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HomeMy WebLinkAbout12-0483Burton 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, N.A. 701 East 60th Street N Sioux Falls, SD 57117 Plaintiff V. DAVID R STEIGELMAN 8 Robin Drive Shippensburg PA 172579484 Defendant D7 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. lp1. - '783 0i"itTem 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 (3-S Carlisle, PA 17013 4103.75 PD ATN Telephone No. 717-249-3166 or 800-990-9108 C* (13,189 C-56060 / 304 0,91038& 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, N.A. 701 East 60th Street N Sioux Falls, SD 57117 Plaintiff V. DAVID R STEIGELMAN 8 Robin Drive Shippensburg PA 172579484 Defendant IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION - LAW Complaint 1. Plaintiff is CITIBANK, N.A. with place of business located at 701 East 60th Street North, Sioux Falls, South Dakota. 2. Defendant is David R Steigelman who resides 8 Robin Drive, Shippensburg, 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. Defendant obtained extensions of credit from Citibank, N.A., successor in interest to Citibank (South Dakota), N.A., by means of a credit card account (hereafter the Account) with account number ending in 9447. 5. Citibank (South Dakota), N.A. merged into Citibank, N.A. in or about July 2011. 6. Accurate records of all debits and credits to the Account were maintained by plaintiff. 7. Defendant was provided with monthly statements for the Account including the billing statement attached hereto as Exhibit A (redacted to remove confidential information). The monthly statements accurately stated the previous balance and the debits and credits to the 1 Account for the prior billing period. 8. Defendant had for many months after receipt of a billing statement made payment on the Account or retained the statement without payment. 9. Defendant retained the Exhibit A statement without making payment by the stated due date. 10. Defendant's assent to the Account balance set forth in the Exhibit A statement is manifested through the prior conduct of defendant either making payment on the Account or retaining the statement without payment, after receipt of the monthly billing statements. 11. As a result of said assent, an account stated for the sum of $5,902.58 exists 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 $5,902.58, and the costs of this action. P.C. By ale D. Weinstein, Esquire ttorney for Plaintiff In making this communication, we advise Burton Neil & 4rssociates, P.C. is a debt collector. 8 ~ o jfij tIl J Q ? O r XI 1? e.erOXV C 7 xs umv,Gt UP I ? !2 o ? < a i a ? to ? r V, ? a x r a u CL p tr W I W C V, N y? ? ? y Q OC J C r = ? r 1w 11 1 oho 10 3 Y O V ? yw N ? _S S S w a `b ut < N q L V ? 5 > r ? ut a ` ut _ e. N . , N P O !O Y Y E c yI u Y y E E g u _< IYI o N Y y? C P >i u > c 31 > L'?? ^ wMAw?l' u't9TrCLz a i uiu<>vo 1 K-6 8 9! 1 IL eQ h Jim g$o it i, 36 0 :0, P >i 1 40 poi L > > ? ? N ! N ;>n; g g3 1.2 E;at E? N ?da(? t9 e C d 9 S 40 0L "1' P+M W"W1Wt Prd chGd a Oetadt elld laew ?aynwnt Nalrwpene ea feee/M alaeska191160ow Mewe~pew.MtYCM Cards 9447 0590258 0590258 0012400 0411 New Balance. $5.902.58 9447 Minimum Payment Our.. Awewd Entient $5.902.58 Payment Due Date: 11/02/2011 io PoInW4 Mud be Halved W SAO PM payment Ow date. 000000 MC 32 A 0 DAVID R STEIGELMAN a ROBIN DR CITI CARDS SHIPPENSBURG PA 17237-9484 P.O. BOX 182564 COLUMBUS, ON 43218-2561 EXHIBITL,A E 0 V a 0 9 Y V q C r F- r- L o LO V q uO q ? q? In J 7 RN oLn > w0 G'Dx a ?OoO 0 u 2- Umv) t a Em S z 'c u u T Ln a O o T a a O O E Or- T v fa c> > s > o 0 0 MM° c 2 C VI ° L ??? n > M m . N- E U a . o o °c W_ a E 3 . 0 -m -M O ,ip N ON c '5 .-C ¢ a`o? Ea a <E Z ?oE> a? 2ZE 1o mc- ?o a o ° c01 N W , ? 3o? EE oY a Q o E t 2 m " t N c L ? 0. n L ` ° Z m v1 =O m1p m-a a. w =) o ?oEa c'co Eo uu m ?Y vu x a v`` n 3 7 a Q Ln=E G1 u T 'm w ycY o ° cu N N L N? 7 > O = O v -oyu N =7 = .- ? ava° o ' -m? vo E? m Wye O c > ou o• 4 U ?w c y a E ?cm op W ,Cw7UJ ? 0 M? u p N V ? Ca L- a n ° N CL ~ O .= _ 3Q?? ? °/cE .2:E Z ¢c a E ~ Z c o Zo ;? m Z c - - Q > o O C ut .Y V ys+ o Y > > m .. ?dC N O LC c c d C T - w w y.+ a d L O O >.-o n u m- V 'oouu c. ' vnE v`° w i?TOm Q u 2 na aE Verification Ash?eY Cooley 1, , am employed by Citicorp Credit Services, Inc. (USA) (hereafter CCSI), a subsidiary of Citibank, N.A. (hereafter Citibank), which is successor in interest to Citibank (South Dakota), N.A. CCSI is a service provider for Citibank in that it services credit card accounts owned by Citibank This includes accounts previously owned by Citibank (South Dakota), N.A. which merged into Citibank in or about July 2011. 1 am authorized to make this verification on behalf of Citibank. 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. C-56060 David R Steigelman Account number ending 9447 1000 SHERIFF'S OFFICE OF CUMBERLAND COUNTY + -`{ Ronny R Anderson Sheriff I f t? r 1 i t Q?t?}4? of ?a+aGcr?r??t Jody S Smith -6 ??? 9 12 Chief Deputy a $, FEB Richard W Stewart ?JM?R?+'? Solicitor PENNSyLV,NH1P` Citibank, NA Case Number vs. 2012-483 David Richard Steigelman, Sr SHERIFF'S RETURN OF SERVICE 02/01/2012 12:19 PM - Elizabeth Muller, Deputy Sheriff, who being duly sworn according to law, states that on February 1, 2012 at 1219 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: David Richard Steigelman, Sr., by making known unto Gertrude Steigelman, Wife of Defendant at 8 Robin Drive, Shippensburg, Cumberland County, Pennsylvania 17257 its contents and at the same time handing to her personally the said true and correct copy of the same. ELI ETH MULLER, DEPUTY SHERIFF COST: $48.00 February 02, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF ic: CountySufte Shentf. Teleosott. Inc CITIBANK, N.A. 1 Tr o i ttl ?' is 'IN THE COURT OF COMMON PLEAS 701 East 60th Street N, Sioux Falls, 'SD 57117 29 i?F`1 2' Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA ERLAHD COW .1 ,'(??,'a!1 r+ V. DAVID R STEIGELMAN 8 Robin Drive Shippensbur:g PA 172579484 Defendant To the Prothonotary: NO. 12-483-CIVIL, CIVIL ACTION - LAW Praecipe for Default Judgment 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: $5,902.58 Less Credits: $552.54 TOTAL $5,350.04 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. lel"% JUDGME AND DAt NOTICE Pro BY DEFAULT ENTERED DES ASSESSED AS ABOVE. 'EhLFNDE LPA.R.CIV.PA31 The law firm of Burton Neil & Associates is a debt collector. C-56060 /221 Associates, P.C. Yde 0. Weinstein, Esquire IP. NO. 89678 060 Andrew Drive, Suite 170 West Chester, PA 19380 ask ® ku. SUIT ,"I qjUqS, al? No?b aaap J CITIBANK, N.A. IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 12-483-CIVIL DAVID R STEIGELMAN Defendant : CIVIL ACTION - LAW TO: David R Steigelman 8 Robin Drive Shippensburg PA 172579484 DATE OF NOTICE: February 24, 2012 IMPORTANT NOTICE C-56060 / 265 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 800-99 M-08 Burtbn Neil &/Xs?bciates, P.C. In making this communication, we advise our office is a debt collector. Yale D. einstein, Esquire Attorn for Plaintiff Ident' cation No. 89678 106 Andrew Drive, Suite 170 W t Chester, PA 19380 (610) 696-2120 Burton Neil & Associates, P.C. By: Yale D. Weinstein, Esquire ID. NO. 89678 1060 Andrea Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for!Plaintiff CITIBANK,'N.A. Plaintiff V. DAVID R STEIGELMAN Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 12-483-CIVIL : 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 S D 9 b7- Prothonotary 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.