HomeMy WebLinkAbout12-0485
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Burton Neil & Associates, P.C.
By: Neil Sarker, Esquire ID. NO. 203465
1060 Andrew Drive, Suite 170
West Chester, PA 19380
(610) 696-2120
Attornev for Plaintiff
CITIBANK, N.A.
701 East 60th Street N
Sioux Falls, SD 57117
Plaintiff
V.
ROLLACE E HEUSTESS
237 Ridge Hill Road
Mechanicsburg PA 17050-1747
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
:NO. /a - IVI
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 0-S
Telephone No. 717-249-3166 or 800-990-9108 D3. q,6 PD ATri/
C-55424 / 304
Grp' /l3 V.T
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BURTON NEIL & ASSOCIATES, P.C.
By: Neil Sarker, Esquire, Id. No. 203465
1060 Andrew Drive, Suite 170
West Chester, PA 19380
610-696-2120
Attornev for Plaintiff
CITIBANK, N.A. IN THE COURT OF COMMON PLEAS
701 East 60th Street N
Sioux Falls, SD 57117
Plaintiff
V.
CUMBERLAND COUNTY, PENNSYLVANIA
NO.
ROLLACE E HEUSTESS
237 Ridge Hill Road
Mechanicsburg PA 170501747
Defendant CIVIL ACTION -LAW
Complaint
Plaintiff is CITIBANK, N.A. with place of business located at 701 East 60th Street
North, Sioux Falls, South Dakota.
2. Defendant is Rollace E Heustess who resides 237 Ridge Hill Road, Mechanicsburg
PA 170501747, 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 5372.
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
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 $6,535.56 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 $6,535.56, and
the costs of this action.
Burton Neil & Associa C.
By:
Neil Sarker, squire
Attorney for Plaintiff
In making this communication, we advise Burton Neil & Associates, P.C. is a debt collector.
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1a!e P.d _ _ amount paid k # _ DatK# and follow paynrrtt IMtfuctlana on ravNea
WWWAltlnatdj&M Make chwk Payable to:CM Cards
5372 0653556 0653556 0008700 1117
New Balance:
$6,333.36 5372
Minimum Payment Due: Amount Enclosed:
$6,533.36
Payment Due Date:
09113/2011 Payment must ee recNvea by 5:11C PM
kcal time M the payment 1ue It..
000000 MC 32 A 0
ROLLACEE HEUSTESS
237 RIDGE HILL RD CITI CARDS
MECHANICSBURGPA 17050.1747 P.O. BOX 182564
COLUMBUS, OH 43218-2564
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Verification
Tiena Reynolds
I, , 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. I 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 unworn falsification to authorities.
Signature
C-55424
Rollace E Heustess
Account number ending 5372
1000
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
'C j J
2012 F EB -6 Ate 9: 12
CUMBL-RLAIND GOUh B `i``
PENNSYLVANIA
Citibank, NA
vs.
Rollace E Heustess
Case Number
2012-485
SHERIFF'S RETURN OF SERVICE
02/01/2012 11:30 AM - Stephen Bender, Deputy Sheriff, who being duly sworn according to law, states that on
February 1, 2012 at 1130 hours, he served a true copy of the within Complaint and Notice, upon the within
named defendant, to wit: Rollace E. Heustess, by making known unto himself personally, at 28 N. Market
Street Rear, Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time
handing to him personally the said true and correct copy of the same.
SHERIFF COST: $48.00
February 02, 2012
STEPHEN ENDER, DEPUTY
SO ANSWERS,
.
( N - w ? "`-
RbNNwY R ANDERSON, SHERIFF
(c)
Coun'YStjito Sheriff. leio-soot. Inc.
Pvt p1104N0"QTAR'
T"F CITIBANK, N.A. OF • IN THE COURT OF COMMON PLEAS
701 East 60th Street N, P' 2. t
Sioux Falls, SD 57117 nalaR 2 UM
Plaintiff `,UMBER SY ? CDO A `t- ERLAND COUNTY, PENNSYLVANIA
P E!?N
V.
NO. 12485-CIVIL TERM
ROLLACE E HEUSTESS
237 Ridge Hill Road
Mechanicsburg PA 17050-1747
Defendant : CIVIL ACTION - LAW
Praecipe for Default Judgment
To the Prothonotary:
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
$6,535.56
$6,535.56
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
AND DAMAG ASSESSED AS ABOVE.
NOTICE GIVE D A. IV.P. 236 /
te_A .,
Pro Prothori
Burton Neil & Associate P.C.
7
By: G
Neil Sarke Esquire
Attorney for Plaintiff
I.D. NO. 203465
1060 Andrew Drive, Suite 170
West Chester, PA 19380
The law firm of Burton Neil & Associates is a debt collector.
C-55424 / 221
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kr
CITIBANK, N.A.
Plaintiff
V.
ROLLACE E HEUSTESS
Defendant
TO: Rollace E Heustess
237 Ridge Hill Road
Mechanicsburg PA 17050-1747
DATE OF NOTICE: February 24, 2012
IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 12-485-CIVIL TERM
CIVIL ACTION - LAW
C-55424 / 265
IMPORTANT NOTICE
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 800-990-9108
C..
Burton Nei) i7
By:
Neil Sarker, Esqui
Attorney for Plaintiff
Identification No. 203465
1060 Andrew Drive, Suite 170
West Chester, PA 19380
In making this communication, we advise our office is a (610) 696-2120
debt collector.
Burton Neil & Associates, P.C.
By: Neil Sarker, Esquire ID. NO. 203465
1060 Andrew Drive, Suite 170
West Chester, PA 19380
610-696-2120
Attorney for Plaintiff
CITIBANK, N.A. IN THE COURT OF COMMON PLEAS
Plaintiff
CUMBERLAND COUNTY, PENNSYLVANIA
V.
NO. 12-485-CIVIL TERM
ROLLACE E HEUSTESS
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 3) 1& ho
i
Prothonotary
By:
neputy
If you have any questions concerning the above, please contact:
Neil Sarker, 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.