. and against the defendant, PATRICIA A ERDMAN, in the sum of $21761.41, plus costs. Prothono of C BE D County Dep A? The law firm of Burton Neil & Associates is a debt collector. C-49104 Jun-16, 2011 6:51AM Burton Neil & Assoc. 6106964111 No-5415 P. 2 1 CREDITOR OFFER LETTER 6(16114116:55 AM Burton Neil & Associates. P.C. by: sward j. v isrten, kNuuc Lu. r4v..3Lya.) 1060 Andrew Drive, Suite 170 West Chester, PA 19380 V 11J-?? V`L 1 Ll% CITIBANK (SOUTH DAKOTA), N.A. : IN THE COURT OF COMMON PLEAS V. : CUMBERLAND COUNTY, PENNSYLVANIA ?T^ Y i •,-,^' nYY PATRICIA A ERDMAN Defendant : CIVIL ACTION - LAW Settlement Agreement with Stipalation for Entry of Judgment This Settlement Agreement is made by and between plaintiff CIMANK (SOUTH DAKOTA), N.A. (hereinafter referred to as "Citibank") and defendant Patricia A Erdman knerentarter rezerred io as --rsaman ): Whereas, Citibank filed legal action against Erdman seeking recovery for the balance owed on credit card account no. xxxx-xxxx-)o=-1549 (hereafter "the Account") in the sum of 521.761.41 plus court costs in the stun of S 130.00 (hereinafter "the Litigation"): and Whereas, Erdman acknowledges liability on the Account to Citibank but is not able to pay the amount due in the Litigation lump sum; and Whereas, Citibank and Erdman by this Settlement Agreement intend to resolve the Account and the Litigation in the manner set forth hereinafter. Now, therefore, in consideration of the mutual covenants and conditions herein contained, and in lieu of further litigation, the parties expressly intending to be legally bound hereby, We as follows: 1. Erdman agrees that judgment may be entered on behalf of Citibank and against Erdman for the amount due in the Litigation as set forth above. Interest will accrue on the judgment at 6% from the date it is entered on the records of the court. Replica Date: June 17, 2011 Document ID: 8570998 Rev: 136E-003-100801 Jun, 16. 2011 6:51AM Burton Neil & Assoc. 6106964111 No. 5415 P. 3 CREDITOR OFFER LETTER 61100116:56 AM 2. Citibank agrees to accept and Erdman agrees to pay the sum of $10,000.00 without interest in full and complete satisfaction of the judgment in installment payments, as follows: a. An initial payment of $2,181.00; followed by b. 22 payments of $340.00 each; and c. A final payment of $339.00 3. The payments will be due on the 28th day of each month beginning June 28, 2011 by check payable to Citibank (South Dakota), N.A. The checks are to be mailed to Burton Neil & Associates, P.C, at 1060 Andrew Drive, Suite 170, West Chester, PA 19380. 4. Citibank agrees to take no action on the judgment provided payments are made by Erdman in accordance with this agreement. 5. When the Settlement is paid, Citibank (South Dakota), N.A. will file with the court a praecipe to mark the judgment satisfied. 6. Should default occur, the full judgment amount including accrued interest will be due and owing less credit for all payments made by Erdman pursuant to this agreement. "Default" shall mean any of the following: Erdman's failure to make a required payment due hereunder by the due date or a check being returned NSF, In witness hereof, the parties hereby execute this Settlement Agreement intending to be bound legally thereby. A facsimile signow shall have the some foroe and effect as an original signature. Burto eil P.C. ,By: Ed rd J. Brie Attorney for Citibank (South Dakota), N.A. Date: 11 k4 Am A a u? if ltg P atricia A Erdman Date: ?1 1gI I) In making this communication, we advise our firm is a debt collector. nepuca uate: uune t i, lui i Document ID: 8570998 Rev: 136E-003-100801 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 CITIBANK (SOUTH DAKOTA), N.A. IN THE COURT OF COMMON PLEAS Plaintiff V. PATRICIA A ERDMAN : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 11-3303 CV Defendant : 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 7 - s `" L Prothonotary By: <?T)a, , j- ? 9 ?I Deputy If you have any questions concerning the above, please contact: Edward J. O'Brien, 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. 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 CITIBANK (SOUTH DAKOTA), N.A. 701 East 60th Street N. Sioux Falls, SD 57117 Plaintiff V. PATRICIA A ERDMAN 1419 Yorktowne Road Mechanicsburg PA 17050-1951 Defendant : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 11-3303 CV : CIVIL ACTION - LAW Certification of Address Understanding that false statements herein are subject to penalty under 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities, I verify that the above are the precise last-known addresses of the judgment creditor and debtor. Burton i ciates, P.C. By: Edward J. O'Brien, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates is a debt collector. 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 CITIBANK (SOUTH DAKOTA), N.A. : IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 11-3303 CV PATRICIA A ERDMAN Defendant : CIVIL ACTION - LAW Affidavit of Non-Military Understanding that false statements herein are subject to penalty under 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities, I verify that 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. Burt .1 iates, P.C. By: Edward J. O'Brien, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates is a debt collector. +llLL -U " IU OF E PRO1HONOLTA R'f 2013 JUN 13 PM 2: 56 CUMBERLAND COUNTY PENNSYLVANIA Burton Neil & Associates, P.C. By: Trenton A. Farmer, Esquire ID. NO. 209422 • 1060 Andrew Drive, Suite 1 70 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff CITIBANK (SOUTH.DAKOTA),N.A. : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 11-3303 CV PATRICIA A ER.DMAN Defendant : CIVIL ACTION - LAW Praecipe to Satisfy Judgment To the Prothonotary: Mark the judgment Satisfied . Burton Neil & . .C. By: AMP "Frei 01 A. . 'armer, Esquire Attorney for Plaintiff This is an attempt to collect a debt, and any information obtained will be used for that purpose. This communication is from a debt collector. C-49104 / 318 am] 4 Ck-k / 3/ ) b